Topic: Reporting to RPRA

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.

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.

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.

Yes, producers are legally required to register and report to RPRA. There are some differences between which materials were reported to Stewardship Ontario as a steward and what must now be reported to RPRA as a producer. Differences include:

• newly obligated materials
• brand holder in Canada now obligated (rather than Ontario)
• producer must report total supply, and then report any weight to be deducted separately.

During transition years, stewards must meet their requirements (e.g., paying fees to Stewardship Ontario) under the Blue Box Program Plan and the WDTA. Producers also have requirements under the new Blue Box Regulation and the RRCEA, which includes registering, reporting, paying their program fee to RPRA and establishing collection, management and promotion and education systems for Blue Box materials.

Under the Blue Box Regulation, allowable deductions for producers include Blue Box materials that are deposited into a receptacle at a location that is not an eligible source and where the product related to the Blue Box material was supplied to a consumer and used or consumed.

This applies to locations such as arenas, college and university campuses and food courts.

A producer must demonstrate the following with regards to an allowable deduction:

1. They are the obligated producer for the materials for which they are claiming a deduction, and the weight of those materials was included in their reported supply data.
2. The materials were supplied onsite to a consumer for personal, family or household purposes.
3. The same materials that were supplied, were used or consumed onsite and disposed of in a receptacle onsite.

Blue Box materials that were disposed of in a building’s receptacles but were not supplied and used or consumed within that physical building are not deductible. This deduction applies to all Blue Box materials supplied for personal, family or household, but not those supplied for business purposes. This deduction is not available for beverage containers.

This does not reduce the obligation of a producer to provide complete and accurate supply data or limit the ability of an Authority inspector to review the data and related records for the purpose of determining compliance.

For the purpose of reporting supply data under the Blue Box Regulation, the weight of newspaper, including any protective wrapping and supplemental advertisements and inserts, must be reported in the appropriate material categories. For example, newsprint must be reported in the ‘paper’ category, while any protective plastic wrapping must be reported as ‘flexible plastic’.

Then, producers will be asked to indicate what percentage of their total Blue Box material supply was newspaper, including any protective wrapping and supplemental advertisements and inserts, in that calendar year.

When reporting either their total supply or the percentage of their total supply that is newspaper, a producer should only include the weight of Blue Box materials for which they are the producer. For example, if flyers for which there is a different brand holder resident in Canada are supplied along with a newspaper and those flyers have a different brand holder resident in Canada, their weight should not be reported by the newspaper producer. Instead, it is the brand holder of those flyers who would be required to include the weight of those flyers in their own supply report.

See our FAQ: “What is a newspaper?”