A person is considered a producer for ITT/AV under the Electrical and Electronic Equipment (EEE) Regulation if they supply ITT/AV into Ontario and:
- are the brand holder of the EEE and have residency in Canada
- have residency in Ontario and import EEE from outside of Ontario
- have residency in Ontario and markets directly to consumers in Ontario (e.g. online sales)
- does not have residency in Ontario and markets directly to consumers in Ontario (e.g. online sales)
Even if you do not meet the above definition, there may be circumstances where you qualify as a producer.
What are my obligations under the EEE Regulation?
Click the headings below to learn more about your obligations as a producer.
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.
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.
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.
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
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 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 D of the EEE Registry Procedure – Verification and Audit. There is no audit required for the first performance period of January 1, 2021, to December 31, 2021.
Deadline: ITT/AV performance reporting is due April 30 of each year.
Upcoming Important Dates
|ITT/AV producers who have not registered||Register with the Authority, unless exempt||Within 30 days of marketing ITT/AV equipment in Ontario|
|Small* ITT/AV producers||Submit annual Supply Report, which reports on the weight of ITT/AV equipment supplied into Ontario in 2021||April 30, 2023|
|Large ITT/AV producers||Submit annual Supply Report, which reports on the weight of ITT/AV equipment supplied into Ontario in 2021|
Submit a Supply Data Verification Report completed by a verifier/qualified person
|April 30, 2023|
|All producers, or a PRO on their behalf||Submit annual Performance Report, which reports the total weight of ITT/AV that was collected and refurbished, and the weight of materials recovered from processing in 2022||April 30, 2023|
*For the purposes of supply reporting verification, the definition of a 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.
Information for Ontario Electronic Stewardship WEEE Stewards
On December 31, 2020, the Waste Electrical and Electronic Equipment (WEEE) Program operated by Ontario Electronic Stewardship (OES) ended. Visit OES’s website for information related to the wind up of the WEEE Program: ontarioelectronicstewardship.ca/mecp-direction-to-oes-wind-up/
We are here to help you understand your requirements
To learn more about the EEE Regulation or to view past webinars and presentations, visit our Learning Series webpage on Understanding Ontario’s New EEE Regulation.