Frequently Asked Questions

No. Producers and PROs working on their behalf must operate the collection systems they have established as required by the Regulation even after their requirements are met. If a consumer is refused permission to drop off materials at a registered collection site, they can contact the Compliance and Registry Team at registry@rpra.ca, 647-496-0530 or toll-free at 1-833-600-0530.

A battery producer qualifies for an exemption if its management requirement is less than 1.25 tonnes of rechargeable batteries or less than 2.5 tonnes of single-use batteries. A producer’s management requirement is calculated as a percentage of the weight of batteries supplied into Ontario in a specific period. This calculation changes each year, and therefore producers should verify whether they qualify for an exemption annually.

For information about how to calculate your management requirement, refer to our FAQ, How are battery producer minimum management requirements determined?

A producer who meets the weight exemption and has five or more full-time employees does not have collection or management requirements but is required to register and report battery supply data to the Authority.

A producer who meets the weight exemption and has less than five full-time employees has no obligation under the Batteries Regulation.

Producers who want to confirm their status as an exempt producer should contact the Compliance Team at registry@rpra.ca or 833-600-0530.

In determining whether an obligated producer used best efforts to meet their management requirements, the Compliance Team will consider whether the producer, acting in good faith, took all reasonable steps to meet the requirements outlined in the applicable regulation.

For example, best efforts in the context of management requirements may involve a producer regularly monitoring the volume of material being collected and managed, and implementing plans for increasing those volumes if the requirements are unlikely to be met.

Producers can contact the Compliance Team to ask specific questions about fulfilling their obligations.

As of July 1, 2020, producers are required to establish and operate a collection system for batteries that meets the accessibility requirements in the regulation. Producers must ensure that all batteries collected are managed regardless of their minimum management requirements.

For producers to meet their obligations, they have the choice of establishing and operating their own collection and management system or working with one or more producer responsibility organizations (PROs) that are registered with the Authority.

Please contact the Compliance Team at 833-600-0530 or registry@rpra.ca to discuss other requirements under the Batteries Regulation.

No. The Authority does not administer contracts or provide incentives. Under the Regulations, producers will either work with a producer responsibility organization (PRO) or work directly with collection sites, haulers, refurbisher’s and/or processors to meet their collection and management requirements. Any reimbursement for services provided towards meeting a producers’ collection and management requirements will be determined through commercial contracts.

To discuss any payment, contact your service provider or a PRO. RPRA does not set the terms of the contractual arrangements between PROs and producers.

Producer supply data is used to calculate their individual minimum management requirements under the Batteries Regulation.

To learn how calculations are formulated, visit the FAQ How are battery producer minimum management requirements determined?

A volunteer organization is a person who:

• Is a brand holder who owns a brand that is used in respect of batteries or EEE;
• Is not a resident in Canada;
• Has registered with the Authority; and
• Has entered into a written agreement with a producer for the purpose of carrying out one or more producer responsibilities.

A volunteer organization is not a producer but can take on the registration and reporting responsibilities for producers in relation to its brand. Under the Regulation, producers remain responsible for meeting their management requirements and cannot pass off their obligations through voluntary remitter agreements or any other commercial agreement.

Any brand holder or producer who is interested in making any agreement as indicated (or described) above, should contact the Compliance Team at registry@rpra.ca, 647-496-0530 or toll-free at 1-833-600-0530.

A producer responsibility organization (PRO) is a business established to contract with producers to provide collection, management, and administrative services to help producers meet their regulatory obligations under the Regulation, including:

• Arranging the establishment or operation of collection and management systems (hauling, recycling, reuse, or refurbishment services)
• Establishing or operating a collection or management system
• Preparing and submitting reports

PROs operate in a competitive market and producers can choose the PRO (or PROs) they want to work with. The terms and conditions of each contract with a PRO may vary.

Individual Producer Responsibility (IPR) means that producers are responsible and accountable for collecting and managing their products and packaging after consumers have finished using them.

Under the regulation, producers are directly responsible and accountable for meeting mandatory collection and recycling requirements for end of life products. With IPR, producers have choice in how they meet their requirements. They can collect and recycle the products themselves, or contract with producer responsibility organizations (PROs) to help them meet their requirements.

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.

The Authority recognizes the commercially sensitive nature of the information that parties submit to the registry. The Authority is committed to protecting the commercially sensitive information and personal information it receives or creates in the course of conducting its regulatory functions. In recognition of this commitment, the Authority, in addition to the regulatory requirements of confidentiality set out in the Resource Recovery and Circular Economy Act 2016 (section 57), has created an Access and Privacy Code that applies to its day-to-day operations, including the regulatory functions that it carries out.

Obligated material supply, collection, and resource recovery data will only be made public in aggregate form, to protect the confidentiality of commercially sensitive information.

The Authority will publish the names and contact information of all registered businesses – producers, service providers (collectors, haulers, processors, etc.), and producer responsibility organizations. The public will also have access to a list or method to locate any obligated material collection sites, as this information becomes available.

As part of its regulatory mandate, the Registrar will provide information to the public related to compliance and enforcement activities that have been undertaken.

The information that is submitted to the Registry will be used by the Registrar to confirm compliance and to track overall collection and management system performance. It will also be used by the Authority to update its policies and procedures and by the Ministry of Environment, Conservation and Parks for policy development.

If a producer misreports their supply data to RPRA, they must contact the Compliance and Registry Team immediately by emailing registry@rpra.ca. Please include the following information in the email:

• The rationale for the change in the data
• Any data that supports the need for a correction (e.g., sales documents, audit)
• Any other information to support the change

While it is an offence to submit false or misleading information under the RRCEA, RPRA wants this corrected as quickly to ensure a producer’s minimum management requirement is calculated using accurate supply data.

RPRA can only receive these requests from the primary contact on the company’s Registry account. Your request for an adjustment will be reviewed by a Compliance and Registry Officer.

In accordance with the legislation (Resource Recovery Circular Economy Act 2016, section 57), the Authority is required to comply with strict confidentiality requirements. The Authority has also developed an Access and Privacy Code that applies to its day-to-day operations.

The Registry has been developed according to cybersecurity best practice principles. This includes VPN-based restrictions, staff training on all cybersecurity policies, staff access to the Registry on a strict role-requirement basis, and registry interface security features (example: two-factor authentication).

You are considered a battery producer under the Batteries Regulation if you market batteries into Ontario and meet the following requirements:

• Are the brand holder of the battery and have residency in Canada;
• If there is no resident brand holder, have residency in Ontario and import batteries from outside of Ontario;
• If there is no resident importer, have residency in Ontario and markets directly to consumers in Ontario (e.g., online sales); or
• If there is no resident marketer, does not have residency in Ontario and markets 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 Batteries 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.

There is no audit verification requirement for the first two supply data reports submitted to the Authority. Therefore, data submitted for single-use batteries supplied in 2018, 2019, and 2020, as well as rechargeable batteries supplied in 2018 and 2019 will not have to be verified in accordance with the Registry Procedure – Verification and Audit.

As shown in the table below, under section 15 of the Battery Regulation, the first supply data report for which there are audit and verification requirements will be submitted in 2022. This supply data report is for single-use batteries supplied in 2021 and rechargeable batteries supplied in 2020.

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.

For the reporting period ending September 30, 2021, producers of batteries and ITT/AV are required to report the following:

If you are a producer of ITT/AV, you are required to report:

• The weight of ITT/AV supplied in 2019
• If applicable, the weight of post-consumer recycled content or products eligible for a reduction in management requirement (outlined in the EEE Verification and Audit Procedure) supplied in Ontario for 2019

To learn what specific ITT/AV are required to be reported, read our Compliance Bulletin What ITT/AV needs to be reported?

If you are a producer of single-use batteries, you are required to report:

• The weight of single-use batteries supplied in 2020
• If applicable, the weight (if any), of post-consumer recycled content contained in the batteries supplied in Ontario for 2020

If you are a producer of rechargeable batteries, you are required to report:

• The weight of rechargeable batteries supplied in 2019
• If applicable, the weight of post-consumer recycled content contained in the batteries supplied in Ontario for 2019

You can use our weight conversion factor to determine weights, in which case you will need to determine the number of units sold into Ontario for each applicable material. For more information, visit our Battery Verification and Audit Procedure.

To learn what specific batteries are required to be reported, read our Compliance Bulletin What batteries need to be reported?

Here are the lists of registered PROs:

Tire PROs

Battery PROs

EEE PROs

Blue Box PROs

Hazardous and Special Products PROs

These lists will continue to be updated as new PROs register with RPRA.

Yes. PROs are private enterprises and charge for their services to producers.

Each commercial contract a producer enters with a PRO will have its own set of terms and conditions. It is up to the PRO and producer to determine the terms of their contractual agreement, including fees and payment schedule.

RPRA does not set the terms of the contractual arrangements between PROs and producers.

Yes. Producers and service providers can enter into contractual agreements with multiple PROs.

Under the Resource Recovery and Circular Economy Act, the Authority is required to provide an annual report to the Minister that includes information on aggregate producer performance, and a summary of compliance and enforcement activities. Under section 51 of the Act, the Registrar also is required to post every order issued on the Registry.