Topic: Reporting to RPRA

What information do Blue Box producers need to provide when reporting their supply data to RPRA?

Starting in 2022, producers are required to report their supply data annually to RPRA.

Each year, producers will need to provide the previous years’ supply data in each of the seven material categories – beverage container, glass material, flexible plastic, rigid plastic, metal material, paper material, and certified compostable products and packaging material – as well as any deductions.

See our FAQ to understand “What deductions are available to producers under the Blue Box Regulation?

 

Are Blue Box materials that are supplied to the Industrial, Commercial, and Institutional (IC&I) sector obligated?

Blue Box materials supplied to the IC&I sector are not obligated, therefore, deductions are available for materials supplied to a consumer in an IC&I setting.

Blue Box producers may deduct materials that are collected from a business or institution where producers are not required to provide Blue Box collection services. Examples include:

  • Offices
  • Stores and shopping malls
  • Restaurants
  • Hotels
  • Hospitals
  • Community centres
  • Places of worship
  • Recreation facilities
  • Sports and entertainment venues
  • Universities and colleges
  • Manufacturing facilities
  • Golf courses
  • Cemeteries
  • Amusement parks

Producers are responsible for material collected from eligible sources in the producer run Common Collection System, Alternative or Supplemental Collections Systems. Material from these categories is not allowed to be deducted:

  • Material that is collected from a residence through a curbside or depot collection service.
  • Material that is generated at a facility (including multi-residential buildings, retirement homes, long-term care homes and schools).
  • Material that is collected from a public space (including an outdoor area in a park, playground or sidewalk, or a public transit station).
  • Material collected under an alternative or supplemental collection system.

Please see the Reporting Guidance Ineligible Source Deductions for the 2026 Blue Box Supply Report for more information on how to determine and use these deductions.

Also see our FAQs: ‘What deductions are available to producers under the Blue Box Regulation?’, ‘Who is a consumer under the Blue Box Regulation’

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.

Are containers that are obligated under the Hazardous and Special Products (HSP) Regulation obligated as Blue Box materials?

No, products or packaging designated as Hazardous and Special Products (HSP) are not obligated under the Blue Box Regulation. For example, primary packaging for paints and coatings are HSP and therefore not obligated as Blue Box materials.

Some packaging for HSP products may still be obligated. For example, the packaging that contains an oil filter is obligated as Blue Box materials.

Consult the HSP Regulation or the Compliance and Registry Team for further information.

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

 

Producer hierarchies - paper products and packaging-like products

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.

 

Producer hierarchy - Blue box packaging

Is the data I report to RPRA the same as what I reported to Ontario Electronic Stewardship?

No. The list of products obligated under the EEE Regulation is different from the list of products included in the OES Program. The OES Program required producers to report the number of units they supplied, while the EEE Regulation requires producers to report the total weight of products.

To help producers calculate the weight of their products, we have included weight conversion factors in our Verification and Audit procedure, which is included as a weight conversion tool on the registration form.  Once a producer determines the units of products on which they are obligated to report, they can enter the units into the conversion tool to get a calculated weight to report to RPRA.

For more information, see the Determining Supply Data section of the Registry Procedure: EEE Verification and Audit.

As a producer, can other companies (e.g., retailers or distributors of my products) report my supply data to RPRA on my behalf?

Yes. If you are a producer with retailers or distributors supplying your obligated EEE into Ontario, you can email us at [email protected] to discuss options on how to report your supply data. There are several options available, including an easy-to-use sales formula and weight conversion factors. See the EEE Verification and Audit procedure for more information.

One option is to have your supply data reported by each of your retailers or distributors on a piecemeal basis. The piecemeal option requires that extra steps be undertaken by you and RPRA. You must contact RPRA in advance if you wish to pursue this option.

Note that even if you have a retailer or distributor providing data on your behalf, it remains the producer’s obligation to ensure that all the required data gets reported and that it is reported accurately to RPRA in accordance with the EEE Regulation. The entry of inaccurate information by someone on your behalf is not a defense to non-compliance.

As an ITT/AV producer, am I required to verify my supply data? 

Each year, large ITT/AV producers are required to submit a supply data verification report in accordance with the EEE Verification and Audit Procedure. Small producers are not required to submit a verification report but will be subject to inspections. 

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

As a battery producer, am I required to verify my supply data? 

Each year, large battery producers are required to submit a supply data verification report in accordance with the Batteries Registry Procedure – Verification and Audit. Small producers are not required to submit a verification report but will be subject to inspections.

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

Why is there an executive attestation requirement?

Brand holders and producers that supply products and packaging are required by legislation to meet individual mandatory collection and resource recovery requirements and may face compliance and enforcement consequences for failing to do so. The executive attestation ensures that executives responsible for managing the brand holder’s or producer’s business are aware of these requirements and can ensure that appropriate measures are put in place to achieve compliance with the regulations.