Producers are required to register with RPRA by October 1, 2021, as outlined in the Blue Box Regulation.
After this date, new businesses are required to register within 30 days of becoming a producer.
Topic: Register with RPRA
Does a First Nation need to register with the Authority to receive Blue Box services? And if so, how can a First Nation register?
First Nation communities interested in receiving producer-run Blue Box services must register with the Authority. To register, communities must submit contact information of the person responsible for waste management in the community using the First Nation community registration form. Once completed, the registration form should be submitted by email to registry@rpra.ca.
Visit our First Nation webpage for more information.
Does RPRA vet PROs that register to ensure that they are viable options for producers to meet their requirements under the regulation?
RPRA does not vet PROs before listing them on the website. Any business that registers as a PRO will be listed. Producers should do their own due diligence when determining which PRO to work with.
Are Blue Box materials that are supplied to the IC&I sector, such as long-term care homes, obligated?
Blue Box materials supplied to a business (e.g., the operators of a long-term care home) are not obligated, however, there are no deductions available for materials supplied to a consumer in an IC&I setting (e.g., a resident of a long-term care home).
Any Blue Box materials supplied to consumers in Ontario are obligated. Blue Box materials supplied to the IC&I sector are not obligated (except beverage containers which are obligated regardless of the sector supplied into).
If a marketplace facilitator supplies products for which there is a brand holder resident in Canada, who is the obligated producer?
The brand holder is the obligated producer.
A marketplace facilitator only becomes obligated for products supplied through its marketplace where the producer would have been a retailer. If the producer is a brand holder or an importer, they remain the obligated producer even when products are distributed by a marketplace facilitator.
A retailer is a business that supplies products to consumers, whether online or at a physical location.
Am I a producer of paper products or packaging-like products?
See our FAQs to understand “What are paper products?” and “What are packaging-like products?”.
For paper products and packaging-like products, a person is considered a producer:
- if they are the brand holder of the paper product or packaging-like product and are resident in Canada
- if no resident brand holder, they are resident in Ontario and import the paper product or packaging-like product from outside of Ontario
- if no resident importer, they are the retailer that supplied the paper product or packaging-like product directly to consumers in Ontario
- if the retailer who would be the producer is a marketplace seller, the marketplace facilitator is the obligated producer
- if the producer is a business that is a franchise, the franchisor is the obligated producer, if that franchisor has franchisees that are resident in Ontario
Am I a producer of Blue Box product packaging?
See our FAQ to understand “What is blue box product packaging?”.
Product packaging added to a product can be added at any stage of the production, distribution and supply of the product. A person adds packaging to a product if they:
- make the packaging available for another person to add the packaging to the product
- cause another person to add the packaging to a product
- combine the product and the packaging
For the portion of the product packaging that a brand holder added to the product, a person is considered a producer:
- if they are the brand holder of the product and are resident in Canada
- if no resident brand holder, they are resident in Ontario and import the product from outside of Ontario
- if no resident importer, they are the retailer that supplied the product directly to consumers in Ontario
- if the retailer who would be the producer is a marketplace seller, the marketplace facilitator is the obligated producer
- if the producer is a business that is a franchise, the franchisor is the obligated producer, if that franchisor has franchisees that are resident in Ontario
For the portion of the product packaging that an importer of the product into Ontario added to the product, a person is considered a producer:
- if they are resident in Ontario and import the product from outside of Ontario
- if no resident importer, they are the retailer that supplied the product directly to consumers in Ontario
- if the retailer who would be the producer is a marketplace seller, the marketplace facilitator is the obligated producer
- if the producer is a business that is a franchise, the franchisor is the obligated producer, if that franchisor has franchisees that are resident in Ontario
For any portion of the packaging that is not described above, the producer is the retailer who supplied the product to consumers in Ontario.
Why is a registration and/or reporting deadline communicated by the Authority different than what is written in the regulation?
As the Regulator responsible for enforcing regulations under the Resource Recovery and Circular Economy Act, 2016, the Registrar uses their discretion for when it is necessary to give registrants more time to collect the information needed for registration and/or reporting.
As an EEE producer who has registered, what other requirements do I need to meet?
As of January 1, 2021, producers are required to establish and operate a collection system for ITT/AV that meets the accessibility requirements in the regulation. Producers must ensure that all ITT/AV collected is managed regardless of what their minimum management requirements are.
Producers have the choice of establishing and operating their own collection and management systems or working with one or more producer responsibility organizations (PROs) registered with the Authority to meet their obligations.
Please contact the Compliance Team at 833-600-0530 or registry@rpra.ca to discuss other requirements under the EEE Regulation.
How do I determine if I am an exempt ITT/AV producer?
An ITT/AV producer qualifies for an exemption if their average weight of supply for that calendar year is less than or equal to 5,000 kg.
Average supply weight is determined using the following formula:
Average weight of ITT/AV supply = (Y3 + Y4 + Y5) / 3
Eg. 2025 average weight of supply = (2022 + 2021 + 2020) / 3
ITT/AV producers that meet the exemption criteria are exempt from:
- Registering and reporting to RPRA
- Establishing a collection and management system
- Meeting a management requirement
- Promotion and education requirements
Producers must verify that they continue to meet the exemption annually, since their average weight of supply will change from year to year.
Exempt producers must keep records related to the weight of ITT/AV supplied into Ontario each year and provide them to the RPRA upon request.
Producers are advised to confirm their exemption with the Compliance Team at 833-600-0530 or registry@rpra.ca.
If I am already registered with the Authority under a different Regulation, do I have to register again to comply with the EEE Regulation?
Yes. You are still required to register with the Authority Registry even if you already have an existing account.
As a producer, am I required to provide an audit report with my ITT/AV supply data?
As shown in the table below, verification of the ITT/AV supply data reported in 2020 and 2021 is not required. Verification of supply data for ITT/AV will be required starting in 2022 for products supplied in 2020. All subsequent years of supply data are required to be verified when the data is reported.
For more information on the required verification and audit of data, view the Registry Procedure: EEE Verification and Audit.
Am I an ITT/AV producer?
You are an information technology, telecommunications, audio-visual (ITT/AV) producer if you market ITT/AV into Ontario and:
- Are the brand holder of the EEE and have residency in Canada;
- If there is no resident brand holder, have residency in Ontario and import EEE from outside of Ontario;
- If there is no resident importer, have residency in Ontario and market directly to consumers in Ontario (e.g., online sales); or
- If there is no resident marketer, do not have residency in Ontario and market directly to consumers in Ontario (e.g., online sales).
Even if you do not meet the above definition, there may be circumstances where you qualify as a producer. Read the Electrical and Electronic Equipment Regulation for more detail or contact the Compliance and Registry Team for guidance at registry@rpra.ca or (647) 496-0530 or toll-free at (833) 600-0530.