Topic: Management Activities

What deductions are available to producers under the Blue Box Regulation?

There are only two allowable deductions for Blue Box materials. There are for materials that are:

  • 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). This is the “installation deduction”.
  • 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 is the “ineligible source deduction” that was expanded by the regulation amendment in July 2023.

Ineligible source deductions:

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 generated at a facility (including multi-residential buildings, retirement homes, long-term care homes and schools).
  • 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.
  • Beverage containers cannot be deducted.

Materials that are deducted cannot count toward a producer’s management requirement.

Please see the Reporting Guidance Ineligible Source Deductions for the 2024 Blue Box Supply Report for more information on how to determine and use these deductions.

Are Blue Box materials that are supplied to the IC&I sector, such as long-term care homes, obligated?

Blue Box materials supplied to a business (e.g., the operators of a long-term care home) are not obligated, however, there are no deductions available for materials supplied to a consumer in an IC&I setting (e.g., a resident of a long-term care home).

Any Blue Box materials supplied to consumers in Ontario are obligated. Blue Box materials supplied to the IC&I sector are not obligated (except beverage containers which are obligated regardless of the sector supplied into).

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.

Are containers that are obligated under the Hazardous and Special Products (HSP) Regulation obligated as Blue Box materials?

No, products or packaging designated as Hazardous and Special Products (HSP) are not obligated under the Blue Box Regulation. For example, primary packaging for paints and coatings are HSP and therefore not obligated as Blue Box materials.

Some packaging for HSP products may still be obligated. For example, the packaging that contains an oil filter is obligated as Blue Box materials.

Consult the HSP Regulation or the Compliance and Registry Team for further information.

How are ITT/AV producer minimum management requirements determined?

A producer’s individual management requirements are determined by formulas found in section 14 of the Regulation, summarized in the table below:

Performance YearSupply Report YearFormula
20252024(2020 supply + 2021 supply + 2022 supply) / 3×65%*
20262025(2021 supply + 2022 supply + 2023 supply) / 3×65%
20272026(2022 supply + 2023 supply + 2024 supply) / 3×65%
20282027(2023 supply + 2024 supply + 2025 supply) / 3×65%
20292028(2024 supply + 2025 supply + 2026 supply) / 3×65%
20302029(2025 supply + 2026 supply + 2027 supply) / 3×70%

*For reports submitted in 2024, producers should use RPRA’s manual calculator

It is important to note that producers must ensure that all ITT/AV collected is managed regardless of what their minimum management requirement is.

Note: Producers with a management requirement below a certain threshold may be exempt from registering with and reporting to RPRA. See our FAQ ‘How do I determine if I am an exempt ITT/AV producer?’ to learn more.

How are battery producers’ minimum management requirements determined?

A producer’s individual management requirement is determined by formulas found in section 13 of the Regulation. See the table below for details:

Supply Report Year for Primary BatteriesSupply Report Year for Rechargeable BatteriesFormulaPerformance Year
20232022[(2023+2022+2021)/3] + (2022+2021+2020)/3] × 45%2025*
20242023[(2024+2023+2022)/3] + (2023+2022+2021)/3] × 50%2026
20252024[(2025+2024+2023)/3] + (2024+2023+2022)/3] × 50%2027
20262025[(2026+2025+2024)/3] + (2025+2024+2023)/3] × 50%2028

*For reports submitted in 2024, producers should use RPRA’s manual calculator.

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

Note: Producers with a management requirement below a certain threshold may be exempt from registering with and reporting to RPRA.

See our FAQ ‘How do I determine if I am an exempt battery producer?’ to learn more.

Does RPRA pay incentives for collecting, hauling, and processing materials?

No. The Authority 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.

What is a PRO?

A producer responsibility organization (PRO) is a business established to contract with producers to provide collection, management, and administrative services to help producers meet their regulatory obligations under the Regulation, including:

  • Arranging the establishment or operation of collection and management systems (hauling, recycling, reuse, or refurbishment services)
  • Establishing or operating a collection or management system
  • Preparing and submitting reports

PROs operate in a competitive market and producers can choose the PRO (or PROs) they want to work with. The terms and conditions of each contract with a PRO may vary.

I’m a producer. How do I set up my tire collection and tire management network?

The Tires Regulation requires producers to submit to the Registry the identity of each tire collector and tire collection site that is a part of that producer’s tire collection system. It is up to each producer, or a producer responsibility organization (PRO) on the producer’s behalf, to identify the tire collection sites that will be used in their tire collection systems.

Tire collectors are required to register and identify their collection sites (i.e., the address for every individual site where tires are collected). The collection site data will be used to populate a list of collection sites that will be available to producers and PROs. Producers, or their PROs, will be required to identify their tire collection systems.

Please read Compliance Bulletin -Tire Collection Systems for compliance guidance to producers who are required to establish and operate tire collection systems under the Tires Regulation.