Posted on October 20, 2021 by Monica Ahmed -
Yes, a food court restaurant can 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 a RPRA inspector to review the data and related records for the purpose of determining compliance.
Posted on October 19, 2021 by Michelle Hoover -
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.
Posted on October 19, 2021 by Michelle Hoover -
Producers of refillable propane containers have no management requirements.
Posted on October 19, 2021 by Michelle Hoover -
Producers of fertilizers have no management requirements.
Posted on October 19, 2021 by Aian Binlayo -
Producers must ensure that, no later than three months from the date of the pickup, the HSP is processed by an HSP processor who is registered with RPRA.
In 2027, producers or PROs on their behalf must use a processor who met, at a minimum, the average recycling efficiency rate (RER) specified in the table below in the calendar year two years prior:
| Type of HSP | Average Recycling Efficiency Rate (RER) percentage |
| Barometers, Thermometers and Thermostats | 90 |
Posted on October 19, 2021 by Aian Binlayo -
Producers, or PROs acting on their behalf, are required to establish and operate a system for managing HSP by satisfying their management requirements as follows:
- All oil containers, antifreeze, solvents, paints and coatings picked up from a collection site must be processed within three months from the date of the pickup
- Producers must ensure that materials are processed by an HSP processor registered with RPRA. In 2027, producers or PROs on their behalf must use a processor who met, at a minimum, the average recycling efficiency rate (RER) specified in the table below in the calendar year two years prior for the type of HSP:
| Type of HSP | Average Recycling Efficiency Rate (RER) percentage |
| Antifreeze | 90 |
| Oil Containers | 95 |
| Paints and Coatings | 75 |
| Solvents | 10 |
- Producers of pesticides must ensure that pesticides are properly disposed of at an HSP disposal facility registered with RPRA no later than three months after the day the pesticides are collected.
Posted on October 19, 2021 by Aian Binlayo -
Producers, or PROs acting on their behalf, are required to establish and operate a management system and must:
- process all oil filters and non-refillable pressurized containers picked up from a collection site within three months from the date of the pickup
- ensure that materials are processed by an HSP processor registered with RPRA
Producers are required to recover an amount of material based on their average supply into Ontario and report on it annually.
Posted on October 12, 2021 by Monica Ahmed -
In determining whether an obligated producer used best efforts to meet their management requirements, the Compliance Team will consider whether the producer, acting in good faith, took all reasonable steps to meet the requirements outlined in the applicable regulation.
For example, best efforts in the context of management requirements may involve a producer regularly monitoring the volume of material being collected and managed, and implementing plans for increasing those volumes if the requirements are unlikely to be met.
Producers can contact the Compliance Team to ask specific questions about fulfilling their obligations.
Posted on September 15, 2021 by RPRA Communications -
Yes, a producer can change PROs at any time. Producers must notify RPRA of any change in PROs within 30 days of the change.
Posted on September 15, 2021 by Aian Binlayo -
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].
Posted on September 15, 2021 by Monica Ahmed -
There are two allowable deductions for Blue Box materials:
The “installation deduction” for materials collected from an eligible source at the time a related product was installed or delivered (e.g., packaging that is removed from the house by a technician installing a new appliance).
The “ineligible source deduction” for materials deposited into a receptacle at a location that is collected from a business or institution where Blue Box collection services are not provided under the regulation. This was expanded by the regulatory amendment in July 2023.
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, community centres, recreation facilities, sports and entertainment venues, universities and colleges, and manufacturing facilities.
Producers cannot deduct the following materials collected through the collection systems established under the Blue Box Regulation:
- Material that is collected from a residence through a curbside or depot collection service.
- 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.
Materials that are deducted cannot count toward a producer’s management requirement.
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.
Posted on August 18, 2021 by Monica Ahmed -
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’
Posted on August 18, 2021 by Jess Turchet -
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.
