Yes, a producer can change PROs at any time. Producers must notify RPRA of any change in PROs within 30 days of the change.
Topic: Collection Systems
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 HSP | Exempt (Less than <) |
|---|---|
| Oil Filters | 3.5 |
| Non-refillable Pressurized Containers | 3 |
| Antifreeze | 20 |
| Oil Containers | 2 |
| Solvents | 3 |
| Paints and Coatings | 10 |
| Pesticides | 1 |
| Refillable Pressurized Containers | 8 |
| Mercury-containing Devices | N/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].
What are the types of Blue Box materials obligated under the Blue Box Regulation?
The following are the types of Blue Box Materials obligated under the Blue Box Regulation:
- Blue box packaging (primary, transport, convenience, service accessories, ancillary elements)
- Paper products
- Packaging-like products
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.
Is transport packaging that is removed by a retail location and not supplied to the consumer obligated?
No, transport packaging is only obligated when supplied to a consumer in Ontario. Any transport packaging removed by a retailer or other entity before the product is supplied to a consumer is not obligated under this regulation.
What is blue box product packaging?
Under the Blue Box Regulation, blue box product packaging includes:
- Primary packaging is for the containment, protection, handling, delivery and presentation of a product at the point of sale, including all packaging components, but does not include convenience packaging or transport packaging (e.g., film and cardboard used to package a 24-pack of water bottles and the label on the water bottle).
- Transportation packaging which is provided in addition to primary packaging to facilitate the handling or transportation of one or more products such as a pallet, bale wrap or box, but does not include a shipping container designed for transporting things by road, ship, rail or air.
- Convenience packaging includes service packaging and is used in addition to primary packaging to facilitate end users’ handling or transportation of one or more products. It also includes packaging that is supplied at the point of sale by food-service or other service providers to facilitate the delivery of goods and includes items such as bags and boxes that are supplied to end users at check out, whether or not there is a separate fee for these items.
- Service accessories are products supplied with a food or beverage product and facilitate the consumption of that food or beverage product and are ordinarily disposed of after a single use, whether or not they could be reused (e.g., a straw, cutlery or plate).
- Ancillary elements are integrated into packaging (directly hung or attached to packaging) and are intended to be consumed or disposed of with the primary packaging. Ancillary elements help the consumer use the product. Examples of ancillary packaging include a mascara brush forming part of a container closure, a toy on the top of candy acting as part of the closure, devices for measuring dosage that form part of a detergent container cap, or the pouring spout on a juice or milk carton.
What are paper products?
Under the Blue Box Regulation, paper products include printed and unprinted paper, such as a newspaper, magazine, greeting cards, calendars (promotional or purchased), notebooks and daily planners, promotional material, directory, catalogue or paper used for copying, writing or any other general use.
Hard or soft cover books and hardcover periodicals are not considered paper products.
What are packaging-like products?
Under the Blue Box Regulation, a packaging-like product is:
- ordinarily used for the containment, protection, handling, delivery, presentation or transportation of things
- ordinarily disposed of after a single use
- not used as packaging when it is supplied to the consumer
Packaging-like products include aluminum foil, a metal tray, plastic film, plastic wrap, wrapping paper, a paper bag, beverage cup, plastic bag, cardboard box or envelope, but does not include a product made from flexible plastic that is ordinarily used for the containment, protection, or handling of food, such as cling wrap, sandwich bags, or freezer bags.
If a producer is unsure whether or not their product is a packaging-like product, they can ask themselves the following questions to help determine whether the product is obligated to be reported under the Blue Box Regulation:
- Is the product actually packaging around a separate product?
- If yes, the product is not a packaging-like product. Instead, the product is considered blue box packaging and must be reported as blue box material. If no, continue to the next question.
- Is the product used for the containment, protection, handling, delivery, presentation or transportation of a thing(s)?
- If no, the product is not a packaging-like product. If yes, continue to the next question.
- Is the product typically disposed of after a single use (regardless if some may wash and reuse it)?
- If no, the product is not a packaging-like product. If yes, continue to the next question.
- Is the product made from flexible plastic that is for the containment, protection or handling of food?
- If yes, the product is not a packaging-like product. If no, the product is a packaging-like product and must be reported as blue box material.
If a producer is still unsure whether or not their product is a packaging-like product, they should contact the Compliance and Registry Team at 833-600-0530 or [email protected].
As an EEE producer who has registered, what other requirements do I need to meet?
Producers are required to establish and operate a collection system for ITT/AV that meets the accessibility requirements in the regulation. Producers must ensure that all ITT/AV collected is managed regardless of what their minimum management requirements are.
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.
Please contact the Compliance Team at 833-600-0530 or [email protected] to discuss other requirements under the EEE Regulation.
As a battery producer who has registered, what other requirements do I need to meet?
Producers are required to establish and operate a collection system for batteries that meets the accessibility requirements in the regulation. Producers must ensure that all batteries collected are managed regardless of their minimum management requirements.
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 the Authority.
Please contact the Compliance Team at 833-600-0530 or [email protected] to discuss other requirements under the Batteries Regulation.
What Tires Can Be Accepted at Collection Sites?
Tire collection sites are established to facilitate the responsible recycling and management of used tires. The types of tires accepted at these sites include, but are not limited to:
Examples of Accepted Tires:
- Automobile tires (cars, SUVs, light-duty trucks)
- Motorcycle tires
- Motor assisted bicycle tires (e.g., mopeds, non-kick scooters)
- Tractor tires
- Tires on industrial and agricultural vehicles and equipment
- Transport truck tires
- Trailer tires (e.g., boat trailers, RVs)
- All-terrain vehicle (ATV) tires
- Riding lawn mower tires
- Aircraft tires (if not supplied on an aircraft)
- Snow blower tires
- Small tires (1 kg to <5 kg), such as:
- Wheelbarrow tires
- Dolly tires
Examples of Tires That Are Not Accepted:
- Bicycle tires (muscle-powered)
- Stroller and kick scooter tires (non-motorized)
- Power-assisted bicycle tires (e.g., electric bicycles)
- Personal mobility device tires (e.g., wheelchairs, medical scooters)
Tires can be dropped off on or off the rim. Collection sites must accept tires on rims.
Does RPRA pay incentives for collecting, hauling, and processing materials?
No. RPRA does not administer contracts or provide incentives. Under the Regulations, producers will either work with a producer responsibility organization (PRO) or work directly with collection sites, haulers, refurbisher’s and/or processors to meet their collection and management requirements. Any reimbursement for services provided towards meeting a producers’ collection and management requirements will be determined through commercial contracts.
To discuss any payment, contact your service provider or a PRO. RPRA does not set the terms of the contractual arrangements between PROs and producers.