Topic: Producer

Can Blue Box producers or PROs collect materials that are not marketed to consumers under the Blue Box regulation?

Yes, a Blue Box producer or PRO (producer responsibility organization) on behalf of a producer, or a service provider on behalf of either party, can voluntarily choose to collect Blue Box materials that are not marketed to consumers.

Blue Box materials not marketed to consumers cannot be counted towards meeting a producer’s collection or management requirements under the Blue Box Regulation.

If Blue Box materials that are marketed to consumers are co-collected with Blue Box materials not marketed to consumers, a person must use a methodology or process acceptable to the Authority to account for materials supplied to a consumer or not. Anyone considering this can contact the Compliance Team to discuss at registry@rpra.ca or 833-600-0530.

For example, if Blue Box materials supplied to a consumer in Ontario are collected along the same collection route as Blue Box materials that were not supplied to a consumer, they must be accounted for separately. When those materials are then sent to a processor, they must also be accounted for separately.

See the FAQ: Who is a consumer under the Blue Box Regulation?

Can Blue Box producers or PROs collect from locations that are not eligible sources?

Yes, a Blue Box producer, or PRO (producer responsibility organization) on behalf of a producer, or a service provider on behalf of either party, can choose to offer collection services to any location. Blue Box producers are required to provide collection services to all eligible sources, as well as public spaces.

Blue Box materials collected from locations that are not eligible sources cannot count towards meeting a producer’s management requirement unless they were supplied to a consumer in Ontario. See this FAQ: Who is a consumer under the Blue Box Regulation?

If a person is co-collecting from locations that are eligible sources and not eligible sources, a person must use a methodology or process acceptable to the Authority to account for materials collected from each type of source. Anyone considering this can contact the Compliance Team to discuss at registry@rpra.ca or 833-600-0530.

For example, if materials are collected from an eligible source and a location that is not an eligible source along the same collection route, they must be accounted for separately. When those materials are then sent to a processor, they must also be accounted for separately.

Can a producer collect products or materials that are not designated under RRCEA regulations?

Yes, a producer, a PRO (producer responsibility organization) on behalf of a producer, or a service provider on behalf of either party, can collect any product or material (including materials or products that are not designated under the Resource Recovery and Circular Economy Act, 2016 (RRCEA)). For example, a battery producer may choose to collect batteries that weigh over 5kg; a tire producer may choose to collect bicycle tires; or a Blue Box producer may choose to collect books.

Products or materials that are not designated under RRCEA regulations cannot be counted towards meeting a producer’s collection or management requirements under RRCEA.

If designated materials are co-collected with materials that are not designated, a person must use a methodology or process acceptable to the Authority to account for those materials. Anyone considering this can contact the Compliance Team to discuss at registry@rpra.ca or 833-600-0530.

For example, if bicycle tires are collected at the same time as automotive tires, they must be accounted for separately both when collected and when sent to a processor.

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?

What is the difference between an account admin, a primary and a secondary user in the Registry portal?

Account admins have access to all information within a registrant’s account. They can create and assign primary and secondary users’ access to the account, edit and submit reports, and pay fees. They are the only ones who can manage PROs.  Account admins can view all activities users undertake. They will also be the recipient of emails from the Registry portal.

Primary users can only assign secondary users’ access to the account, edit and submit reports and pay fees.

Secondary users can only edit and submit reports and pay fees.

Are cheques an obligated material?

Yes, cheques are an obligated material and should be reported under the paper material category. If you have questions regarding how to determine whether you are the brand holder and are obligated to report the supply of cheques, please reach out to the Compliance & Registry team at registry@rpra.ca.

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.

As a lighting producer, what data do I submit to RPRA?

In 2022, lighting producers will report the total weight of obligated lighting supplied into Ontario from 2018, 2019 and 2020. Producers will report the total weight (kg) for each year required.

Starting in 2023, lighting producers will report data from two preceding years (i.e., 2021 supply data reported in 2023).

Producers can use the actual weight of the obligated lighting, or RPRA’s weight conversion factors found in the EEE Verification and Audit Procedure.

For further questions, contact the Compliance and Registry Team at registry@rpra.ca or 1-833-600-0530.

How do I determine if I am an exempt lighting producer?

A lighting producer qualifies for an exemption if their management requirement isn’t more than 350 kg. The lighting producer is exempt from the following:

  • Registering and reporting to RPRA;
  • Establishing a collection and management system and meeting a management requirement; and
  • Promotion and education requirements.

Management requirements are calculated using the formulas in the table below. For the 2022 reporting period, producers need to determine if they will be exempt for the 2023 performance period.

Performance PeriodFormulaExemption threshold (kg)Exempt if average annual supply less than (kg)
2023(2018 supply + 2019 supply + 2020 supply) / 3×30%3501167
2024(2019 supply + 2020 supply + 2021 supply) / 3×30%3501167
2025(2020 supply + 2021 supply + 2022 supply) / 3×30%3501167
2026(2021 supply + 2022 supply + 2023 supply) / 3×40%350875
2027(2022 supply + 2023 supply + 2024 supply) / 3×50%350700

Producers not required to register and report are required to keep records as set out in section 30 of the regulation. Note: The minimum management requirement percentage increases for the 2025 supply report (2026 performance year) and subsequent years. While some producers may be exempt one year, they might not be exempt in subsequent years. Producers must verify that they continue to meet the exemption each year using the table above.

Producers are encouraged to confirm their exemption with the Compliance Team at registry@rpra.ca or 1-833-600-0530.

See our FAQ to understand “How are lighting producers’ minimum management requirements determined?” and “What do I have to do if I am an exempt lighting producer?

What do I have to do if I am an exempt lighting producer?

An exempt producer is not required to:

  • Register and report to RPRA;
  • Establish a collection and management system and meet a management requirement; and
  • Promotion and education requirements.

Exempt producers must retain records related to the weight of lighting supplied into Ontario each year and provide them to the Authority upon request.

See our FAQ to understand “How do I determine if I am an exempt lighting producer?