As of July 1, 2020, producers are required to establish and operate a collection system for their single-use (primary) or rechargeable batteries and should reference the Battery Collection Systems compliance bulletin for guidance.

Collection Sites

Producers must ensure that consumers can drop off batteries free of charge at each site that is part of their collection system and satisfy the following requirements:

• If the battery collection site is not part of a retail location, it must accept all batteries
• If the site is part of a retail location, it must accept (at a minimum) all batteries that are of a similar size, function and category of batteries sold at the location
• The site must be readily accessible to the public and operate during normal business hours
• The site must accept, at a minimum, up to 15kg of batteries per day from any person
• If the site is not part of a retail location and accepts more than 15 kg of batteries from a person on a single day, the site operator must record the person’s name, contact information and the weight of batteries accepted

Producers can reduce their accessibility requirements by providing options such as curbside collection, mailback programs, or collection events.

Management Requirements

Producers must ensure that every battery picked up from a collection site, regardless of whether it is part of the producer’s collection system, is managed (reused, refurbished, or processed) within three months of the pickup date.

Each year, every obligated producer shall manage a minimum amount of batteries for each category. For the 2022 performance period, every producer shall make best efforts to ensure at least 40% of batteries supplied into Ontario are reused, refurbished, or recycled. The amount of recovered resources should equal their management requirement, which is calculated based on the average of batteries supplied over three years. For more information on minimum management requirements for future years, review this FAQ.

As of January 1, 2023, producers or PROs on their behalf can rely on battery processors listed on RPRA’s website to meet their management requirements that start in 2023. The list will be updated as required. View the list of battery processors here.

The regulation defines recovered resources as:

• materials used or destined to be used by a person for the making of new products or packaging
• materials used to enrich soil
• materials used as aggregate (up to a 15% max weight)

The following must not be counted towards the management requirement:

• materials that are land disposed
• materials that are incinerated or used as fuel or a fuel supplement
• materials that are stored, stockpiled, used as a daily landfill cover or otherwise deposited on land

Working with PROs

Producers have the choice of establishing and operating their own collection and management systems or working with one or more producer responsibility organizations (PROs) registered with the Authority to meet their obligations.

A PRO is a business established to contract with producers to provide collection and management and administrative services to help producers meet their regulatory obligations under the Batteries Regulation, including:

• Arranging the establishment or operation of battery collection and management systems (hauling, recycling, reuse or refurbishment services)
• Establishing or operating a collection or management system
• Preparing and submitting reports

PROs operate in a competitive market and producers can choose the PRO (or PROs) they want to work with. The terms and conditions of each contract with a PRO may vary. Registered PROs are listed here.

Under the Batteries Regulation, large battery producers are required to register with the Authority.

Register

Small producers are exempt from registering and reporting with RPRA. Learn more here.

Have questions about registration? View the following resources:

• Am I a battery producer?
• What information is required for producers of batteries to register with the Authority?
• Review our Supply Data Reporting Guide to learn how to register
• FAQs

Collection and Management System Reporting

Battery producers, or the PRO acting on their behalf, are required to establish and operate a collection and management system and report the following information in RPRA’s Registry within 30 days of registering:

• The location of every collection site in their system
• A description of their collection services
• Every hauler, processor or refurbisher that is part of their collection system

Annual Supply Reporting

Each year, large producers as defined in the Batteries Regulation must submit the following information in RPRA’s Registry about the batteries they supplied in Ontario:

• The weight of single-use batteries supplied into Ontario in the previous calendar year
• If applicable, the weight of post-consumer recycled content contained in the batteries supplied in Ontario in the previous calendar year
• Provide a list of brands that make up the single-use batteries you supplied into Ontario in the previous calendar year
• The weight of rechargeable batteries supplied into Ontario two years prior
• If applicable, the weight of post-consumer recycled content contained in the batteries supplied in Ontario two years prior
• Provide a list of brands that make up the single-use batteries you supplied into Ontario two years prior

Supply data must be submitted in accordance with the Registry Procedure – Verification and Audit. Starting in 2023 and every year thereafter, verification of supply data and post-consumer recycled content is only required for large producers, as defined in the Batteries and ITT/AV Supply Data Verification Procedure. Small producers will no longer be required to submit a verification report but will be subject to inspections. Verification requirements are outlined in Appendix C of the Registry Procedure – Verification and Audit.

Note: For the purposes of supply reporting verification, the definition of small and large producer is different than the definition in the Batteries Regulation. View this FAQ to determine if you are a small or large battery producer.

Have questions about supply data reporting? View the following resources:

• What batteries need to be reported?
• Review our Supply Data Reporting Guide to learn how to report your data

Deadline: Battery supply reporting is due April 30 of each year.

Annual Performance Reporting

For the 2022 performance period, producers are required to make best efforts to ensure that at least 40% of batteries supplied into Ontario are processed, refurbished or reused. Each year, you or your PRO will have to report how you were able to achieve the management requirement. To learn more about producer management requirements, read the following Compliance Bulletin: Battery Performance Requirements for Performance. For more information on minimum management requirements for future years, review this FAQ.

Producers, or PRO(s) on your behalf, are required to report the following information annually in RPRA’s Registry:

• Total weight of single-use and rechargeable batteries collected
• Total weight of single-use and rechargeable batteries that were refurbished
• Weight of materials recovered from processing the collected single-use and rechargeable batteries (e.g. metals, chemicals, etc.)

Most producers will work with a PRO to meet their mandatory collection and management requirements. If you have not yet contracted with a PRO, it is important that you do so as soon as possible to ensure that you can meet your obligations. In order for a PRO to report on your behalf, you must identify them in RPRA’s Registry. Learn more about PROs here.

If a PRO submits the performance report on your behalf, as a producer you are legally responsible to meet your requirements under the Batteries Regulation.

Beginning in 2024, producers or PROs reporting on their behalf, will be required to submit an audit verifying their performance reporting. The first audit, due in 2024, will be verifying performance for 2022 and 2023. Performance is audited every three years for the previous three performance periods, meaning the second audit will be due in 2027 (for the performance years 2024, 2025 and 2026). The audit must be conducted in accordance with Appendix C of the Registry Procedure – Verification and Audit. There is no audit required for the first performance period of July 1, 2020, to December 31, 2021.

Deadline: Battery performance reporting is due April 30 of each year.