Extended Producer Responsibility for Packaging in Canada

10/30/2024

EPR for Packaging in Canada

As 2024 continues, extended producer responsibility (EPR) programs for packaging in the United States continue to hit new milestones, but none are currently collecting fees from producers. In anticipation of looming reporting and fee deadlines in five US programs, let's explore the implementation of EPR for packaging in several Canadian provinces to learn how our neighbors in the north are managing packaging waste and externalities with EPR.

Similar to the US, extended producer responsibility (EPR) for packaging legislation in Canada is organized at the provincial level, rather than the federal level. Canada currently has nine active EPR for packaging laws, all with different timelines, covered materials, and structures.

Canadian Provinces with EPR for Packaging Legislation:

Alberta — Extended Producer Responsibility Regulation
British Columbia — Packaging & Paper Product EPR Plan
*Manitoba — Packaging & Printed Paper Stewardship Regulation
New Brunswick — Stewardship Plan for Packaging & Paper
Nova Scotia — EPR for Packaging, Paper Products, & Packaging-Like Products
Ontario — Resource Recovery & Circular Economy Act
Québec — Éco Entreprises Québec (ÉEQ)
*Saskatchewan — Multi-Material Stewardship Western
Yukon — Extended Producer Responsibility Regulation

The remainder of this blog will provide an overview of the EPR for packaging programs in the nine provinces listed above.

Alberta — Extended Producer Responsibility Regulations

Alberta's EPR Regulation was implemented on November 30, 2022 and includes two distinct EPR programs: one for single-use products, packaging, and printed paper products (PPP), and another for hazardous and special products (HSP). In this blog, we will examine the specific requirements and timeline related to the PPP program.

The program is expected to be fully operational by April 2025 and aims to achieve the following goals:

Develop local recycling markets and infrastructure

Enhance the cost-effectiveness and efficiency of recycling programs
Enable the province to showcase its commitment to environmental responsibility

The PPP EPR program is specifically designed to address residential and household waste, excluding industrial and institutional waste. It encompasses the following materials:

Paper products (such as newspapers, packaging, corrugated fiberboard, and printed paper)
Plastic products and packaging (both rigid and flexible)
Metal and glass products, along with packaging materials

The Alberta Recycling Management Authority (ARMA) currently oversees the program, drawing on over 30 years of experience managing recycling initiatives across various industries in Alberta. The most recent milestone for the PPP EPR system was the April 1, 2024 deadline for designated producers to submit their collection and management plans to ARMA. Both the PPP and HSP programs are scheduled to launch on April 1, 2025.

The full timeline includes:

October 3, 2022: Alberta’s EPR program introduced through an Order in Council
November 30, 2022: Alberta’s EPR Regulation came into effect
Spring 2023: Development of Bylaws & EPR Agreement on Administration & Oversight
Fall 2023: Bylaws finalized and launch of community and producer registration process
April 1, 2024: Deadline for PPP producers to “provide verification of collection and management plans to the ARMA”
APRIL 1, 2025: EPR System for PPP (and HSP) will be in operation for all registered communities who had “existing services as of Nov. 30, 2022”—with plans of expanding to other communities by October 1, 2026.

British Columbia — Packaging and Paper Product EPR Plan

British Columbia’s EPR program for packaging and paper products was established in 2014, making it the first of its kind in Canada, and one of the first in North America. The program was updated in 2019 to introduce new requirements for paper and packaging products (PPP), which included expanding collection efforts, reducing contamination rates, and creating standardized measurement and reporting protocols.

RecycleBC, a non-profit organization, manages British Columbia’s packaging EPR legislation as the province's producer responsibility organization (PRO). As noted by CircularMaterials.CA, the EPR program in British Columbia collects more than 200,000 tons of packaging and paper products annually from households across the province—resulting in a recovery rate of 79.6%.

The packaging covered by British Columbia’s EPR program includes:

Primary packaging systems (point of sale)
Grouped or secondary packaging (delivered to households)
Tertiary or distribution packaging (received by households)
Service packaging (such as pizza boxes and plastic carry-out bags)
Packaging components and ancillary elements

It is essential to understand that, according to RecycleBC, “paper packaging” encompasses all materials derived from a “cellulosic fiber source.” This includes, but is not limited to, biomaterials such as bamboo and hemp.

British Columbia Fee Structure

Since British Columbia was an early adopter of EPR for packaging, the program is fully operational and has a robust methodology for calculating fees for each designated packaging and paper product material that falls under the program. Producers pay a fee per kg of PPP material sold to British Columbia residents.

Let’s explore some of the 2025 fee rates:

Corrugated Cardboard: $0.56 cents/kg
PET Bottles: $1.02 cents/kg
Expanded Polystyrene (EPS): $3.24 cents/kg
Aluminum Food & Other Containers: $0.61 cents/kg
Clear Glass: $0.50 cents/kg

Aside from cents/kg fees based on material, RecycleBC also offers the option for flat fee payments for small- to medium-sized businesses, paying a flat fee based on the amount of PPP supplied each year to British Columbia households and residences. This is reserved for identified producers who sell 15,000 kg of material or less per year in British Columbia.

The 2025 flat fees include:

For total supplied (kg) of 1,000–2,499: $1,300
For total supplied (kg) of 2,500–5,000: $3,100
For total supplied (kg) 5,000–10,000: $7,300
For total supplied (kg) 10,000–15,000: $12,400

The fees for British Columbia’s EPR program changes annually, in some cases with 20% increases, so it is important to stay up to date with projected changes and new rates.

Manitoba — Packaging and Printed Paper Stewardship Regulation*

Manitoba launched its EPR program for packaging in 2009, though it doesn’t qualify as a “full EPR program” since designated producers fund only 80% of recycling for packaging and printed paper in the province. The program is managed by Multi-Material Stewardship Manitoba (MMSM), which proposed a draft for a full EPR system in November 2021.

Under the current MMSM plan, covered materials include printed paper (like newspapers and magazines), paper packaging, plastic packaging, steel and other metal packaging, aluminum packaging, and glass packaging. Additionally, the program applies only to producers with an annual gross revenue exceeding $750,000 CAD.

The latest draft of the transition plan to full EPR, released in June 2022, can be found here.

Manitoba MSSM Fee Structure

As highlighted in the section above, Manitoba’s EPR program was created in 2009, meaning the program has been collecting fees from producers for years, although identified producers are only responsible for funding 80% of recycling and EOL activities. Similar to British Columbia’s EPR program, MSSM calculates new fees every year using a “Four-Step Fee Methodology” and a “Material Cost Index.” Let's explore some of the 2024 fees (cents/kg).

2024 Fee Rates include:

Corrugated Cardboard: $0.20 cents/kg
PET Bottles: $0.31 cents/kg
Polystyrene: $1.21 cents/kg
Aluminum Food & Beverage Cans: $0.0026
Clear Glass: $0.20 cents/kg

See the full fee rates by material here.

If you are wondering why Aluminum Food & Beverage cans are remarkably low compared to other materials, MSSM stated, “Fee rates for HDPE Containers and Bottles and Aluminum Food & Beverage Cans decrease significantly more than the average due to increased commodity revenues.” In other words, since aluminum (and HDPE) is in higher demand and worth more in recycling markets, the resale value covers part of the EPR program expenses, allowing for a lower cents/kg rate—others do not generate as much revenue when recycled so they have higher fees to help fund the EPR program and collection and infrastructure for those materials.

As you can see, the fees for Manitoba’s EPR program are much lower than that of British Columbia, and for the same materials. This can be for a number of reasons, including the fact that Manitoba’s program currently only requires producers to fund 80% of EPR efforts. Other reasons include material demand, commodity prices, logistics / geography, scope of the program, and more.

Despite only requiring that producers fund 80% of the EPR program and recycling efforts, Manitoba has an impressive recycling rate of packaging and printed paper which was 80.3% in 2020 (increasing 26% since the MMSM program was live in 2010).

New Brunswick — Stewardship Plan for Paper & Packaging

In May 2023, New Brunswick amended its 2008 Clean Environment Act to introduce an EPR program for packaging, formally known as the New Brunswick Stewardship Plan for Packaging and Paper. Circular Materials, via Circular Materials Atlantic, serves as the sole PRO for this initiative.

New Brunswick’s EPR program defines designated materials in two primary categories: 4.1 Paper and 4.2 Packaging and Packaging-Like Products. The Packaging and Packaging-Like Products category includes various types and levels of packaging, from primary to transport packaging. Covered materials range from paperboard and corrugated cardboard to PET bottles, jars, and jugs, as well as a variety of polymers, aluminum, glass, and more.

The full rollout of New Brunswick's EPR system is anticipated to conclude by 2027. Phase 1, which involves contracts between Circular Materials Atlantic and “Group 1” of the Regional Service Commissions (RSC), is set to complete by May 1, 2024. Between 2024 and 2027, the program aims to expand recycling and collection services in schools and public spaces for the designated materials.

The remaining transition timeline, provided by Circular Materials, includes:

November 1, 2024: Remaining residential programs transition to EPR
2024–2025: Expansion of services, multi-family, and school collection to be completed
2027: Roll out of public space collection

New Brunswick’s EPR program, like many others around the world, includes a number of exemptions, including:

Producers who generate less than $2 million CAD in gross revenue in New Brunswick annually
Producers who enter less than one tonne of packaging and paper each year in New Brunswick
A producer who is a “charitable organization” under the Income Tax Act (Canada)

New Brunswick Fee Structure

Similar to Manitoba and British Columbia, New Brunswick’s EPR program has a fee structure for producers based on the kilograms of different packaging materials entered onto the New Brunswick market measured in cents/kg.

The 2024 Fees include:

Corrugated Cardboard: $0.39 cents/kg
PET Containers, Jars, and Jugs <5 liters: $0.73 cents/kg
Expanded Polystyrene (EPS): $2.25 cents/kg
PLA, PHA, PHB—Plastic Film: $1.02 cents/kg
Aluminum Containers: $0.64 cents/kg
Clear Glass: $0.41 cents/kg

See the full fee rates by material type here.

According to Circular Materials, the fee rates represent “the net system costs to collect, transfer, process, and market our producers’ material in New Brunswick’s recycling system.” This might help explain why PLA, PHA, and PHB—common industrial compostable bioplastics—have fees of $1.02 cents/kg while PET containers have a fee of $0.73 cents/kg. Although many consumers and some life cycle assessments claim that bioplastics are more sustainable that conventional PET and other plastics, in New Brunswick and other regions, the infrastructure to collect, process, and market these materials is not as established as those for PET, resulting in higher per kg rates.

Nova Scotia — EPR for Packaging, Paper Products, & Packaging-Like Products

Nova Scotia introduced its EPR program for packaging and paper products on August 1, 2023. The new regulations are under Section 102 of the Environment Act, first enacted in 1995 and amended multiple times since.

Materials that are considered “Designated Materials” include paper, rigid and flexible plastics, glass and metal, and more. Each of these materials have targets for recovery and recycling, provided by Circular Materials. These rates include:

Paper:

2026/2027: Best efforts to meet 80%
2028/2029: 80%
2030: 90%
2035 onward: 95%

Rigid Plastic:

2026/2027: Best efforts to meet 60%
2028/2029: 60%
2030: 65%
2035 onward: 70% + 5% every 5 years until reaching 85%

Flexible Plastic:

2026/2027: Best efforts to meet 30%
2028/2029: 30%
2030: 40%
2035 onward: 50% + 5% every 5 years until reach 85%

Glass:

2026/2027: Best efforts to meet 75%
2028/2029: 75%
2030: 80%
2035 onward: 90%

Metal:

2026/2027: Best efforts to meet 70%
2028/2029: 70%
2030: 80%
2035 onward: 85%

The complete implementation of the EPR program is planned for December 1, 2025. Until then, producers are required to meet additional reporting obligations. By September 1, 2024 they must submit a 2024 report containing 2023 data via the WeRecycle portal. Additionally, data from 2023 on paper and packaging products must be provided to Divert NS, Nova Scotia’s designated PRO, by October 1, 2024.

Similar to New Brunswick’s EPR program, Nova Scotia’s includes a number of exemptions, including:

Smaller producers with “gross annual revenue of less than $1 million CAD annually or that supplies more than 1 tonne of designated material a year.”
A society, incorporated under the Societies Act, “except for a society incorporated for education purposes such as a university or college within Nova Scotia.”

Ontario — Resource Recovery & Circular Economy Act

Ontario’s EPR program for packaging and packaging-related products began in 2016 with these items categorized as “Blue Box” materials. The Blue Box designation includes a range of materials, such as beverage containers, glass, flexible and rigid plastics, metal, paper, and certified compostable packaging.

Circular Materials serves as the PRO for Ontario’s EPR program and is also responsible for setting up a “common collection system” for other PROs that will operate in the province. The program’s full implementation is planned for January 1, 2026 with several key deadlines leading up to it.

By May 15, 2024, producers choosing Circular Materials to report on their behalf to the Resource Productivity & Recovery Authority (RPRA) must submit a 2024 report with 2023 data to the WeRecycle Portal. Producers opting to report directly to the RPRA have until May 31, 2024 to meet this requirement.

The remaining transition timeline includes:

December 31, 2025: Transition to new Blue Box Regulation complete
January 1, 2026: Transition to full extended producer responsibility for blue box materials

You can see the full transition timeline, broken down by town, nation, and reserve here.

Ontario Fee Structure

Since the regulation has been in effect since 2016, fees for the Blue Box materials are already available, managed by the RPRA. The breakdown is not as robust as other programs, but here are the basics:

Producers who enter 50,000 kg or less of Blue Box material into Ontario pay a $90 flat fee to RPRA
Producers who supply over 50,000 kg of Blue Box material into Ontario pay $0.0062 per kg

You can read more about Ontario’s EPR fees for packaging materials here.

Québec—Éco Entreprises Québec (ÉEQ)

Québec launched its EPR program for packaging and paper products in 2022, overseen by Éco Entreprises Québec (ÉEQ), the province’s designated PRO. Established in 2005, ÉEQ was appointed as the official PRO to manage recycling efforts across Québec, supporting sustainable design and encouraging innovation in packaging.

ÉEQ highlights the Designated Materials in the EPR program under their Materials Guide, including:

Containers and packaging made of flexible and rigid materials like paper, cardboard, glass,
and metal
Packaging designed to contain, protect, or wrap products or other packaging
Packaging used for “single use of a short service life”
Printed matter, paper, and other cellulose-based fibers
Short-life containers and packaging, “sold as products and printed matter sold as products”

ÉEQ represents eligible producers, helping establish structure fees and manage funding to expand curbside recycling. The organization has developed four main principles for “eco-design” in packaging: responsible procurement, optimized design, end-of-life management, and communication.

From the legislation itself:

“The purpose of this Regulation is to require persons who commercialize, market or otherwise distribute products in containers or packaging or commercialize, market or otherwise distribute containers, packaging and printed matter to develop, implement and contribute financially to a system to selective collection of residual materials generated to allow them to be recovered and reclaimed.”

According to Berlin Packaging, Québec’s EPR program has “covered all of the costs of curbside collection and recycling, with municipalities remaining in charge of the operations.”

ÉEQ expands upon the impact of the EPR program, highlighting the following:

In 2013, the EPR program recovered more than 700,000 tonnes of material from municipalities
99% of the Québec population is served by curbside recycling systems / services
Since 2005, producers have contributed nearly $1 billion CAD to finance Québec’s curbside recycling system

Saskatchewan — Multi-Material Stewardship Western*

In 2016, Saskatchewan introduced its EPR program for packaging and paper through the Multi-Material Stewardship Western (MMSW). Currently, this initiative mandates that identified producers of packaging and paper materials contribute to 75% of the province's recycling efforts, similar to Manitoba requiring 80% funding.

The MMSW serves as the primary PRO in Saskatchewan and collaborates with Circular Materials to enhance the program, aiming for a more integrated national recycling approach. This organization assists producers in adhering to the Household Packaging and Paper Stewardship Program Regulations, which took effect in March 2023.

The legislation mentions that covered materials include "Household packaging and paper products."

The remaining transition timeline includes the following:

December 1, 2024: Phase 1 of EPR implementation begins
December 1, 2025: Phase 2 of EPR implementation begins
December 1, 2026: Phase 3 of EPR implementation begins

In order for smooth implementation, Circular Materials highlights that MMSW has “formed partnerships with over 500 municipalities, regional waste authorities, and First Nations communities.” Similar to Manitoba, Saskatchewan and MMSW are actively working to transition their provinces into a full EPR program where producers pay for 100% of recycling services and infrastructure.

Yukon — Extended Producer Responsibility Regulation

Yukon’s EPR program for packaging and paper products is the latest initiative in Canada, set to come into effect on January 25, 2024. The complete shift to extended producer responsibility is planned for October 1, 2025.

The materials covered by Yukon’s EPR program consist of:

Primary, convenience, and transport packaging
Flyers, booklets, newspapers, and various other paper products
Single-use items such as straws, plates, and bags

The regulations specify the requirements for entities wishing to act as a PRO. This includes submitting a comprehensive plan that outlines the types of designated materials collected, collection and recycling targets, and strategies for engaging with stakeholders and the wider public.

Certain small producers are exempt from Yukon’s EPR program if they meet one of the following criteria:

They are a registered charity
Their gross revenue in Yukon for the most recent fiscal year is less than $1 million CAD
They imported or supplied less than one ton of designated materials into Yukon in the most recent fiscal year

Upcoming deadlines prior to the program’s launch in October 2025 include the submission of the stewardship plan, which is due by September 24, 2024, and producer data for 2024, which must be submitted by May 31, 2025.