Ontario vs Washington EPR: Rules Compared
Last verified
Ontario and Washington both run packaging EPR, but the rules differ. Ontario exempts only producers below the lower revenue floor, CA$2,000,000 against $5,000,000 in Washington. Washington has the lower weight floor, 907.2 kg against 1 tonne in Ontario. Both require producers to register. Both programmes set their first annual report for May 31.
Ontario and Washington side by side
4 of 9 rows have a verified figure on each side of Ontario and Washington; a cell reads “not yet published” when a side has none, and an exemption row reads “none recorded; see thresholds” when no exemption is on record.
| Measure | Ontario | Washington | Stricter |
|---|---|---|---|
| Registration duty | Required | Required | Same |
| Producer organisation | more than one producer responsibility organisation | one producer responsibility organisation | Not comparable |
| Lowest revenue exemption | CA$2,000,000 | $5,000,000 | Ontario |
| Lowest weight exemption | 1 tonne | 907.2 kg | Washington |
| First annual report date | May 31 | May 31 | Same |
| Published penalties | not yet published | 1 published | Not comparable |
| Report file | csv | csv | Not comparable |
| Paper fee, cheapest matched rate | not yet published | not yet published | Not comparable |
| Plastic fee, cheapest matched rate | not yet published | not yet published | Not comparable |
The lowest revenue exemption is CA$2,000,000 in Ontario and $5,000,000 in Washington (CA$6,989,000 at the Bank of Canada 2025 annual average rate). Ontario therefore reaches smaller sellers: a business with revenue between the two lines is exempt in Washington but still in scope in Ontario.
The lowest weight exemption is 1 tonne of packaging in Ontario and 907.2 kg in Washington, about 1.1 times as much in Ontario as in Washington. A seller whose packaging falls between the two lines is exempt in Ontario but counted in Washington.
Both programmes require a producer to register, in Ontario and in Washington.
The first annual report date is the same on both sides, May 31.
Who runs the programme in Ontario and Washington
Who collects and who the producer files with, in Ontario and then Washington.
| Aspect | Ontario | Washington |
|---|---|---|
| Regime | Full producer responsibility for Blue Box material (packaging, paper products, packaging-like products) under the Blue Box Regulation | Washington Recycling Reform Act, chapter 70A.208 RCW |
| Regulator | Resource Productivity and Recovery Authority (RPRA) | Washington State Department of Ecology |
| Producers obligated | Yes | Yes |
| Registration | Required, RPRA Registry | Required, Producer registers with a PRO; the PRO registers with Ecology |
| Producer organisation | more than one producer responsibility organisation; membership optional | one producer responsibility organisation: Circular Action Alliance; membership required |
| Transfer of responsibility | Allowed | not yet published |
| Revenue counted as | regional revenue, CAD, calendar year | worldwide gross revenue, USD, prior fiscal year |
| Who counts as the producer | other: brand owner, importer, seller, online marketplace; primary: brand owner, importer, seller, online marketplace; secondary: brand owner, importer, seller, online marketplace; service: seller; shipping: brand owner, importer, seller, online marketplace; tertiary: brand owner, importer, seller, online marketplace | primary: manufacturer, brand licensee, brand owner, importer |
The two programmes are organised differently. Ontario uses more than one producer responsibility organisation; Washington uses one producer responsibility organisation. For a seller in both, that usually means two different counterparties, two different sign-up routes and two different sets of terms to read before the first report is due.
What Ontario and Washington cover, side by side
Each row below is one published feature of the two programmes; a cell reads “not yet published” when Ontario or Washington has no verified entry for it in the dataset.
| Aspect | Ontario | Washington |
|---|---|---|
| Materials covered | paper, glass, metal, plastic, other | packaging, paper products |
| Product classes covered | primary packaging, secondary packaging, shipment packaging, other | packaging, paper |
| Excluded from scope | producers under revenue exemption, newspaper producers for collection management and promotion | exempt materials |
| Sales channels addressed | retail, wholesale, online, online marketplace | physical retail, remote sale, other distribution |
| Producer duty: primary packaging | brand_owner; importer; seller; marketplace | manufacturer; licensee; brand_owner; importer |
| Producer duty: secondary packaging | brand_owner; importer; seller; marketplace | not yet published |
| Producer duty: tertiary packaging | brand_owner; importer; seller; marketplace | not yet published |
| Producer duty: shipping packaging | brand_owner; importer; seller; marketplace | not yet published |
| Producer duty: service packaging | seller | not yet published |
| Producer duty: other packaging | brand_owner; importer; seller; marketplace | not yet published |
| Reporting categories | 7, material category | not yet published |
| Published targets | paper_management_requirement 80 by 2027-12-31; rigid_plastic_management_requirement 50 by 2027-12-31; flexible_plastic_management_requirement 10 by 2027-12-31; glass_management_requirement 75 by 2027-12-31; metal_management_requirement 67 by 2027-12-31; beverage_container_management_requirement 75 by 2027-12-31 | not yet published |
| Exemption 1 | Producers with gross annual Ontario revenue under 2,000,000 dollars are exempt from all producer requirements. | A de minimis producer is under one ton, or under the global revenue limit, or an agricultural employer within limits. |
| Exemption 2 | Producers above the revenue level but below the per-category supply weights are exempt from collection, management and promotion and education, but still register and report. | Registered 501(c)(3) and 501(c)(4) organizations are excluded from the producer definition. |
| Exemption 3 | Producers whose newspaper supply is more than 70 percent of their total Blue Box weight are exempt from collection, management and promotion and education. | not yet published |
Thresholds and exemptions in Ontario and Washington
Every verified threshold Ontario and Washington publish, as each states it.
| Place | Measure | Amount | Effect | Basis as published |
|---|---|---|---|---|
| Ontario | revenue | CA$2,000,000 | exempt below | gross annual Ontario revenue from products and services |
| Ontario | packaging tonnage | 9 tonnes | exempt below | paper supplied in Ontario per year (9,000 kg) |
| Ontario | packaging tonnage | 2 tonnes | exempt below | rigid plastic supplied in Ontario per year (2,000 kg) |
| Ontario | packaging tonnage | 2 tonnes | exempt below | flexible plastic supplied in Ontario per year (2,000 kg) |
| Ontario | packaging tonnage | 1 tonne | exempt below | glass supplied in Ontario per year (1,000 kg) |
| Ontario | packaging tonnage | 1 tonne | exempt below | metal supplied in Ontario per year (1,000 kg) |
| Ontario | packaging tonnage | 1 tonne | exempt below | beverage containers supplied in Ontario per year (1,000 kg) |
| Washington | packaging tonnage | 1 short ton | exempt below | covered materials introduced, most recent fiscal year |
| Washington | revenue | $5,000,000 | exempt below | global gross revenue, prior fiscal year |
Ontario exemption: Producers with gross annual Ontario revenue under 2,000,000 dollars are exempt from all producer requirements. It does not have to be applied for.
Ontario exemption: Producers above the revenue level but below the per-category supply weights are exempt from collection, management and promotion and education, but still register and report. It does not have to be applied for.
Ontario exemption: Producers whose newspaper supply is more than 70 percent of their total Blue Box weight are exempt from collection, management and promotion and education. It does not have to be applied for.
Washington exemption: A de minimis producer is under one ton, or under the global revenue limit, or an agricultural employer within limits. It does not have to be applied for.
Washington exemption: Registered 501(c)(3) and 501(c)(4) organizations are excluded from the producer definition. It does not have to be applied for.
Read the basis column first: the same amount can exempt a producer in one programme and only simplify its report in another.
The lowest revenue exemption is CA$2,000,000 in Ontario and $5,000,000 in Washington (CA$6,989,000 at the Bank of Canada 2025 annual average rate). Ontario therefore reaches smaller sellers: a business with revenue between the two lines is exempt in Washington but still in scope in Ontario.
The lowest weight exemption is 1 tonne of packaging in Ontario and 907.2 kg in Washington, about 1.1 times as much in Ontario as in Washington. A seller whose packaging falls between the two lines is exempt in Ontario but counted in Washington.
Fees per kilogram for shared materials
Neither Ontario nor Washington has a verified per-kilogram fee schedule in the dataset yet. Until both sides publish per-kilogram rates for the same material class, a fee comparison between Ontario and Washington would mean inventing a figure, and this page does not do that.
Deadlines in Ontario and Washington
Each verified date, with the period it covers when one is given.
| Place | Kind | Date | Covers |
|---|---|---|---|
| Ontario | report | May 31, 2026 | calendar year 2025 |
| Ontario | report | May 31, 2026 | calendar year 2025 |
| Washington | other | March 1, 2026 | not yet published |
| Washington | report | May 31, 2026 | not yet published |
| Washington | registration | July 1, 2026 | not yet published |
| Washington | other | October 1, 2028 | not yet published |
| Washington | other | March 1, 2029 | not yet published |
| Washington | other | January 1, 2030 | not yet published |
| Washington | payment | February 15, 2031 | not yet published |
| Washington | payment | February 15, 2032 | not yet published |
The first annual report date is the same on both sides, May 31.
Penalties in Ontario and Washington
What each side has published; a side without an amount says so.
Washington penalty for producer violating chapter 70A.208 RCW: up to $1,000 per day.
Report formats in Ontario and Washington
How the report file for Ontario compares with the one for Washington.
| Aspect | Ontario | Washington |
|---|---|---|
| Layout | Ontario Blue Box supply report (working layout) Working layout, sources reviewed 2026-11-04 | Washington interim producer supply report by material class 2026-09-29 (interim, built from CAA guidance) |
| Recipient | Resource Productivity and Recovery Authority (RPRA) | Circular Action Alliance (Washington PRO) |
| How it is submitted | RPRA Registry (online). The customer signs in and enters or submits. | CAA producer portal. The customer signs in and submits. |
| File type | csv | csv |
| Encoding | utf-8 | utf-8 |
| Delimiter | , | , |
| Decimal separator | . | |
| Columns | 4 | 4 |
| Required columns | 4 of 4 | 4 of 4 |
| Weight unit | kg | lb |
| Period basis | calendar year | calendar year |
The two layouts share a file type and a delimiter, but each programme names its own columns and categories, so one file cannot be sent to both programmes. Each report is built from the same underlying measurements and exported separately.
Which to plan for first, Ontario or Washington
Check the exemption thresholds before anything else. Ontario reaches smaller sellers than Washington, so a seller that is exempt in Washington may still have to register in Ontario.
Questions about comparing these two programmes
Is Ontario or Washington stricter on packaging EPR?
Ontario exempts only producers below the lower revenue floor, CA$2,000,000 against $5,000,000 in Washington. Washington has the lower weight floor, 907.2 kg against 1 tonne in Ontario. Both require producers to register. Both programmes set their first annual report for May 31.
Do I register in both Ontario and Washington?
Ontario requires producers to register. Washington requires producers to register.
How do the fees per kilogram compare in Ontario and Washington?
The dataset does not hold per-kilogram rates for the same material class on both sides, so this page does not compare fees.
Which deadline comes first, Ontario or Washington?
The first annual report date is the same on both sides, May 31.
How these figures are made
Sources
- rpra.ca: regulation retrieved
Original wording: Blue Box producers became fully accountable and financially responsible for collecting and recycling their materials when consumers discard them.
- rpra.ca: producers retrieved
Original wording: Unless otherwise stated, all information must be submitted through RPRA’s registry.
Original wording: if they supply Blue Box material (packaging, paper products or packaging-like products) comprised of paper, glass, metal or plastic
Original wording: Within 30 days of supplying obligated Blue Box materials in Ontario
Original wording: PROs operate in a competitive market, and producers can choose the PRO (or PROs) they want to work with.
Original wording: Producers have the choice of working with one or more producer responsibility organizations (PROs) registered with RPRA
Original wording: Any producer whose gross annual Ontario revenue from products and services is less than $2,000,000 is exempt from all producer requirements under the regulation.
Original wording: if the retailer who would be the producer is a marketplace seller, the marketplace facilitator is the obligated producer
Original wording: is exempt from all producer requirements under the regulation.
Original wording: Paper 9,000
Original wording: Rigid plastic 2,000
Original wording: Flexible plastic 2,000
Original wording: Glass 1,000
Original wording: Metal 1,000
Original wording: Beverage containers 1,000
Original wording: Any producer who meets the exemption must keep any records that demonstrate its gross annual Ontario revenue is less than $2,000,000
Original wording: the producer is required to register and report.
Original wording: newspaper must account for more than 70% of their total weight of Blue Box materials supplied to consumers in Ontario in a calendar year.
Original wording: Deadline: Supply data must be submitted by May 31 of each year.
Original wording: Deadline: Performance reporting is due May 31 of each year.
Original wording: Under the Blue Box Regulation, consumers are individuals who use a product and its packaging for personal, family or household purposes.
Original wording: beverage container, glass, flexible plastic, rigid plastic, metal, paper, and certified compostable products and packaging
Original wording: Management requirement = A × B
- circularactionalliance.org: washington retrieved
Original wording: required in the Recycling Reform Act
Original wording: By January 1, 2026 Washington Department of Ecology must establish and appoint the initial membership of the advisory council.
Original wording: July 1, 2026 Washington regulatory deadline for Producers to register with a PRO.
Original wording: By March 1, 2026 A PRO must register with Washington Department of Ecology on behalf of its producers.
Original wording: By May 31, 2026 Reporting (Interim State Addendum Signed & Simplified Reporting)
- app.leg.wa.gov: default retrieved
Original wording: After July 1, 2026, be a member of a producer responsibility organization registered in this state
Original wording: Has a global gross revenue, not including on-premises alcohol sales, for the prior fiscal year of
Original wording: the producer is the person that manufactures the item
Original wording: In their most recent fiscal year introduced less than one ton of covered materials
Original wording: Until January 1, 2031, less than $5,000,000
Original wording: "De minimis producer" means a producer that
Original wording: Registered 501(c)(3) charitable organizations and 501(c)(4) social welfare organizations
Original wording: By October 1, 2028, and every five years thereafter, submit a plan that meets the requirements of this chapter
Original wording: Beginning March 1, 2029, a producer that is not a member in good standing with a registered producer responsibility organization
Original wording: By January 1, 2030, or within six months of plan approval, whichever is later, implement the plan approved by the department
Original wording: No less than 75 percent of the net costs by February 15, 2031
Original wording: No less than 90 percent of the net costs by February 15, 2032, and each year thereafter
Original wording: civil penalty of up to $1,000 per violation per day on any producer who violates this chapter
Original wording: "Covered material" means packaging and paper products introduced into the state.
- ecology.wa.gov: producer responsibility organization retrieved
Original wording: The Circular Action Alliance is the PRO representing producers in Washington. We encourage all potentially obligated producers to register with CAA.
- Bank of Canada, FXAUSDCAD (annual average 2025) retrieved
The free plan is enough to start. We estimate and prepare; you sign and submit.