Topic: Reporting to RPRA

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.

If I already reported my Blue Box supply data to Stewardship Ontario through the WeRecycle Portal, do I have to report again to RPRA?

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.

What must a producer demonstrate to deduct materials that are supplied, used, or consumed and disposed of at a non-eligible source (e.g., an arena, a college or university campus, or a food court)?

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.

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

A tire producer qualifies for an exemption if their average weight of supply for that calendar year is less than 1,175 kg.

Average supply weight is determined using the following formula:

Average weight of tire supply = (Y3+Y4+Y5) / 3

E.g. 2025 average weight of supply = (2022 + 2021 + 2020) / 3

Tire producers that meet the exemption criteria are exempt from:

  • Registering and reporting to RPRA
  • Establishing a collection and management system
  • Meeting a management requirement

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 tires supplied into Ontario each year and provide them to RPRA upon request.

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

Can a producer choose to work with an external consultant?

Producers are obligated parties under the Resource Recovery and Circular Economy Act and are ultimately responsible for their data submitted through RPRA’s Registry. Producers can choose to contract with an external consultant to support their data submission, but third parties have limited permissions in the Registry as they are not regulated parties.

A producer can choose to assign a primary or secondary user profile in their Registry account to an external consultant. An external consultant may submit supply data reports and/or pay registry fees on the producer’s behalf.

External consultants cannot submit and/or sign registration, executive attestations, account admin changes or supply data adjustment documentation on behalf of a producer. External consultants cannot be account admins, nor can they manage a PRO within the Registry on behalf of a producer.

Who does RPRA consider an acceptable verifier/qualified person?

A Verifier can be an individual, either an employee of the business or a hired third-party (including a PRO), who has one of the following designations and is not the same person who prepared the supply report:

  • CPA (Chartered Professional Accountants) in Canada or CPA (Certified Public Accountant) in the US
  • ACCA (Association of Chartered Certified Accounts) Qualification
  • CIA (Certified Internal Auditor)
  • CPB (Certified Professional Bookkeeper) in Canada
  • RPA (Registered Professional Accountant) in Canada

For annual supply reporting verification, how do I know if I am a small or large ITT/AV producer?

For the purposes of ITT/AV supply reporting verification:

  • “Large ITT/AV producer” means an ITT/AV producer with a minimum management requirement greater than or equal to 200,000 kilograms in the previous calendar year.

To view your management requirements, log into your Registry account, download a copy of your previous year’s Supply Report and review the section with your minimum management requirements for your reporting year.

Beginning in 2023, only large producers are required to submit a Supply Data Verification Report. Small producers will no longer be required to submit a verification report but will be subject to inspections. Review the Registry Procedure – Verification and Audit for more information.

For annual supply reporting verification, how do I know if I am a small or large battery producer?

For the purposes of battery supply reporting verification:

  • “Large single-use battery producer” means a battery producer with a minimum management requirement greater than or equal to 50,000 kilograms of single-use batteries in the previous calendar year.
  • “Large rechargeable battery producer” means a battery producer with a minimum management requirement greater than or equal to 5,000 kilograms of rechargeable batteries in the previous calendar year.

To view your management requirements, log into your Registry account, download a copy of your previous year’s Supply Report and review the section with your minimum management requirements for your reporting year.

Beginning in 2023, only large producers are required to submit a Supply Data Verification Report. Small producers will no longer be required to submit a verification report but will be subject to inspections. Review the Registry Procedure – Verification and Audit for more information.

How do newspaper producers report their supply of newspapers?

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?”