As of January 1, 2021, producers are required to establish and operate a collection system for ITT/AV in Ontario. Producers should reference the ITT/AV Collection Systems compliance bulletin for guidance.

Collection Sites

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

• If the ITT/AV collection site is not part of a retail location, the site must accept all ITT/AV
• If the ITT/AV collection site is part of a retail location, the site must accept, at a minimum, all ITT/AV that are of a similar size and function supplied by the producer at that location.
• The ITT/AV collection site must be readily accessible to the public and must be operated and accept ITT/AV during normal business hours throughout the performance period.
• The ITT/AV collection site must accept, at a minimum, up to 50 kilograms of ITT/AV per day from any person.
• If the ITT/AV collection site is not part of a retail location and the ITT/AV collection site accepts more than as noted in #4, the operator of the site shall record the person’s name, contact information, any unique identifier assigned by the Registrar and the weight of ITT/AV accepted.

For Ontario Crown sites, municipal sites located in municipalities with a population less than 1,000 and First Nations Reserves, the following requirements apply:

• Once the site has four tonnes of ITT/AV, they may notify a PRO or a large producer for pick up
• The ITT/AV must be collected within one year from notification
• Does not apply to the Far North

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

Management Requirements

Producers must ensure that all ITT/AV 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.

Every year, every obligated producer shall manage a minimum amount of ITT/AV. For the 2022 performance period, every obligated producer shall make best efforts to ensure that at least 55% of ITT/AV supplied into Ontario is reuses, refurbished, or recycled. The amount of recovered resources should equal their management requirement, which is calculated based on the average of ITT/AV 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 ITT/AV processors listed on RPRA’s website to meet their management requirements. The list will be updated as required. View the list of ITT/AV 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 removed from used batteries used to enrich soil
• glass used as aggregate from EEE (up to a 15% max weight for ITT/AV)

The following must not be counted toward 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 (unless they enrich soil or as aggregate within allowable limits)
• aggregate over the allowed limits

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 EEE Regulation, including:

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

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 EEE Regulation, ITT/AV producers are required to register with the Authority.

Register

Some small producers may be exempt from registering and reporting with RPRA. Learn more here.

Have questions about registration? View the following resources:

• Am I an ITT/AV producer?
• What information is required for producers of ITT/AV to register with the Authority?
• Review our Supply Data Reporting Guide to learn how to register
• FAQs

Collection and Management System Reporting

ITT/AV producers, or PROs acting on their behalf, must submit the following information about their collection network in RPRA’s Registry within 30 days of registering:

• The location of every collection site that is part of their system to satisfy the accessibility requirements
• A description of their collection services (e.g., curbside)
• Every hauler, processor and refurbisher that is part of their collection or management system

Annual Supply Reporting

Each year, ITT/AV producers must submit the following information in RPRA’s Registry about the ITT/AV they supplied in Ontario:

• The weight of ITT/AV they supplied into Ontario in the previous two calendar years;
• If applicable, the weight of post-consumer recycled content or products eligible for a reduction in management requirements, supplied in the previous two calendar years;
• Provide a list of the brands that make up the ITT/AV they supplied into Ontario in the previous two calendar years

Supply data must be submitted in accordance with the EEE Registry Procedure – Verification and Audit. Starting in 2023 and every year thereafter, verification of supply data and management reductions (e.g., 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 D of the EEE 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 EEE Regulation. View this FAQ to determine if you are a small or large ITT/AV producer.

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

• What ITT/AV needs to be reported?
• Review our Supply Data Reporting Guide to learn how to report your data

Deadline: ITT/AV 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 55% of ITT/AV supplied into Ontario is processed, refurbished or reused. For more information on minimum management requirements for future years, review this FAQ. Each year, you, or your PRO will have to report on the extent to which you were able to achieve your management requirement.

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

• Total weight of ITT/AV collected
• Total weight of collected ITT/AV that were refurbished
• Input the weight of materials recovered from processing the collected ITT/AV (e.g. metals, plastics, 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 EEE Regulation.

Beginning in 2025, producers or PROs reporting on their behalf, will be required to submit an audit verifying their performance reporting. More information about audit reporting will be communicated in the future.

Deadline: ITT/AV performance reporting is due April 30 of each year.