Hazardous and Special Products Producers

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A person is considered a producer under the HSP Regulation if they marketed oil filters, oil containers, antifreeze, solvents, paints and coatings, pesticides, pressurized containers (non-refillable and refillable) or refillable propane containers and:

  • Are the brand holder and have residency in Canada.
  • If no resident brand holder, the importer of the product and have residency in Ontario.
  • If no resident importer, the person marketing directly to consumers in Ontario and have residency in Ontario.
  • If no marketer resident in Ontario, the person marketing directly to consumers and have no residency in Ontario (e.g., e-retailers).

A person is considered a producer under the HSP Regulation if they marketed mercury-containing barometers, thermometers or thermostats and:

  • Are the brand holder and have residency in Canada.
  • If no resident brand holder, the brand holder of barometers, thermometers or thermostats marketed to consumers in Ontario that do not contain mercury.

A person is considered a producer under the HSP Regulation if they marketed fertilizers and:

  • Are the brand holder and have residency in Canada.

Even if you do not meet the above definitions, there may be circumstances where you qualify as a producer. Read the HSP Regulation for more detail or contact the Compliance Team at registry@rpra.ca or 1-833-600-0530 for support.

 

What are my obligations under the HSP Regulation?

Click the headings below to learn more about your obligations as a producer for each material. Materials that have the same requirements are grouped together, with differences identified below.

Oil filters and non-refillable pressurized containers are under category A in the HSP Regulation and have the following definitions:

  • Oil filters produced and/or arriving in Ontario, and which are for sale, directly or as part of a product.
  • Non-refillable pressurized containers that are used for the supply of a gas product, including propane, but cannot be refilled.

Registration

Under the HSP Regulation, producers of oil filters and non-refillable pressurized containers are required to register with RPRA.

Register here

If the producer’s average weight of supply in 2018, 2019, 2020 was above the threshold in the table below, the producer was required to register with RPRA by November 30, 2021. Obligated producers who have not yet registered are out of compliance with the regulation and may face compliance action by RPRA.

If a producer was not required to register in 2021, they must register on or before July 31 of the first calendar year that they exceed the threshold in the table below.

Type of HSPAverage weight of supply from the previous three calendar years (tonnes)
Oil filters3.5
Non-refillable pressurized containers3

For assistance in calculating your weighted average, please contact RPRA’s Compliance Team at registry@rpra.ca.

Producers that are required to register with RPRA by must provide the following information:

  • Business name, address, contact information, CRA number and Stewardship Ontario number (if applicable).
  • Identify any PROs who they have retained (if applicable at time of registration).
  • Name, contact information of the person who will be responsible for completing registration.
  • The total weight of each type of HSP that was supplied to consumers in Ontario in 2018, 2019 and 2020.

Producers are also required to pay their annual program fee at the time of registration.

Collection

From October 1, 2021, to December 31, 2022, producers are required to establish the following:

  • Collection sites – maintain at least the same number of sites that producers had at the end of the MHSW Program.
  • Collection events – make best efforts to hold the same number of events in each community as in 2020.
  • Call-in service (only applicable to large producers) – provide a phone number for communities to call to request a pickup (of 100 kg or more) if requested by a council of the band, a municipality not located in the Far North, a depot owned or operated by the Crown not in the Far North.
  • Large producers shall make reasonable efforts to collect the HSP within one year of being notified by a representative of a council of the band located on a reserve in the Far North.

View our Collection Systems Compliance Bulletin for further guidance on collection requirements that began January 1, 2023.

Management

As of October 1, 2021, producers, or PROs acting on their behalf, are required to establish and operate a management system and must:

  • Process all oil filters and non-refillable pressurized containers picked up from a collection site within three months from the date of the pickup.
  • Ensure that materials are processed by an HSP processor registered with RPRA.

Beginning October 1, 2021, to December 31, 2022, producers are required to recover an amount of material based on their average supply into Ontario and report on it starting in 2023.

Type of HSPPercentage for 2022
Oil filters85
Non-refillable pressurized containers20
A producer may count the weight of recovered resources from oil filters and non-refillable pressurized from October 1, 2021, to December 31, 2022.

As a producer, it is recommended that you confirm with your PRO that they have contracted with a processor on RPRA’s registered processor list.

If you are an HSP processor and are not listed, contact the Compliance Team at registry@rpra.ca or 1-833-600-0530.

Promotion and Education

Beginning October 1, 2021, producers of oil filters and non-refillable pressurized containers, or PROs acting on their behalf, are required to establish and operate a promotion and education program including the following:

  • Promote their collection and management services with respect to the type of HSP they are obligated for.
  • Provide the following information on a website with respect to that type of HSP:
    • The location of each HSP collection site established or operated by the producer that is accessible to the public and the types of HSP accepted at each site.
    • The location and date of each HSP collection event held by the producer and the types of HSP accepted at each event.
    • A description of the collection services provided by the producer, other than HSP collection sites and HSP collection events.
    • A description of how the producer manages that type of HSP after it is collected.
  • Create promotional and educational materials with respect to that type of HSP that include the following:
    • The website URL.
    • A description of how that type of HSP is collected and managed.
  • The producer shall make the promotional and educational materials available to retailers that supply that type of HSP, municipal governments and Indigenous communities, and shall solicit and consider feedback on how the promotional and educational materials can be improved.
  • The producer shall promote each HSP collection event for that type of HSP in the local municipality or territorial district where it will be held for at least one week prior to the date of the event using a combination of two or more forms of media, including but not limited to:
    • Local print publications.
    • Local print media.
    • Local radio.
    • Local signage or social media.

Reporting

Supply Data Report

Starting in 2022, and every year thereafter, HSP producers are required to submit a report that provides the total weight of HSP they supplied to consumers in Ontario in the previous calendar year. Producers must also provide a brand supply list that makes up their supply data.

Producers must submit supply data in accordance with Appendix B of the Hazardous and Special Products Verification and Audit Procedure.

Performance Report

Starting in 2023, producers, or PROs on their behalf, are required to submit an annual report with the following information from October 1, 2021 to December 31, 2022:

  • A list of all collection services provided, including collection sites, collection events, call-in collection services and curbside pickup.
  • A description of the activities undertaken by the producer to comply with the promotion and education requirements.
  • The name and contact information of each processor.
  • The weight of the material(s) supplied to consumers in Ontario.
  • The weight of recovered resources.
  • The weight of recovered resources accounted for to meet the producer’s management requirements.
  • The weight of materials processed from that type of HSP that were:
    • Land disposed,
    • Incinerated,
    • Used as a fuel or a fuel supplement, or
    • Stored, stockpiled, used as daily landfill cover or otherwise deposited on land.

Collection and Management System Reporting

Producers, or PROs acting on their behalf, are required to establish and operate a collection and management system and report the following information to RPRA annually:

  • A list of all collection services provided, including:
    • The locations of collection sites,
    • If applicable:
      • Curbside collection services,
      • Collection upon request,
      • Collection events, and
    • Call-in collection services.
  • Every hauler, processor or disposal facility that is part of their management system.

View our Collection Systems Compliance Bulletin for further guidance on collection requirements that began January 1, 2023.

Audit Report

RPRA will communicate requirements for HSP performance audits in advance of the registry opening for annual reporting in summer 2024.   

Record Keeping

Beginning October 1, 2021, producers are required to keep records for every HSP material for a period of five years from the date of the record being created.

Producers must keep records that relate to the following:

  • Arranging for the establishment or operation of a collection or management system.
  • Establishing or operating a collection or management system.
  • Information required to be submitted to RPRA through the Registry.
  • Implementing a promotion and education program.
  • Weight of each type of HSP within each applicable category of HSP supplied to consumers in Ontario, regardless of whether information about the weight was required to be submitted to RPRA.
  • Any agreements that relate to the above records.

Oil containers, antifreeze, pesticides, refillable pressurized containers, solvents, paints and coatings are under category B in the HSP Regulation and have the following definitions:

  • Oil containers that have a capacity of 30 litres or less and that was manufactured and used for the purpose of containing lubricating oil.
  • Antifreeze that contains ethylene or propylene glycol used or intended for use as a vehicle engine coolant.
  • Pesticides, fungicides, herbicides or insecticides that are registered under the Pest Control Products Act.
  • Refillable pressurized containers that are used for the supply of a gas and can be refilled.
  • Solvents that are used to dissolve or thin a compatible substance, comprised of 10% or more of water-immiscible liquid hydrocarbons, including halogen-substituted liquid hydrocarbons.
  • Paints and coatings that contain latex, oil or solvent-based architectural coatings whether tinted or untinted, non-pesticide marine paints, paints for automotive craft and industrial applications.

Under the following material categories, the product’s primary packaging is also obligated:

  • Antifreeze
  • Paints and coatings
  • Pesticides
  • Solvents

Note: Primary packaging made of corrugated and boxboard boxes, plastic film, shrink wrap or printed materials is not obligated under the HSP Regulation, please see the Blue Box Regulation for more information and possible obligations.

  • Oil containers, solvents, paints and coatings, fertilizers and pesticides are only obligated when supplied in a container that has a capacity of 30 litres or 30 kilograms or less.
  • All antifreeze supplied – regardless of container size – must be reported. However, the antifreeze container is only obligated when supplied in a container that has a capacity of 30 litres or 30 kilograms or less.

Registration

Under the HSP Regulation, producers of oil containers, antifreeze, pesticides, refillable pressurized containers, solvents, paints and coatings are required to register with RPRA.

Register here

If the producer’s average weight of supply in 2018, 2019, 2020 was above the threshold in the table below, the producer was required to register with RPRA by November 30, 2021. Obligated producers who have not yet registered are out of compliance with the regulation and may face compliance action by RPRA.

If a producer was not required to register in 2021, they must register on or before July 31 of the first calendar year that they exceed the threshold in the table below.

Type of HSPAverage weight of supply from the previous three calendar years (tonnes)
Antifreeze20
Oil Containers2
Paints and coatings10
Pesticides1
Refillable pressurized containers8
Solvents3

For assistance in calculating your weighted average, please contact RPRA’s Compliance Team at registry@rpra.ca.

Producers that are required to register with RPRA must provide the following information:

  • Business name, address, contact information, CRA number and Stewardship Ontario number (if applicable).
  • Identify any PROs who they have retained (if applicable at time of registration).
  • Name, contact information of the person who will be responsible for completing registration.

Producers are also required to pay their annual program fee at the time of registration.

When registering with RPRA, producers of oil containers, antifreeze, pesticides, solvents, paints and coatings and refillable pressurized containers are required to submit the following information:

  • The total weight of each type of HSP that was supplied to consumers in Ontario in 2018, 2019 and 2020.

Note: At this time, obligated producers of factory fill antifreeze are not required to include the weight of factory fill antifreeze when they report the total weight of obligated antifreeze they supplied. The deadline for reporting factory fill antifreeze supply will be communicated at a later date.

Collection

From October 1, 2021, to December 31, 2022, producers are required to establish the following:

  • Collection sites – maintain at least the same number of sites that producers had at the end of the MHSW Program.
  • Collection events – make best efforts to hold same number of events in each community as in 2020.
  • Call-in service (only applicable to large producers) – provide a phone number for communities to call to request a pickup (of 100 kg or more) if requested by a council of the band, a municipality not located in the Far North, a depot owned or operated by the Crown not in the Far North.
  • Large producers shall make reasonable efforts to collect the HSP within one year of being notified by a representative of a council of the band located on a reserve in the Far North.

View our Collection Systems Compliance Bulletin for further guidance on collection requirements that began January 1, 2023.

Management

As of October 1, 2021, producers, or PROs acting on their behalf, are required to establish and operate a system for managing HSP by satisfying their management requirements as follows:

  • All oil containers, antifreeze, refillable pressurized containers, solvents, paints and coatings picked up from a collection site must be processed within three months from the date of the pickup.
  • Producers of pesticides must ensure that pesticides are disposed of at an HSP disposal facility registered with RPRA no later than three months after the day the pesticides are collected.
  • Producers must ensure that materials are processed by an HSP processor registered with RPRA.

Further guidance on the new management requirements for small and large producers will be provided closer to the requirement start date of January 1, 2023.

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

As a producer, it is recommended that you confirm with your PRO that they have contracted with a processor on RPRA’s registered processor list.

If you are an HSP processor and are not listed, contact the Compliance Team at registry@rpra.ca or 1-833-600-0530.

Promotion and Education

Beginning October 1, 2021, producers, or PROs acting on their behalf, of oil containers, antifreeze, pesticides, solvents, paints and coatings are required to establish and operate a promotion and education program including the following:

  • Promote their collection and management services with respect to the type of HSP they are obligated for.
  • Provide the following information on a website with respect to that type of HSP:
    • The location of each HSP collection site established or operated by the producer that is accessible to the public and the types of HSP accepted at each site.
    • The location and date of each HSP collection event held by the producer and the types of HSP accepted at each event.
    • A description of the collection services provided by the producer, other than HSP collection sites and HSP collection events.
    • A description of how the producer manages that type of HSP after it is collected.
  • Create promotional and educational materials with respect to that type of HSP that include the following:
    • The address of the website.
    • A description of how that type of HSP is collected and managed.
  • The producer shall make the promotional and educational materials available to retailers that supply that type of HSP, municipal governments and Indigenous communities, and shall solicit and consider feedback on how the promotional and educational materials can be improved.
  • The producer shall promote each HSP collection event for that type of HSP in the local municipality or territorial district where it will be held for at least one week prior to the date of the event using a combination of two or more forms of media, including but not limited to:
    • Local print publications.
    • Local print media.
    • Local radio.
    • Local signage or social media.

Note: there are no promotion and education requirements for refillable pressurized containers.

Reporting

Supply Data Report

Starting in 2022, and every year thereafter, HSP producers are required to submit a report that provides the total weight of HSP they supplied to consumers in Ontario in the previous calendar year. Producers must also provide a brand supply list that makes up their supply data.

Producers must submit supply data in accordance with Appendix B of the Hazardous and Special Products Verification and Audit Procedure.

Note: At this time, obligated producers of factory fill antifreeze are not required to include the weight of factory fill antifreeze when they report the total weight of obligated antifreeze they supplied. The deadline for reporting factory fill antifreeze supply will be communicated at a later date.

Performance Report

Starting in 2023, producers are required to submit an annual report with the following information from October 1, 2021 to December 31, 2022:

  • A list of all collection services provided, including collection sites, collection events, call-in collection services and curbside pickup.
  • A description of the activities undertaken by the producer to comply with the promotion and education requirements.
  • The name and contact information of each processor.
  • The weight of the material(s) supplied to consumers in Ontario.
  • The weight of recovered resources.
  • The weight of materials processed from that type of HSP that were:
    • Land disposed,
    • Incinerated,
    • Used as a fuel or a fuel supplement, or
    • Stored, stockpiled, used as daily landfill cover or otherwise deposited on land.

Collection and Management System Reporting

Producers, or PROs acting on their behalf, are required to establish and operate a collection and management system and report the following information to RPRA annually:

  • A list of all collection services provided, including:
    • The locations of collection sites,
    • If applicable:
      • Curbside collection services,
      • Collection upon request,
      • Collection events, and
    • Call-in collection services.
  • Every hauler, processor or disposal facility that is part of their management system.

View our Collection Systems Compliance Bulletin for further guidance on collection requirements that began January 1, 2023.

Audit Report

RPRA will communicate requirements for HSP performance audits in advance of the registry opening for annual reporting in summer 2024.

Record Keeping

Beginning October 1, 2021, producers are required to keep records for every HSP material for a period of five years from the date of the record being created.

Producers must keep records that relate to the following:

  • Arranging for the establishment or operation of a collection or management system.
  • Establishing or operating a collection or management system.
  • Information required to be submitted to RPRA through the Registry.
  • Implementing a promotion and education program.
  • Weight of each type of HSP within each applicable category of HSP supplied to consumers in Ontario, regardless of whether information about the weight was required to be submitted to RPRA.
  • Any agreements that relate to the above records.

Barometers, thermometers and thermostats are under category C in the HSP Regulation and have the following definitions:

  • Barometers that contain mercury, are intended for residential use and may contain electronic components.
  • Thermometers that contain mercury, are intended for residential use to measure body or air temperature and may contain electronic component.
  • Thermostats that contain mercury, and may contain electronic components.

Registration

Under the HSP Regulation, producers of mercury-containing barometers, thermometers and thermostats are required to register with RPRA.

Register here

Producers were required to register with RPRA by November 30, 2021. Otherwise, a producer must register within 30 days of mercury-containing barometers, thermometers or thermostats being supplied in Ontario. Obligated producers who have not yet registered are out of compliance with the regulation and may face compliance action by RPRA.

Producers that are required to register must provide the following information:

  • Business name, address, contact information, CRA number and Stewardship Ontario number (if applicable).
  • Name, contact information of the person who will be responsible for completing registration.

Producers are also required to pay their annual program fee at the time of registration.

Collection

As of October 1, 2021, producers of mercury-containing barometers, thermometers and thermostats must provide a call-in service number for communities to call to request a pickup if requested by the following representatives:

  • A council of the band.
  • A municipality not located in the Far North.
  • A territorial district that is not located in the Far North.
  • A depot owned or operated by the Crown not in the Far North.

Producers shall make reasonable efforts to collect the HSP within one year of being notified by a representative of a council of the band located on a reserve in the Far North.

View our Collection Systems Compliance Bulletin for further guidance on collection requirements that began January 1, 2023.

Management

Producer shall ensure that, no later than three months after the day the material is collected, the HSP is processed by an HSP processor who is registered.

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

If you are an HSP processor and are not listed, contact the Compliance Team at registry@rpra.ca or 1-833-600-0530.

Promotion and Education

Beginning October 1, 2021, producers, or PROs acting on their behalf, of mercury-containing devices are required to establish and operate a promotion and education program that:

  • Promotes their collection and management services with respect to the type of HSP they are obligated for.
  • Provides the following information on a website with respect to that type of HSP:
    • The presence of mercury in that type of HSP.
    • How to distinguish that type of HSP from similar products that do not contain mercury.
    • The hazards to human health and the environment related to mercury.
    • How consumers can properly dispose of that type of HSP.
    • A description of the collection services provided by the producer under the regulation for that type of HSP.
    • A description of how the producer manages that type of HSP after it is collected under the regulation.
  • Creates promotional and educational materials with respect to that type of HSP that include the following:
    • The address of the website.
    • A description of how that type of HSP is collected and managed.
  • The producer shall make the promotional and educational materials available to retailers that supply that type of HSP or similar products that do not contain mercury, municipal governments and Indigenous communities, and shall solicit and consider feedback from those retailers, municipal governments and Indigenous communities on how the promotional and educational materials can be improved.

Reporting

Supply Data Report

Producers are not required to submit supply data to RPRA. However, starting in 2022, and every year thereafter, producers must confirm if their revenue is above or below $2 million and provide a brand supply list that makes up their supply data. A brand supply list is a list of brands of obligated products that a producer supplies to consumers in Ontario. Each program has different requirements regarding how a producer must submit a brand supply list. For more information, contact RPRA’s Compliance Team at 1-833-600-0530 or by emailing registry@rpra.ca.

Performance Report

Starting in 2023, producers are required to submit an annual report with the following information from October 1, 2021 to December 31, 2022:

  • A list of call-in collection services, and if applicable, collection sites and collection events.
  • A description of the activities undertaken by the producer to comply with the promotion and education requirements.
  • The name and contact information of each processor.
  • The weight of recovered resources.
  • The weight of materials processed from that type of HSP that were:
    • Land disposed,
    • Incinerated,
    • Used as a fuel or a fuel supplement, or
    • Stored, stockpiled, used as daily landfill cover or otherwise deposited on land
  • The weight of mercury recovered from that type of HSP.

View our Collection Systems Compliance Bulletin for further guidance on collection requirements that began January 1, 2023.

Collection and Management System Reporting

Producers, or PROs acting on their behalf, are required to report the call-in collection services to RPRA annually.

Audit Report

RPRA will communicate requirements for HSP performance audits in advance of the registry opening for annual reporting in summer 2024.

Record Keeping

Beginning October 1, 2021, producers are required to keep records for every HSP material for a period of five years from the date of the record being created.

Producers must keep records that relate to the following:

  • Arranging for the establishment or operation of a collection or management system.
  • Establishing or operating a collection or management system.
  • Information required to be submitted to RPRA through the Registry.
  • Implementing a promotion and education program.
  • Weight of each type of HSP within each applicable category of HSP supplied to consumers in Ontario, regardless of whether information about the weight was required to be submitted to RPRA.
  • Any agreements that relate to the above records.

Fertilizers are under category D in the HSP Regulation and have the following definition:

  • Any substance or mixture of substances containing nitrogen, phosphorus, potassium or other plant food, manufactured, sold or represented for use as a plant nutrient and regulated under the Fertilizers Act (Canada).

Registration

Under the HSP Regulation, producers of fertilizers are required to register with RPRA.

Register here

If producers supplied fertilizers between January 01, 2018, and October 31, 2021, they were required to register with RPRA by November 30, 2021. Otherwise, a producer must register within 30 days of fertilizers being supplied in Ontario. Obligated producers who have not yet registered are out of compliance with the regulation and may face compliance action by RPRA.

Producers that are required to register must provide the following information:

  • Business name, address, contact information, CRA number and Stewardship Ontario number (if applicable).
  • Name, and contact information of any PRO retained (if applicable at time of registration).
  • Name, and contact information of an employee who has the authority to bind the producer and who will be responsible for completing the registration.
  • Type of HSP and the category to which it belongs.
  • The date on which the fertilizer was supplied to consumers in Ontario.

Producers are also required to pay their annual program fee at the time of registration.

Promotion and Education

Producers required to register by November 30, 2021, are obligated to:

  • Establish and operate a promotion and education program starting in 2022.
  • Provide information on a website about how consumers can use, share and properly dispose of fertilizer.
  • Create promotional and education materials that include:
    • The website URL.
    • A description of how consumers can use, share and properly dispose of fertilizer.
  • Solicit, consider feedback from, and make the promotional and education materials available to:
    • Indigenous communities.
    • Municipal governments.
    • Retailers that supply fertilizers.
  • Provide information to municipalities on innovative end-use options for fertilizers as an alternative to disposal.

Reporting

Supply Data Report

Producers of fertilizers are not required to submit supply data to RPRA. However, starting in 2022, and every year thereafter, producers must confirm if their revenue is above or below $2 million and provide a brand supply list that makes up their supply data. A brand supply list is a list of brands of obligated products that a producer supplies to consumers in Ontario. Each program has different requirements regarding how a producer must submit a brand supply list. For more information, contact RPRA’s Compliance Team at 1-833-600-0530 or by emailing registry@rpra.ca.

Performance Report

Beginning in 2023, producers required to register by November 30, 2021, shall submit an annual report to RPRA that includes a description of the activities undertaken by the producer to comply with the promotion and education requirements from October 1, 2021 to December 31, 2022.

Record Keeping

Producers are required to keep records in a paper or electronic format that can be examined or accessed in Ontario for a period of five years from the date of the record being created.

Producers must keep records that relate to the following:

  • Information required to be submitted to RPRA through the Registry.
  • Implementing a promotion and education program.
  • Weight of fertilizers supplied to consumers in Ontario, regardless of whether information about the weight was required to be submitted to RPRA.
  • Any agreements that relate to the above records.

Refillable propane containers are under category E in the HSP Regulation and have the following definition:

  • A pressurized container that can be refilled, has a water capacity of 109 litres or less and is used only for propane.

Registration

Under the HSP Regulation, producers of refillable propane containers are required to register with RPRA.

Register here

If producers supplied refillable propane containers between January 1, 2018, and October 31, 2021, they were required to register with RPRA by November 30, 2021. Otherwise, a producer must register within 30 days of refillable propane containers being supplied in Ontario. Obligated producers who have not yet registered are out of compliance with the regulation and may face compliance action by RPRA.

Producers that are required to register must provide the following information:

  • Business name, address, contact information, CRA number and Stewardship Ontario number (if applicable).
  • Name and contact information of any PRO retained (if applicable at time of registration).
  • Name and contact information of an employee who has the authority to bind the producer and who will be responsible for completing the registration.
  • Type of HSP and the category to which it belongs.
  • The date on which the refillable propane container was supplied to consumers in Ontario.

Producers are also required to pay their annual program fee at the time of registration.

Collection

As of October 1, 2021, producers of refillable propane containers must establish and operate a call-in service number for the following representatives to request a pickup:

  • A council of the band.
  • A municipality that is not located in the Far North.
  • A reserve in the Far North.
  • A territorial district that is not located in the Far North.
  • A depot where refillable propane containers are collected, that is owned or operated by the Crown in right of Ontario and that is not located in the Far North.

View our Collection Systems Compliance Bulletin for further guidance on collection requirements that began January 1, 2023.

Reporting

Supply Data Report

Producers are not required to submit supply data to RPRA. However, starting in 2022, and every year thereafter, producers must confirm if their revenue is above or below $2 million and provide a brand supply list that makes up their supply data. A brand supply list is a list of brands of obligated products that a producer supplies to consumers in Ontario. Each program has different requirements regarding how a producer must submit a brand supply list. For more information, contact RPRA’s Compliance Team at 1-833-600-0530 or by emailing registry@rpra.ca.

Record Keeping

Producers are required to keep records in a paper or electronic format that can be examined or accessed in Ontario for a period of five years from the date of the record being created.

Producers must keep records that relate to the following:

  • Arranging for the establishment or operation of a collection or management system.
  • Establishing or operating a collection or management system.
  • Information required to be submitted to RPRA through the Registry.
  • Implementing a promotion and education program.
  • Weight of refillable propane containers supplied to consumers in Ontario, regardless of whether information about the weight was required to be submitted to RPRA.
  • Any agreements that relate to the above records.

Working with PROs

Producers have the choice of working with one or more producer responsibility organizations (PROs) registered with RPRA to meet their obligations.

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

  • Arranging, establishing or operating a collection or management system.
  • Arranging, establishing or operating a promotion and education system.
  • Preparing and submitting reports.

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

To view a list of PROs, visit our HSP PRO page.

 

Upcoming Important Dates

RequirementProducer CategoriesDeadline
Register with RPRAAll ProducersA producer must register on or before July 31 of the first calendar year in which the producer exceeds the threshold outlined here.
Supply Reporting
Submit list of brands supplied in 2022All ProducersSeptember 15, 2023*
Submit supply data from 2022 year and verification report Categories A and BSeptember 15, 2023*
Confirm revenue from 2022Categories C, D and ESeptember 15, 2023*
Collection and Management System Reporting
Submit a collection and management system reportCategories A, B, and CSeptember 15, 2023*
Performance Reporting
Submit annual performance report based on data from October 1, 2021 to December 31, 2022Categories A, B, C and DSeptember 15, 2023*
Submit audit report based on data from October 1, 2021 to December 31, 2022Categories A, B, and C (producers reporting on their own activities)2024**
Submit promotion and education report based on activities from October 1, 2021 to December 31, 2022Categories A, B (except producers of refillable pressurized containers), C and DSeptember 15, 2023*
*RPRA’s Registrar is delaying HSP supply and performance reporting. The July 31 reporting deadline in the HSP Regulation will not be enforced.

**RPRA’s Registrar originally delayed the HSP performance audit requirement from July 31, 2023, to November 30, 2023, but due to the ongoing development of the procedure, the 2023 performance audit will be delayed until 2024. More information about HSP audit reporting will be communicated in the future. 

 

We are here to help you understand your requirements

To learn more about the HSP Regulation or to view past webinars and presentations, visit our Learning Series webpage on Understanding Ontario’s New Hazardous and Special Products Regulation.

If you have questions relating to the HSP Regulation, contact our Compliance Team at registry@rpra.ca or 1-833-600-0530 for support.