Topic: PRO

What is blue box product packaging?

Under the Blue Box Regulation, blue box product packaging includes:

  • Primary packaging is for the containment, protection, handling, delivery and presentation of a product at the point of sale, including all packaging components, but does not include convenience packaging or transport packaging (e.g., film and cardboard used to package a 24-pack of water bottles and the label on the water bottle).
  • Transportation packaging which is provided in addition to primary packaging to facilitate the handling or transportation of one or more products such as a pallet, bale wrap or box, but does not include a shipping container designed for transporting things by road, ship, rail or air.
  • Convenience packaging includes service packaging and is used in addition to primary packaging to facilitate end users’ handling or transportation of one or more products. It also includes packaging that is supplied at the point of sale by food-service or other service providers to facilitate the delivery of goods and includes items such as bags and boxes that are supplied to end users at check out, whether or not there is a separate fee for these items.
  • Service accessories are products supplied with a food or beverage product and facilitate the consumption of that food or beverage product and are ordinarily disposed of after a single use, whether or not they could be reused (e.g., a straw, cutlery or plate).
  • Ancillary elements are integrated into packaging (directly hung or attached to packaging) and are intended to be consumed or disposed of with the primary packaging. Ancillary elements help the consumer use the product. Examples of ancillary packaging include a mascara brush forming part of a container closure, a toy on the top of candy acting as part of the closure, devices for measuring dosage that form part of a detergent container cap, or the pouring spout on a juice or milk carton.

What are paper products?

Under the Blue Box Regulation, paper products include printed and unprinted paper, such as a newspaper, magazine, greeting cards, calendars (promotional or purchased), notebooks and daily planners, promotional material, directory, catalogue or paper used for copying, writing or any other general use.

Hard or soft cover books and hardcover periodicals are not considered paper products.

What are packaging-like products?

Under the Blue Box Regulation, a packaging-like product is:

  • ordinarily used for the containment, protection, handling, delivery, presentation or transportation of things
  • ordinarily disposed of after a single use
  • not used as packaging when it is supplied to the consumer

Packaging-like products include aluminum foil, a metal tray, plastic film, plastic wrap, wrapping paper, a paper bag, beverage cup, plastic bag, cardboard box or envelope, but does not include a product made from flexible plastic that is ordinarily used for the containment, protection, or handling of food, such as cling wrap, sandwich bags, or freezer bags.

If a producer is unsure whether or not their product is a packaging-like product, they can ask themselves the following questions to help determine whether the product is obligated to be reported under the Blue Box Regulation:

  1. Is the product actually packaging around a separate product?
    • If yes, the product is not a packaging-like product. Instead, the product is considered blue box packaging and must be reported as blue box material.  If no, continue to the next question.
  2. Is the product used for the containment, protection, handling, delivery, presentation or transportation of a thing(s)?
    • If no, the product is not a packaging-like product. If yes, continue to the next question.
  3. Is the product typically disposed of after a single use (regardless if some may wash and reuse it)?
    • If no, the product is not a packaging-like product. If yes, continue to the next question.
  4. Is the product made from flexible plastic that is for the containment, protection or handling of food?
    • If yes, the product is not a packaging-like product. If no, the product is a packaging-like product and must be reported as blue box material.

If a producer is still unsure whether or not their product is a packaging-like product, they should contact the Compliance and Registry Team at 833-600-0530 or registry@rpra.ca.

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.

Is a PRO required to make my collection site part of their collection system?

A producer responsibility organization (PRO) is not necessarily required to include each and every collection site in Ontario in their collection system. However, producers and PROs acting on their behalf are required to establish and operate a collection system that meets the requirements of the Tires Regulation.

If a collection site operator is unable to be included in a collection system, the operator should contact RPRA’s Compliance Team at registry@rpra.ca, 647-496-0530 or toll free at 1-833-600-0530 for assistance.

Read Compliance Bulletin – Tire Collection Systems for more information. The contact information for all registered PROs is available on the producer responsibility organization webpage.

If a producer meets its collection and management requirements early, can it stop collecting and processing materials?

No. Producers and PROs working on their behalf must operate the collection systems they have established as required by the Regulation even after their requirements are met. If a consumer is refused permission to drop off materials at a registered collection site, they can contact the Compliance and Registry Team at registry@rpra.ca, 647-496-0530 or toll-free at 1-833-600-0530.

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.

I’m a collector. Who will pick up my tires?

Collectors will have to independently enter into commercial agreements with producers, producer responsibility organizations (PROs) or other service providers such as haulers or processors to secure tire collection services. Collectors could also continue to operate within their existing agreements with service providers such as haulers or processors. As long as a collector’s site is part of a producer’s tire collection system, the producer, or their PRO, is obligated to ensure tires are picked up from that site.

Since producers now have legal obligations under the Tires Regulation, producers, or their PROs, will need your tires to meet their management requirements , but you must be registered with RPRA for your tires to count towards producers’ collection and management requirements (unless you are exempt from the registration requirement, for example, municipal sites, Crown sites and fleet operator sites).

A list of registered PROs and producers is available on RPRA’s website on the Find a Registrant page.

As a producer, do I need a PRO to meet my collection and management requirements?

No, producers are not required to sign up with a PRO to meet their regulatory requirements. It is a business decision if a producer chooses to work with a PRO, and a producer can choose to meet their obligations without a PRO.

Most producers will choose to contract with a PRO to provide collection, hauling, processing, retreading and/or refurbishing services to achieve their collection and management requirements unless they carry out these activities themselves.