Topic: Collection Systems

What are Blue Box producers’ obligations for public space receptacle collection?

A “Public space” means an outdoor area in a park, playground or beside/on a sidewalk, a public transit station or stop under municipal or provincial jurisdiction, including a track-level stop, to which the public is normally provided access.

Blue Box producers must provide the same quantity of public space receptacles as the previous WDTA program. Producers are obligated to collect materials before the bins are full and must repair or replace any damaged receptacles within one year of notification. Please note that producers are not obligated to provide receptacles for, or to collect from, any newly created public spaces after December 31, 2025.

As an HSP producer, what are my requirements under the HSP regulation?

As an obligated HSP producer, you are required to:

  • register and report annual supply and performance data of obligated materials
  • meet mandatory and enforceable requirements for collection and management
  • meet mandatory and enforceable requirements for promotion and education
  • meet mandatory and enforceable requirements for auditing, verification, and record keeping

These requirements vary based on material type and amount of material the producer supplies.

As an HSP producer of mercury-containing barometers, thermometers or thermostats, what are my collection requirements?

Producers of mercury-containing barometers, thermometers and thermostats are required to provide a call-in collection service. A pick up must be arranged for that type of HSP regardless of the brand within three months from being notified 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.

For producers to meet their obligations, they have the choice of establishing and operating their own collection and management system or working with one or more producer responsibility organizations (PROs) that are registered with RPRA.

Please contact the Compliance and Registry Team at 1-833-600-0530 or [email protected] to discuss other requirements under the HSP Regulation.

As an HSP producer of refillable propane containers, what are my collection requirements?

As of October 1, 2021, producers of refillable propane containers must establish and operate a call-in collection 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

As an HSP producer of oil filters, oil containers, antifreeze, pesticides, non-refillable pressurized containers, solvents, or paints and coatings, what are my collection requirements? 

Producers are required to establish and operate a collection system that meets the accessibility requirements in the regulation. Producers must ensure that all HSP collected is managed regardless of what their minimum management requirements are.

For producers to meet their obligations, they have the choice of establishing and operating their own collection and management system or working with one or more producer responsibility organizations (PROs) that are registered with RPRA.
Large producers have an additional requirement to provide call-in collection services. Learn more.

Please contact the Compliance Team at 1-833-600-0530 or [email protected] to discuss other requirements under the HSP Regulation.

See our FAQ to understand “Am I a small, large or exempt HSP producer?“. For more guidance, read the Hazardous and Special Products Collection Systems Compliance Bulletin.

How do I determine if I am an exempt HSP producer?

There are exemptions under the HSP Regulation for category A and B producers. If an HSP producer meets the exemption threshold for a material type, they are not required to establish a collection system, manage those materials or implement a promotion and education program.

Producers of refillable pressurized containers that meet the exemption threshold are still required to provide a call-in collection service.

An HSP producer qualifies for an exemption if their average weight of supply for the previous calendar year is less than or equal to the weight (in tonnes) specified in the chart below:

Type of HSPExempt (Less than <)
Oil Filters3.5
Non-refillable Pressurized Containers3
Antifreeze20
Oil Containers2
Solvents3
Paints and Coatings10
Pesticides1
Refillable Pressurized Containers8
Mercury-containing DevicesN/A
Fertilizers
Propane Containers (refillable)

Producers must verify that they continue to meet the exemption annually, since their average weight of supply will change from year to year.

See our FAQ “Am I a small, large, or exempt HSP producer?” to determine how to calculate if you are an exempt HSP producer.

HSP producers that meet the exemption criteria are exempt from:

  • Registering and reporting to RPRA
  • Establishing a collection and management system
  • Meeting a management requirement
  • Promotion and education requirements

Exempt producers must keep records related to the weight of HSP supplied into Ontario each year and provide them to RPRA upon request.

Producers are advised to confirm their exemption with the Compliance and Registry Team at 1-833-600-0530 or [email protected].

Are Blue Box materials that are supplied to the Industrial, Commercial, and Institutional (IC&I) sector obligated?

Blue Box materials supplied to the IC&I sector are not obligated, therefore, deductions are available for materials supplied to a consumer in an IC&I setting.

Blue Box producers may deduct materials that are collected from a business or institution where producers are not required to provide Blue Box collection services. Examples include:

  • Offices
  • Stores and shopping malls
  • Restaurants
  • Hotels
  • Hospitals
  • Community centres
  • Places of worship
  • Recreation facilities
  • Sports and entertainment venues
  • Universities and colleges
  • Manufacturing facilities
  • Golf courses
  • Cemeteries
  • Amusement parks

Producers are responsible for material collected from eligible sources in the producer run Common Collection System, Alternative or Supplemental Collections Systems. Material from these categories is not allowed to be deducted:

  • Material that is collected from a residence through a curbside or depot collection service.
  • Material that is generated at a facility (including multi-residential buildings, retirement homes, long-term care homes and schools).
  • Material that is collected from a public space (including an outdoor area in a park, playground or sidewalk, or a public transit station).
  • Material collected under an alternative or supplemental collection system.

Please see the Reporting Guidance Ineligible Source Deductions for the 2026 Blue Box Supply Report for more information on how to determine and use these deductions.

Also see our FAQs: ‘What deductions are available to producers under the Blue Box Regulation?’, ‘Who is a consumer under the Blue Box Regulation’

If a marketplace facilitator supplies products for which there is a brand holder resident in Canada, who is the obligated producer?

The brand holder is the obligated producer.

A marketplace facilitator only becomes obligated for products supplied through its marketplace where the producer would have been a retailer. If the producer is a brand holder or an importer, they remain the obligated producer even when products are distributed by a marketplace facilitator.

A retailer is a business that supplies products to consumers, whether online or at a physical location.