About PROs

A Producer Responsibility Organization (PRO) is a business that supports producers to meet their regulatory obligations.

PROs focus on:

• Ensuring the collection of waste in all affected communities and regions.
• Providing compliant waste management and resource recovery for the waste that is collected on behalf of the producers.
• Provision of promotional and educational initiatives.
• Submission of performance reports to the regulatory authorities on behalf of their producers.
• Representing the producers per the legislation.

In Ontario, producers are free to choose the PRO or PROs they wish to work with. We recommend H2 Compliance North America as your preferred and trusted PRO.

A company is considered a producer if they supply the relevant materials onto the market in Ontario. Franchisees and retailers may be considered producers when they are the entity that introduced the materials of producers that are not established in Ontario. The exact definition of a producer is set out in the relevant legislation and should be considered by persons placing products and packaging on the market. In Ontario, the definitions are as follows:

BLUE BOX: For packaging introduced by the brand holder, the producer is:

• The brand holder of the product when they are resident in Canada.
• If the brand holder does not reside in Canada, the importer of the product who resides in Ontario.
• If there is no resident importer, the producer is the retailer that supplied the product directly to consumers in Ontario.
• If the retailer who would be the producer is a marketplace seller, the producer is the marketplace facilitator.
• If the producer is a franchise business and the franchisor has franchisees residing in Ontario, the franchisor is the producer.

For product packaging that an importer of the product into Ontario has added to the product, the producer is:

• The importer of the product who resides in Ontario.
• If there are no resident importers, the retailer who supplied the product to consumers in Ontario.
• If the retailer obligated as producer is a marketplace seller, the marketplace facilitator becomes the producer.
• If the producer is a franchise business and the franchisor has franchisees residing in Ontario, the franchisor is the producer.
• If neither of the above applies, the producer is the retailer who supplied the product to consumers in Ontario.

ITT/AV:
A person is considered a producer for Information Technology, Telecommunications & Audiovisual Equipment (ITT/AV) when they supply ITT/AV into Ontario and:

• are the brand holder of the Electrical and Electronic Equipment (EEE) and reside in Canada
• they reside in Ontario and import EEE from outside of Ontario
• they reside in Ontario and market directly to consumers in Ontario (e.g. online sales)
• they don’t reside in Ontario and market directly to consumers in Ontario (e.g. online sales)

Batteries:
The producer, under the Batteries Regulation is:

• The brand holder residing in Canada
• A resident in Ontario who imported batteries from outside Ontario
• A resident in Ontario who sold directly batteries to consumers in Ontario (e.g. online)
• A non-Ontario resident marketing directly to consumers in Ontario (e.g. online)

What are Management Requirements?

Producers are required to provide a yearly report providing information on the quantity of relevant materials supplied to the market as required by the specific regulation. After applying the relevant deductions where applicable (e.g. for resource recovery or refurbishment), their management requirement is determined as the amount of waste they are ultimately responsible for managing.

Costs for producers:

The PRO will set out the costs based on the fees associated with the collection, recycling and refurbishment of the end-of-life products and packaging. In Ontario, the RPRA can charge a program fee to producers based on the following table presented on RPRA’s website:

2024 Program Fees – RPRA

H2 Compliance operate as a Producer Responsibility Organization (PRO) in Ontario for the Blue Box, ITT/AV and Batteries programs. With its North American footprint, H2 Compliance helps producers to navigate Extended Producer Responsibility regulations across Canada and the United States.

H2 Compliance supports producers with their compliance responsibilities and obligations throughout North America providing environmental and chemical regulatory compliance services.

H2 Compliance is backed by the international experience and presence of the Landbell group, who operate more than 40 PROs around the world. Producers can choose PROs and partners to work with, to ensure that the disposal and recycling of the materials are achieved in line with the regulations.

Set up a free 30 minute consultation with our team to discuss your business needs.

Under Extended Producer Responsibility (EPR) regulations, producers are accountable for the products and packaging after their customers have finished using them. EPR regulations can also set targets and requirements for the recycling and recovery of the resources and materials.

Producers can choose PROs and partners to work with, like H2 Compliance North America, to ensure that the disposal and recycling of the materials are achieved in line with the regulations.