Consultation webinar: Proposed changes to Blue Box supply reporting

Executive Summary

The Resource Productivity and Recovery Authority (RPRA) is consulting on proposed changes to Ontario Blue Box supply reporting. The proposals aim to improve the quality and comparability of reported supply data, help identify non-reporters and inaccurate reports, and support more risk-based inspections. They are proposals, not final requirements.

The consultation opened on October 2 and is scheduled to close on November 16. RPRA plans to refine the documents based on feedback and publish final guidance around December or January for use in the 2027 reporting cycle.

Proposed Reporting and Verification Playbook

• Expand and standardize supply data. Current reporting focuses on tonnage for six regulated categories, related deductions, and brand lists. RPRA proposes collecting more detail using 57 harmonized categories it considers applicable in Ontario. These are drawn from a wider set of 62 categories developed with producer-responsibility organizations across Canada.
• Use a three-stage inspection process:
  1. Risk assessment: Screen submitted data and compare companies using additional information, including North American Industry Classification System (NAICS) codes.
  2. Verification review: Ask targeted questions and request evidence when data warrant closer review.
  3. Audit: Conduct a more extensive examination, including a review of internal controls, and potentially recommend improvements.

RPRA said its current information checks take an average of 75 days. More structured submissions are intended to speed up initial screening and reduce repeated follow-up.

• Apply a graduated evidence standard for supply weights:

  • Level 1 (strongest): Examples include product weights documented with photographs on scales, packaging specifications, and technical product data.
  • Level 2: Examples include more detailed bills of materials, supplier confirmations, and potentially approved weight-conversion coefficients.
  • Level 3 (simplest): For example, materials specifications used by a sales department. This level is intended for limited cases where stronger documentation would be disproportionate.

• Phase in higher evidence coverage. RPRA proposes increasing the share of gross supply supported by Level 1 methods over four years: 20% in year two, 35% in year three, and 50% in year four. By the final year, the proposal calls for 90% of gross supply to be supported by Level 1 or Level 2 methods, leaving up to 10% for Level 3. The percentages apply to tonnage, not the share of SKUs. The precise schedule and calculations should be checked against the consultation document, as the webinar’s explanation was not fully clear.

• Retain evidence rather than submit it all upfront. Businesses would report the methods and percentages used in tables. RPRA said it is not asking companies to attach thousands of photos or specifications to routine submissions. Supporting evidence would be requested selectively during verification or audit.
• Allow evidence to remain valid for a period. RPRA proposes recognizing qualifying evidence for 1,260 days (three and a half years), so companies would not need to reweigh products every year. Similar products—such as different flavours of the same chips in the same packaging—could potentially share weight evidence.
• Use inspections and sampling strategically. RPRA said higher-quality documentation could reduce a company’s risk rating, while random, stratified sampling would be used to test risk assumptions. A lower risk rating would not eliminate the possibility of an inspection.

Other Proposed Changes

Qualitative Information and Sign-Off

RPRA proposes collecting information about a company’s business, products, and relationships with other businesses to help interpret its supply data and identify inconsistencies. It proposes replacing the requirement for a qualified accountant’s signature on this information with company-provided responses and a corporate certification. RPRA staff would conduct the verification work.

Deductions

RPRA described a sharp concentration in deduction claims: the median reported deduction is zero, while a small group of “superusers” claim deductions averaging more than $500,000. It proposes clearer rules and more representative evidence, including accounting for seasonal and demographic variation and distinguishing materially different products. For example, small beverage bottles may be consumed away from home, while larger packages are more likely to be used at home.

RPRA also plans to develop and publish research-based deduction methods for selected industries, which could make substantiation more practical for small and medium-sized businesses. The webinar stated that deductions cannot be claimed for multi-residential buildings covered by the regulatory definition of an obligated object.

Small-Business Reporting

Existing exemptions remain in place, including a revenue threshold of less than $2 million and certain material-specific thresholds. RPRA is also consulting on a simplified reporting approach for businesses with 100 or fewer full-time-equivalent employees. Options discussed include:

• Using fewer reporting categories
• Focusing on brand-owner information
• Reporting the five largest products
• Answering a short set of yes-or-no questions

RPRA could still inspect a business if its risk assessment warranted it.

Business Rationale and Metrics

• RPRA said manufacturers have asked for better data verification and a fairer system, particularly to address both companies that do not report and companies that report inaccurately.
• In its presentation, RPRA cited 2025 supply and processing data that included 114% for glass and 99% for paper. It said these results warranted further investigation, while noting that the system had not yet been fully transitioned and that only 85% had been transitioned at that point.
• RPRA’s business plan calls for verifying 80% of supply and performance data on an ongoing basis by 2031. The 150 largest manufacturers account for about 80% of supply, making them central to achieving that target.
• RPRA proposed that a completed inspection could remain valid for up to three years, reducing repeated visits to large manufacturers while allowing staff to inspect more businesses.
• RPRA noted that producer-responsibility organizations—not RPRA—were forecasting contribution increases of more than 20% the following year. It presented stronger reporting as important to the fairness and accuracy of those cost allocations.

Implementation, Enforcement, and Actions for Businesses

• RPRA said 2027 would be a learning and transition period. The first reporting cycle under the proposed approach would not bring fines for failing to meet the new evidence percentages. Businesses should expect more compliance conversations ahead of 2028, when non-compliance with the phased requirements could have consequences.
• RPRA expects to focus first on getting reporting corrected where possible. It said non-reporting may lead to escalating enforcement, while administrative penalties and assessment of economic impact are topics for a separate consultation.
• Businesses can use the consultation period to review the draft guidance, assess how their current product data map to the proposed categories and evidence levels, and comment on the costs and practicality of the proposed requirements. RPRA specifically invited feedback on evidence methods, the phase-in schedule, deductions, small-business provisions, and information requests.
• Written feedback was requested by November 16 at consultations@rpra.ca. RPRA said it would share the slides and recording and respond to unanswered questions during the consultation period.

Presenters and Source

• Jess Tette, Manager of Communications, RPRA
• Sebastian Amadeus, Director of Inspections, RPRA
• Source: RPRA consultation webinar on proposed changes to Blue Box supply reporting.