Topic: PRO

Who does RPRA consider an acceptable verifier/qualified person?

A Verifier can be an individual, either an employee of the business or a hired third-party (including a PRO), who has one of the following designations and is not the same person who prepared the supply report:

  • CPA (Chartered Professional Accountant) in Canada or CPA (Certified Public Accountant) in the US
  • ACCA (Association of Chartered Certified Accounts) Qualification
  • CIA (Certified Internal Auditor)
  • CPB (Certified Professional Bookkeeper) in Canada
  • RPA (Registered Professional Accountant) in Canada

What are the potential consequences of late reporting?

Failure of an obligated party to meet a registration or reporting deadline may result in compliance action, including compliance orders, prosecutions or monetary penalties issued in accordance with the Administrative Penalties Guidelines.

In accordance with the Risk Based Compliance Framework, RPRA will communicate to obligated parties, via email, about their reporting requirements in advance of submission deadlines. RPRA will also send deadline reminders and notify missed deadlines to obligated parties prior to taking further compliance action.

For more guidance, read the new Late Registration or Report Submissions Compliance Bulletin.

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?

Do I dispose of my empty paints cans, pesticides, solvents and fertilizers at Blue Box collection sites or HSP collection sites?

Paints, pesticides, solvents fertilizers obligated under the HSP Regulation along with their primary packaging must be accepted at collection sites collecting the corresponding material. For instance, empty paint cans and pesticide aerosols obligated under the HSP Regulation must be accepted at collection sites collecting paint and pesticides.

See our FAQ to understand “Under the HSP Regulation, is the packaging of antifreeze, pesticides, solvents, paints and coatings obligated?” and “Are containers that are obligated under the HSP Regulation obligated as Blue Box materials?

Why can’t I see the Manage PRO widget to add my PRO choice?

The Manage PRO option will appear on the dashboard below your list of supply data reports when your supply data reporting is complete and if you have management requirements. If your supply data reporting is below the supply exemption threshold you will not have management requirements, and therefore not need to assign a PRO to assist with your obligations.

Also note that Account Admin are the only portal users that can manage your PRO’s responsibility, so this widget is not viewable to primary and secondary users.

Are beverage containers eligible for a producer’s allowable deductions for Blue Box materials that are deposited into a receptacle at a location that is a) not an eligible source, and b) where the product related to the Blue Box material was supplied and used or consumed?

No, beverage containers are not eligible for this deduction.

The allowable deduction is permitted for Blue Box materials that are deposited into a “non-eligible source,” meaning a place where consumers dispose of Blue Box materials that are not included in the producer-run collection system.

Under the Blue Box Regulation, beverage containers that are supplied to Ontario consumers for personal, family, household or business purposes are obligated Blue Box materials. The inclusion of “business purposes” is unique to the beverage container material category.

Because supplying a beverage container can mean either supplying for “personal, family and/or household purposes” that will likely be consumed and disposed of in a residential context (e.g., a home, apartment, long-term care facility, etc.) or supplying for “business purposes” that will likely be consumed and disposed of in a commercial or institutional context (e.g., a restaurant, college or gym), there are no “non-eligible sources” for beverage containers. All beverage containers must be reported and collected from all sources, whether they are residential, business, commercial or institutional.

See our FAQ to understand “What deductions are available to producers under the Blue Box Regulation?

What collection service obligations do producers have to eligible communities that currently receive recycling curbside collection but residents also have access to “secondary” or “convenience” recycling depots?

Where an entire community is receiving recycling curbside collection and has access to recycling depots, the requirement is that during transition, that same level of service is still provided. After transition, there is no requirement to maintain depots within these communities.

When managing PROs in RPRA’s Registry, it asked for a “Service End Date”. However, the contract I have with my PRO does not provide an end date. What date should I use?

In the Manage PRO section in the Registry, the “Service End Date” is not a mandatory field. You can leave this field blank if there is no end date in your contract. If you decide to change PROs in the future, you can update this field to the date your agreement ended with that PRO.

What is a brand supply list?

A brand supply list is a list of brands of obligated products that a producer supplies to consumers in Ontario. A producer must provide a brand supply list that makes up their supply data annually to RPRA. Each program has different requirements regarding how a producer must submit a brand supply list. For more information, consult the applicable programs’ walkthrough guide or contact RPRA’s Compliance and Registry Team at 1-833-600-0530 or by emailing

What are certified compostable products and packaging?

In the Blue Box Regulation, certified compostable products and packaging is defined as material that:

  • is only capable of being processed by composting, anaerobic digestion or other processes that result in decomposition by bacteria or other living organisms, and
  • is certified compostable by an international, national, or industry standard that is listed in this procedure.

All certified compostable products and packaging reported by producers must be certified under one of the following standards:

  • CAN/BNQ 0017-088: Specifications for Compostable Plastics
  • ISO 17088: Specifications for compostable plastics
  • ASTM D6400: Standard Specification for Labeling of Plastics Designed to be Aerobically Composted in Municipal or Industrial Facilities
  • ASTM D6868: Standard Specification for Labeling of End Items that Incorporate Plastics and Polymers as Coatings or Additives with Paper and Other Substrates Designed to be Aerobically Composted in Municipal or Industrial Facilities
  • EN 13432: Requirements for packaging recoverable through composting and biodegradation – Test scheme and evaluation criteria for the final acceptance of packaging


As a producer or municipality, do the 2022 Blue Box Regulation amendments change anything for me?

For most producers and for all municipalities, little has changed:

  1. Rule creators and the rule creation process, including the allocation table, have been removed. Instead, each producer is responsible for providing Blue Box collection to every eligible source in Ontario and creating a province-wide system for collection.
  2. Producer Responsibility Organizations (PROs) are now required to submit a report to RPRA on how they will operate the Blue Box system on behalf of producers.
  3. Newspaper producers whose newspaper supply accounts for more than 70% of their total Blue Box supply to consumers in Ontario are exempt from collection, management, and promotion and education requirements.

The amendments do not change or impact:

  • Producer registration or 2020 supply data reporting to RPRA
  • Most producers’ 2021 supply data reporting to RPRA
  • The materials collected in the Blue Box system
  • The communities that receive collection or the collection requirements
  • The transition schedule and its timelines

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.