Topic: Reporting to RPRA

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?

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.

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?

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.

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:

• 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.
• The materials were supplied onsite to a consumer for personal, family or household purposes.
• 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 does not reduce the obligation of a producer to provide complete and accurate supply data or limit the ability of a RPRA inspector to review the data and related records for the purpose of determining compliance.