Topic: Producer

Are Blue Box producers (or PROs on their behalf) required to provide printed promotion and education materials about Blue Box by mail to each eligible source (e.g., each Ontario household) at least once per year as of January 1, 2026?

While the Blue Box Regulation states the requirement for Blue Box producers or PROs to deliver printed promotion and education materials to eligible sources by mail at least once a year, many Ontario municipalities have stopped providing printed promotion and education materials to their residents in favour of electronic formats.

As long as Blue Box producers or Blue Box PROs continue to provide the same format of promotion and education materials as the Ontario municipality provided prior to the date the municipality transitioned under the Blue Box Regulation (i.e., print or electronic or both), RPRA will consider this as having satisfied the requirement in section 72(1) paragraph 2.

If a municipality distributes documents on behalf of another brand holder, does the municipality include the weight of those documents in their annual supply report?

Where a municipality distributes documents on behalf of another brand holder, the municipality is not obligated to report the paper in its supply. That obligation falls to the brand holder.

For example: A municipality may distribute documents issued by the provincial government (such as marriage licences and court documents) which are usually branded with the provincial agency or ministerial logos and names. In these cases, the provincial government would be the brand holder responsible for reporting these materials in their annual supply data report.

Please see FAQ “Who is a brand holder?” for more information.

When and how do I register with RPRA as an HSP producer?

When to register as a producer 

Producers of oil filters and non-refillable pressurized containers, oil containers, antifreeze, pesticides, refillable pressurized containers, solvents, paints and coatings  

If the producer’s average weight of supply in 2018, 2019, 2020 was above the threshold in the table below, the producer was required to register with RPRA by November 30, 2021. Obligated producers who have not yet registered are out of compliance with the regulation and may face compliance action by RPRA. 

If a producer was not required to register in 2021, they must register on or before July 31 of the first calendar year that they exceed the threshold in the table below. 

Type of HSPAverage weight of supply from the previous three calendar years (tonnes)
Oil Filters3.5
Non-refillable pressurized containers3
Antifreeze20
Oil Containers2
Paints and coatings10
Pesticides1
Refillable pressurized containers8
Solvents3

For assistance in calculating your average weight of supply, contact RPRA’s Compliance Team at registry@rpra.ca.  

Producers of mercury-containing barometers, thermometers and thermostats, fertilizers and refillable propane containers

If a producer met the definition of an HSP producer in 2021, they were required to register with RPRA by November 31, 2021.

If you meet the definition of an HSP producer after November 31, 2021, you must register with RPRA within 30 days. 

How to register as a producer

  1. Go to RPRA’s Registry at https://registry.rpra.ca/s/login/?language=en_US 
    • Note: The Registry will not work with the Internet Explorer web browser. Google Chrome is the recommended web browser to use.
  2. Click “Don’t have an Account? Create a new Account”.
  3. Follow the prompts to fill out your account details. 
    • Information needed at time of registration: 
      • CRA business number, business name, address, contact information, and 
      • Name, contact information of the person who will be responsible for completing registration.
  4. You’ll receive an email with a link to create your password.
  5. Select the program you want to enroll in.
  6. Submit a supply report with the total weight of each type of HSP that was supplied to consumers in Ontario in the previous years. 

For more information and step by step instructions on how to submit a supply report, view our supply reporting guides here. 

Am I considered a large or small producer for HSP supply data verification reporting?

Large producers for supply data verification

Producers whose average supply meets the large producer threshold in the below chart must submit a verification report for that reporting year.

Example: Producers of oil filters that have an average weight of supply in their 2023 supply report that exceeds 100 tonnes are considered a large producer and must submit a verification report for oil filters in 2024.

Chart of HSP average weight of supply

Small producers for supply data verification

Producers who are below the threshold are considered small producers. Small producers are only required to submit a verification report but will be subject to inspections.

Our company supplies its products in refillable packaging. How should we report these containers in our Supply Report?

For the purposes of supply data reporting, ‘refillable packaging’ is defined as packaging surrounding a supplied product that a consumer can return to the product manufacturer for cleaning and reuse.

A producer who supplies its products in refillable packaging should only report weights (under the appropriate material category) the first time the packaging is supplied to consumers.

For example:

A milk producer that used 1000 new glass bottles to supply its product to consumers in 2022, reported the weight of all 1000 bottles under the beverage container category in their 2023 supply data report.

In 2023, the producer added 500 new glass bottles to its supply, bringing the total of supplied material to 1500 bottles. Their 2024 supply data report should only reflect the weights of the 500 new bottles, not the total currently being used by the producer (1500).

Important: Products supplied in beverage containers should be reported in the ‘beverage container’ category, not the category the container is made of (plastic, metal, glass).

See Compliance Bulletin: What blue box materials need to be reported?

How can I ensure that my products or packaging are collected and sent for management when I don’t know where they end up once a consumer discards them?

Producers are not required to collect and manage their own branded products and materials. Instead, a producer is expected to collect and manage a portion of similar materials in Ontario. The portion of material that a producer collects and manages is known as their minimum management requirement. A minimum management requirement, which is set based on calculations outlined in the applicable Regulation, is the weight of the products or packaging that the producer must ensure is collected and managed. The calculated amount is proportionate to the weight of materials that producer supplied into the province.

For example, a producer who supplied laptops into Ontario does not need to collect and manage their own branded laptops. Instead, they must ensure that they collect and manage an equivalent weight of information technology, telecommunications, and audio-visual equipment (ITT/AV) materials.

Similarly, a producer who supplied cardboard boxes into Ontario does not need to collect and manage those exact cardboard boxes. Rather, they need to ensure that an equivalent weight of paper is collected and managed.

Almost all producers will work with producer responsibility organizations (PROs) for the purposes of meeting their obligations to collect and manage materials. PROs establish collection and management systems across Ontario for different material types. A producer can meet their obligations to collect and manage materials by entering into a contract with a PRO to provide these services on their behalf.

If we use a delivery company to mail our products or correspondence, who is required to report on the shipping packaging supplied to the consumer?

Each Blue Box producer is required to report the Blue Box packaging they add to a product.

For example: a college or university bookstore plans to ship a book to a consumer in Ontario. The bookstore staff packages the book in a small box with the packing slip and inserts the box into a plastic mailer supplied by the delivery service with the required label affixed.

In this scenario, the college or university is the obligated producer of the small box and packing slip and must report these materials in their supply report, whereas the delivery company is the obligated producer of the plastic mailer and label and must report these materials in their supply report.

Also see:
Am I a producer of Blue Box product packaging?

Our institution has implemented a source-separation program to capture and divert recyclable material from landfill. Why are we obligated to report to the RPRA when we’re already recycling our waste?

Eligible Ontario institutions are obligated to manage their waste under several regulations, each of which imposes different obligations and requirements.

Under the Ontario Environmental Protection Act, Industrial, Commercial and Institutional (IC&I) sector organizations have obligations to establish and operate an internal collection system that separates the waste generated on-site into different material categories (i.e., a source-separation program).

The Blue Box Regulation, under the Resource Recovery and Circular Economy Act, obligates producers of Blue Box material to collect, manage, and report on the materials that they supply to consumers both on-site and off-site.

We are a public sector institution and understand that we are a Blue Box producer. What information do we need to include in our supply report?

Public sector institutions, such as colleges and universities, are suppliers of Blue Box materials to consumers in Ontario. They supply Blue Box materials to consumers on-site (e.g., food service packaging, unprinted paper in photocopiers, etc.) and off-site (e.g., mailings).

For the purposes of supply reporting, colleges, universities, and other public sector institutions must determine the total amount of Blue Box material they supply to consumers in Ontario. One way to gather this data is by canvassing internal departments to obtain annual weights of Blue Box materials supplied to consumers on-site and off-site.

Also see:
FAQ: What deductions are available to producers under the Blue Box Regulation?
Compliance Bulletin: What Blue Box materials need to be reported?

What types of food service packaging does a public sector institution need to include in its supply report?

Public sector institutions must report all branded and unbranded Blue Box packaging supplied or sold with food served in their owned and operated on-site facilities. These facilities include but are not limited to cafeterias, pubs, cafes, and in the case of a college or university, faculty offices.

It is important to consider other situations where food service Blue Box packaging is supplied to consumers. For example, a college must report the packaging used in their Culinary and Hospitality programs that allow students to take home food prepared in class.

My institution has a reuse store and/or hosts upcycling events in which some Blue Box materials (e.g., donated paper products like notebooks, loose paper, and file folders) are sold or given away for free. As a Blue Box producer, what materials from this service should be included in our supply report?

Any donated or re-supplied paper products or other Blue Box materials that are supplied to consumers through a reuse store or upcycling event should not be included in your supply report.

My institution provides self-serve hot drink machines where students and employees can serve themselves. As a Blue Box producer, what materials from this service should be included in our supply report?

Any public sector institution, including colleges and universities, that offers a self-serve hot drink machine for use by students and employees (i.e., consumers) must report all the Blue Box materials supplied with the machine to serve the hot drinks. This includes branded and unbranded single-use cups, lids, etc.