Topic: Processor

The following are the types of Blue Box Materials obligated under the Blue Box Regulation:

• Blue box packaging (primary, transport, convenience, service accessories, ancillary elements)
• Paper products
• Packaging-like products

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.

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.

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.