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Am I a Blue Box Steward?

Ontario legislation and regulation provide the legal basis for an organization being an obligated steward. Obligated stewards need to register, report, pay fees and retain records.

Subject to the exemptions noted below, your organization is an obligated steward if it meets all three of the following criteria:

  • Residency: Determining if an organization is resident in Ontario can be complex, but it generally involves having a “permanent establishment” or paying provincial income taxes.
  • Supplying Designated Materials: This relates to providing items directly or indirectly to residential consumers. Industrial, Commercial and Institutional sales do not count as supply.
  • Responsible Party: There is a hierarchy that determines which resident steward is responsible for supplied materials, going from brand owners to first importers. Franchisors are responsible for all franchisee materials.

When considering if your organization qualifies for a small business exemption, be sure to include any affiliates in calculating total revenue or tonnes of material:

  • Stewards with gross revenues in Ontario of less than $2 million annually do not need to register with Stewardship Ontario and are exempt from collecting and reporting material data 
  • Stewards with gross sales over $2 million annually but with total reported packaging and paper product quantities of less than 15,000 kg (15 tonnes) must register and report their materials to Stewardship Ontario but are exempt from paying fees.

New stewards should refer to the program’s Onboarding Policy and also be aware of the Blue Box transition to a new regulatory framework, the introduction of simplified fee setting and additional information about fees and invoices.

Contact the Customer Relations team for assistance with any questions: werecycle@stewardshipontario.ca.