Topic: Management Activities

What is the difference between a PRO and a prospective PRO?

A producer responsibility organization (PRO) is a person retained by a producer to provide collection, management and administrative services to help producers meet their regulatory obligations.

A prospective PRO is a person that has registered with RPRA but have not been identified by a producer in RPRA’s registry to carry out regulatory responsibilities.

More information on PROs

PRO responsibilities include:

  • Arranging for the establishment or operation of collection or management systems
  • Establishing or operating a collection or management system
  • Preparing and submitting reports

In addition, under the Hazardous and Special Products regulation, a PRO includes a person retained by a producer for the purpose of:

  • Implementing a promotion and education program

Only PROs that meet this definition will:

  • Be listed on RPRA’s website as a PRO
  • Be invited to attend all-PRO meetings with RPRA
  • Receive system-wide compliance communications

More information on prospective PRO

RPRA will list all prospective PROs on its website for up to one year. After that period, prospective PROs that remain unassigned by a producer in the registry will be notified, removed from the website, and have their registry account deactivated.

RPRA will publish a list of producers who have not yet identified a PRO in the registry. This will help prospective PROs understand where opportunities may exist.

What do I do if I need to adjust my performance data?

If a producer or service provider needs to adjust the performance data reported to RPRA, they must contact the Compliance and Registry Team immediately by emailing [email protected]. 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., tonnage purchase or sale contract, 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 as possible to ensure that it has accurate performance data from all registrants.

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 the Compliance and Registry team.

Are reusable bags obligated under the Blue Box Regulation?

Yes, reusable bags made from Blue Box materials ( e.g. plastic, paper) and used as convenience packaging are obligated under the Blue Box Regulation and must be reported annually by producers in their supply report.

Convenience packaging refers to material that is provided with a product for consumers to handle or transport that product, in addition to the product’s primary packaging. This includes items such as bags and boxes that are supplied to consumers at check out.

For additional clarity:

  • Reusable bags made primarily from plastic, paper, or any other Blue Box material, or a combination of these materials, are obligated. Reusable bags made from textile fibres such as cotton, hemp, bamboo, etc., are not obligated.
  • Recycled content of the material has no impact on whether a reusable bag is obligated. For example, reusable bags containing post-consumer recycled plastic content are obligated.
  • A reusable bag is obligated regardless of whether it is supplied to the consumer for free or at a cost. Examples include bags supplied at checkout to consumers at retail locations.

If you haven’t been reporting reusable bags as part of your annual supply data, please contact the Compliance Team immediately at [email protected].

Also see our FAQ: ‘What do I do if I misreported my supply data?’

How are HSP producers’ minimum management requirements determined?

Producers of oil filters and non-refillable pressurized containers have individual management requirements which are determined by the formulas found in section 2 of the HSP Regulation multiplied by the number found in section 31 of the regulation.

Oil filters

A producer’s minimum management requirement is determined by the formulas summarized in the table below.

Performance YearSupply Report YearFormula
20252024[(2024+2023+2022)/3] × 85%
20262025[(2025+2024+2023)/3] x 85%
20272027[(2026+2025+2024)/3] x 85%
20282027[(2027+2026+2025)/3] x 85%

Non-refillable pressurized containers

A producer’s minimum management requirement is determined by the formulas summarized below.

Performance YearSupply Report YearFormula
20252024[(2024+2023+2022)/3] × 30%
20262025[(2025+2024+2023)/3] x 30%
20272027[(2026+2025+2024)/3] x 30%
20282027[(2027+2026+2025)/3] x 30%

It is important to note that producers must ensure that all collected HSP are managed, regardless of what their minimum management requirement is.

Note: Exempt producers are not required to meet minimum management requirements.

See our FAQ “How do I determine if I am an exempt HSP producer?” to learn more.

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 one year 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 producers 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? If a producer does not have a management requirement they do 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 requirements for a given year are determined by supply data from two years prior. For example, 2026 management requirements were based on 2024 supply data (submitted in producers’ 2025 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?

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 RPRA 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 [email protected] 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 average weight of supply for that calendar year is less than or equal to 700 kg.

Average supply weight is determined using the following formula:

Average weight of lighting supply = (Y3 + Y4 + Y5) / 3 

Eg. 2025 average weight of supply = (2022 + 2021 + 2020) / 3 

Lighting producers that meet the exemption criteria are exempt from:

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

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

Producers that are exempt must keep records of the materials they supplied, as set out in section 30 of the regulation.

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

See our FAQs: “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
  • Meet a management requirement
  • Meet promotion and education requirements

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

See our FAQ: ‘How do I determine if I am an exempt lighting producer?’

Are Blue Box producers required to provide collection services to new single-family residences?

Yes, producers are obligated to provide collection services to new single-family residences, but these locations must become eligible sources first.

A new residence becomes an eligible source only after the local municipality, local services board, or First Nation registers the new single-family residences (also referred to as “natural growth”) by updating its address information with the Common Collection System Administrator, Circular Materials. Once the new addresses are properly registered, producers are obligated to provide collection services as soon as is practicable.

Municipalities, local services boards and First Nations should contact Circular Materials if they have new residences that need Blue Box collection service. Contact information can be found by visiting Circular Materials’ website and typing in your community’s name.

What do I do if I misreported my supply data?

If a producer misreports their supply data to RPRA, they must contact the Compliance Team immediately by emailing [email protected]. 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 as possible 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.