Topic: Management activities

How can I ensure that my products or packaging are collected and sent for management when I don’t know where they end up once a consumer discards them?

Producers are not required to collect and manage their own branded products and materials. Instead, a producer is expected to collect and manage a portion of similar materials in Ontario. The portion of material that a producer collects and manages is known as their minimum management requirement. A minimum management requirement, which is set based on calculations outlined in the applicable Regulation, is the weight of the products or packaging that the producer must ensure is collected and managed. The calculated amount is proportionate to the weight of materials that producer supplied into the province.

For example, a producer who supplied laptops into Ontario does not need to collect and manage their own branded laptops. Instead, they must ensure that they collect and manage an equivalent weight of information technology, telecommunications, and audio-visual equipment (ITT/AV) materials.

Similarly, a producer who supplied cardboard boxes into Ontario does not need to collect and manage those exact cardboard boxes. Rather, they need to ensure that an equivalent weight of paper is collected and managed.

Almost all producers will work with producer responsibility organizations (PROs) for the purposes of meeting their obligations to collect and manage materials. PROs establish collection and management systems across Ontario for different material types. A producer can meet their obligations to collect and manage materials by entering into a contract with a PRO to provide these services on their behalf.

What are Blue Box management requirements?

A producer’s management requirement is how much Blue Box material they must ensure is collected and processed into recovered resources each year. Management requirements are calculated based on what they supplied into Ontario two years prior and the resource recovery percentage as set in the regulation. A producer’s management requirement is calculated separately for each Blue Box material category (beverage container, glass, flexible plastic, rigid plastic, metal and paper).

Some producer are exempt from having a management requirement based on their supply data, for more information on exemptions see the FAQ Are there exemptions for Blue Box producers? A producer that does not have a management requirement does not have any collection, management or promotion and education obligations.

A producer with a management requirement must also provide collection and promotion and education services in Ontario. Most producers will contract the services of a producer responsibility organization (PRO) to meet their collection, management and promotion and education obligations.

To view your management requirement(s), log into your registry account, download a copy of your Blue Box Supply Report and review the section with your minimum management requirements. Management requirement for a given year are determine by supply data from two years prior. For example, 2023 management requirements were based on 2021 supply data (submitted in producers’ 2022 Supply Report).

Unsure if you are a Blue Box producer? See our FAQs Am I a producer of Blue Box product packaging? And Am I a producer of paper products and packaging-like products?

As a lighting producer who has registered, what other requirements do I need to meet?

As of January 1, 2023, lighting producers are required to establish and operate a lighting collection system that meets the accessibility requirements in the EEE Regulation. A producer must ensure that all lighting collected is managed regardless of what their minimum management requirements is.

A producer has 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.

For detailed information on lighting producer requirements, visit our Lighting Producer webpage.

If you have further questions about lighting producer requirements, contact the Compliance and Registry Team at registry@rpra.ca or 1-833-600-0530.

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

A lighting producer qualifies for an exemption if their management requirement isn’t more than 350 kg. The lighting producer is exempt from the following:

  • Registering and reporting to RPRA;
  • Establishing a collection and management system and meeting a management requirement; and
  • Promotion and education requirements.

Management requirements are calculated using the formulas in the table below. For the 2022 reporting period, producers need to determine if they will be exempt for the 2023 performance period.

Performance PeriodFormulaExemption threshold (kg)Exempt if average annual supply less than (kg)
2023(2018 supply + 2019 supply + 2020 supply) / 3×30%3501167
2024(2019 supply + 2020 supply + 2021 supply) / 3×30%3501167
2025(2020 supply + 2021 supply + 2022 supply) / 3×30%3501167
2026(2021 supply + 2022 supply + 2023 supply) / 3×40%350875
2027(2022 supply + 2023 supply + 2024 supply) / 3×50%350700

Producers not required to register and report are required to keep records as set out in section 30 of the regulation. Note: The minimum management requirement percentage increases for the 2025 supply report (2026 performance year) and subsequent years. While some producers may be exempt one year, they might not be exempt in subsequent years. Producers must verify that they continue to meet the exemption each year using the table above.

Producers are encouraged to confirm their exemption with the Compliance Team at registry@rpra.ca or 1-833-600-0530.

See our FAQ to understand “How are lighting producers’ minimum management requirements determined?” and “What do I have to do if I am an exempt lighting producer?

What do I have to do if I am an exempt lighting producer?

An exempt producer is not required to:

  • Register and report to RPRA;
  • Establish a collection and management system and meet a management requirement; and
  • Promotion and education requirements.

Exempt producers must retain records related to the weight of lighting supplied into Ontario each year and provide them to the Authority upon request.

See our FAQ to understand “How do I determine if I am an exempt lighting producer?

Do producers need to provide collection services to new facilities, including new multi-residential facilities, during the transition period? Is a municipality’s natural growth accommodated during the transition period?

Producers are obligated to provide collection services to new facilities that come into existence during the transition period only if that facility would have qualified for collection services under the WDTA Blue Box Program.

For further certainty, the WDTA Blue Box Program includes collection services for multi-family households (including rental, cooperative or condominium residential), senior citizen residences, long-term care facilities and public and private elementary and secondary schools.

What has replaced the Rule Creation process in the amended Blue Box Regulation?

With the removal of the rule creation process and allocation table as the tools to create and maintain the Blue Box collection system, the amended regulation now requires producer responsibility organizations (PROs) to submit a report that outlines how they will operate the Blue Box collection system on behalf of producers, ensuring that materials are collected from all eligible communities (i.e., communities outside of the Far North) across the province.

Circular Materials Ontario and Ryse Solutions Ontario PROs submitted a Blue Box PRO initial report to RPRA on July 1, 2022, that provides the following information:

  • A description of how they will comply with the collection requirements of the regulation, including any agreements between themselves and any other PRO
  • A detailed description of how they will make collected Blue Box materials available for processing, how materials will be processed, and the expected location of receiving facilities in Ontario
  • A description of how they will comply with the promotion and education requirements of the regulation

You can read the news release and the initial report here.

What do I do if I misreported my supply data?

If a producer misreports their supply data to RPRA, they must contact the Compliance and Registry Team immediately by emailing registry@rpra.ca. Please include the following information in the email:

  • The rationale for the change in the data
  • Any data that supports the need for a correction (e.g., sales documents, audit)
  • Any other information to support the change

While it is an offence to submit false or misleading information under the RRCEA, RPRA wants this corrected as quickly to ensure a producer’s minimum management requirement is calculated using accurate supply data.

RPRA can only receive these requests from the primary contact on the company’s Registry account. Your request for an adjustment will be reviewed by a Compliance and Registry Officer.

Can a food court restaurant deduct Blue Box materials that are disposed of in its mall recycling receptacles?

Under the Blue Box Regulation, allowable deductions for producers include Blue Box materials that are deposited into a receptacle at a location that is not an eligible source and where the product related to the Blue Box material was supplied and used or consumed.

This applies to food court restaurants located in a mall or in the base of an office tower. Blue Box materials that were disposed of in the buildings’ recycling receptacles and were supplied and used or consumed within that physical building are an allowable deduction. Blue Box materials that were disposed of in the buildings’ recycling receptacles but were not supplied and used or consumed within that physical building are not deductible.

This does not reduce the obligation of a producer to provide complete and accurate supply data or limit the ability of an Authority inspector to review the data and related records for the purpose of determining compliance.

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.