Guide to EPR Regulations: Canada

  • As environmental regulations around packaging and waste management continue to grow globally, Canada has introduced Extended Producer Responsibility (EPR) programs across its provinces. These programs place responsibility on businesses to manage and finance the recycling and disposal of packaging waste. If your business operates in Canada, understanding and complying with EPR regulations is essential for environmental impact and brand reputation.

Understanding Canadian Packaging Regulations: A Guide for Brands and Distributors in 2024

  • Packaging regulations in Canada are essential for protecting public health and encouraging environmental sustainability, including increased recyclability and reduced plastic waste. However, the rapidly evolving regulations can be challenging to navigate. Compliance is particularly crucial for brands and distributors selling across provincial borders, as each province has unique EPR requirements. This guide simplifies the complexities of Canada’s EPR landscape, providing an overview of key requirements and legislation by province.

  • In This Guide

    1. Immediate steps for brands
    2. What is EPR?
    3. Who is the “Producer”?
    4. EPR Legislation in Major Provinces
    5. Key Packaging Laws in Canadian Provinces
    6. Benefits of EPR
    7. Challenges of EPR
    8. Wrapping up

Immediate Steps for Brands

Ontario and British Columbia require companies to register with a PRO to manage the end-of-life treatment of their packaging. The most recognized PROs include Recycle BC and Stewardship Ontario. Registration involves reporting the types and volumes of packaging materials used.

Provincial targets for post-consumer recycled (PCR) content are rising. Incorporating PCR content into packaging helps meet sustainability requirements and enhances brand reputation.

Reducing single-use plastics aligns with Canada’s commitment to sustainability and may prevent future restrictions. This aligns with the federal ban on certain single-use plastics, which include items like plastic straws, cutlery, and bags.

Moving to recyclable or compostable packaging reduces environmental impact and ensures compliance with many provincial mandates, especially in areas like British Columbia and Quebec, where recyclability is a priority.

Review your packaging labels for accuracy regarding recyclability and compostability to avoid confusion and meet Canada’s Truth in Labeling guidelines. Consider third-party verification to support these claims.

Using certifications like FSC, GRS, ABA and BPI on your packaging provides transparency and signals sustainability, helping you meet Canadian consumer expectations for eco-friendly packaging.

What is EPR?

  • Extended Producer Responsibility (EPR) legislation in Canada is designed to shift the responsibility for the end-of-life management of packaging and certain consumer products from municipalities to the producers, manufacturers, and retailers who profit from these items. EPR programs aim to reduce waste, promote recycling, and encourage producers to make more sustainable packaging choices by covering the costs associated with managing the waste generated by their products.
    Canada’s approach to EPR is not federally regulated, so it varies across provinces. Each province has the authority to establish its own EPR requirements, making compliance complex for companies operating in multiple regions. In general, Canadian EPR laws require producers to either fund or directly manage the collection, recycling, and disposal of their packaging materials and other designated products, especially in key sectors like packaging, paper, electronics, and single-use plastics.
  • Under Canadian EPR frameworks, companies typically contribute to a Producer Responsibility Organization (PRO), which manages the collection, recycling, and disposal of materials based on each province’s unique requirements. The fees producers pay to these organizations are often built into the product’s price, and the PROs are responsible for ensuring that provincial recycling targets are met and that materials are processed in an environmentally responsible way.
  • EPR has existed in Canada for years, but its importance has grown as provinces update their waste management strategies to reduce landfill contributions and promote recycling. With major provinces like British Columbia, Ontario, and Quebec leading the way, EPR programs in Canada are moving toward a producer-funded model, aligning with Canada’s commitment to a circular economy.

Who is the "producer"?

In Canada, the definition of a "producer" varies by province, but generally includes companies or organizations that introduce packaging or designated products into the Canadian market. This can mean manufacturing, importing, distributing, or selling products to consumers within provinces that have EPR mandates. Producers are responsible for contributing to the costs of recycling and disposal for their products at end-of-life, often through Producer Responsibility Organizations (PROs).

Certain provinces allow exemptions or reduced obligations based on a company’s size or revenue:

  • Small Businesses: Some provinces exempt small businesses or set lower fees for producers below a certain revenue or production threshold.
  • Low-Volume Producers: For businesses that produce or import a low volume of packaging, certain provinces allow reduced reporting or payment obligations to reduce administrative burdens.

Each province may specify slightly different criteria for what constitutes a producer. For example:

  • British Columbia: Defines producers as any entity that supplies packaging and paper products (PPP) to consumers in the province. This includes first importers if the brand owner is not Canadian, and e-commerce sellers.
  • Ontario: Under the Resource Recovery and Circular Economy Act, Ontario identifies producers as brand owners, importers, and retailers, especially those with private-label goods.
  • Quebec: Defines a producer broadly as anyone who markets products or packaging in the province, including first importers and retailers.

Obligations for producers across Canadian provinces typically include:

  1. Data Reporting: Producers must report the quantity and types of materials they introduce into the market. This data helps determine their financial contributions to PROs.
  2. Fee Payments: Producers are required to pay fees to PROs, based on the type and volume of materials introduced. Fees are often calculated per ton of material, depending on the recyclability and environmental impact of the material.
  3. Consumer Education: In some cases, producers are also responsible for contributing to or participating in public education campaigns around recycling and proper disposal of packaging.
  4. Achieving Recycling Targets: Producers may be required to meet specific recycling targets, which are generally coordinated through PROs. Failure to meet these targets can result in penalties or higher fees.

EPR Legislation in Major Provinces

  • Ontario

    In Ontario, EPR regulations are managed under the Resource Recovery and Circular Economy Act (RRCEA), with Stewardship Ontario playing a key role in administering the province’s Blue Box Program. This program shifts the financial and operational responsibility for the collection, recycling, and disposal of packaging and printed paper from municipalities to producers. As of 2023, Ontario is phasing out municipal control over these recycling programs, moving toward a fully producer-funded system by 2026. Ontario’s regulations include mandatory recycling targets, fees based on packaging type and material, and detailed reporting requirements. Producers are required to register with Ontario’s Resource Productivity and Recovery Authority (RPRA) and report on the weight and types of packaging they introduce into the market. The aim is to drive higher recycling rates for materials like glass, paper, plastics, and metals and ensure producers meet set recycling targets or face penalties.

  • British Columbia

    British Columbia was the first province in Canada to implement full EPR for packaging and printed paper, under a model managed by Recycle BC. BC’s EPR program requires producers to take on financial and physical responsibility for managing the collection and recycling of these materials. Recycle BC collects fees from producers based on the type, recyclability, and volume of packaging materials, which fund the infrastructure for collecting, sorting, and recycling. With a strong emphasis on high recycling rates, Recycle BC focuses on achieving rigorous collection and diversion targets, and the program has reported some of the highest recycling rates for packaging in Canada. In addition to recycling mandates, BC also has specific requirements for public education and awareness around waste reduction. British Columbia's model is fully operational and provides a reference framework for other provinces transitioning to EPR.

  • Quebec

    Quebec’s EPR program is governed by Éco Entreprises Québec (ÉEQ) and operates under the Environment Quality Act. Producers in Quebec are required to fund and manage recycling programs for packaging, printed paper, and certain single-use items. As part of its EPR program, Quebec imposes eco-fees based on the material type, encouraging producers to prioritize recyclable materials in their packaging design. Quebec has increasingly ambitious recycling targets and has also proposed additional legislation to further expand EPR obligations for producers. Recently, Quebec announced plans to establish a fully producer-funded curbside recycling system by 2025, with increasing emphasis on recyclable and reusable packaging options. Producers are responsible for public education on proper recycling practices, with the goal of reducing landfill contributions and promoting a circular economy.

  • Alberta

    Alberta recently passed its first EPR legislation, which represents a significant shift in the province’s waste management approach. Unlike Ontario, British Columbia, and Quebec, Alberta did not previously have an extensive EPR program. However, under the new legislation, Alberta is now implementing EPR requirements that will eventually encompass a broad range of materials, including packaging and single-use items. Alberta’s EPR program is expected to focus on producer responsibility for the end-of-life management of their products, with mandates to increase recycling rates, minimize landfill waste, and reduce reliance on taxpayer-funded waste disposal services. Once fully implemented, Alberta’s EPR regulations will require producers to register with a PRO and contribute fees based on packaging type, weight, and recyclability. Alberta’s EPR model is anticipated to roll out in phases, with packaging regulations expected within the next few years.

  • Manitoba

    Manitoba has had EPR regulations in place since 2010, managed by Multi-Material Stewardship Manitoba (MMSM). This program covers packaging and printed paper and requires producers to contribute to the costs of collection, sorting, and recycling. MMSM collects fees from producers based on the types and volumes of materials used, with specific eco-fees aimed at incentivizing the use of recyclable or compostable packaging. While Manitoba’s EPR program is not as comprehensive as those in Ontario, BC, or Quebec, it includes established recycling targets and reporting requirements for producers. The province is considering updates to expand its EPR model and increase recycling rates further.

  • Saskatchewan

    Saskatchewan’s EPR program, managed by Multi-Material Stewardship Western (MMSW), applies to packaging and printed paper, requiring producers to finance the collection, recycling, and disposal of these materials. MMSW operates similarly to Manitoba’s EPR program, where producers are charged fees based on packaging type and volume. Saskatchewan’s program is currently limited to residential packaging and does not cover all materials that may be regulated in other provinces. However, the program is expected to expand to include more types of packaging and potentially commercial waste as well, aiming to increase recycling rates and reduce landfill usage.

  • Nova Scotia and Prince Edward Island

    Nova Scotia and Prince Edward Island have more limited EPR programs primarily focused on beverage containers, electronics, and hazardous waste. Both provinces have shown interest in expanding EPR to packaging and printed paper, but as of now, their regulations are narrower in scope compared to provinces like Ontario and British Columbia. These provinces require producers to contribute to disposal costs and achieve specific recycling targets for the materials covered under their existing EPR frameworks.

  • Newfoundland and Labrador

    Newfoundland and Labrador implemented EPR for beverage containers, paint, and some electronic waste, though the regulations for packaging are currently limited. The province is exploring options to expand its EPR program, and future legislation may include broader packaging requirements. The current program is primarily funded by eco-fees paid by producers, with future plans potentially extending to printed paper and other packaging materials.

  • New Brunswick

    New Brunswick has implemented limited EPR programs covering electronics, paint, and beverage containers, but it currently lacks a comprehensive EPR program for packaging. However, the province has shown interest in expanding its EPR regulations, with proposed legislation that may include packaging and printed paper in the future.

Key Packaging Laws in Canadian Provinces

  • Canada’s approach to reducing packaging waste involves a combination of eco-fees and deposit systems, bans on certain materials, and producer responsibility fees. Each of these regulatory strategies plays a unique role in incentivizing sustainable packaging and waste reduction across the provinces. Eco-fees and deposit systems require producers and, in some cases, consumers to contribute financially to recycling and waste management, either through direct fees or refundable deposits on items like beverage containers. Bans on single-use plastics and other problematic materials help prevent specific waste streams from entering landfills, while EPR fees require producers to cover the cost of recycling and disposal based on the type and volume of materials they use. Together, these measures form a comprehensive approach to managing packaging waste in Canada, driving businesses toward more eco-friendly practices and supporting a circular economy.

  • Eco-Fees and Deposit Systems

    In Canada, eco-fees are commonly applied as a way to fund recycling programs and encourage sustainable practices without imposing outright bans on materials. These fees vary by province and are typically structured around the material type, with higher fees for products that are difficult to recycle or that require specialized processing. For instance, packaging materials like polystyrene or multi-layer plastics often incur higher fees, while recyclable materials such as glass or paper have lower associated fees. Additionally, most provinces apply beverage container deposit systems, where consumers pay a deposit when purchasing drinks in cans, bottles, or cartons, and can reclaim this deposit upon returning the container. Provinces like British Columbia, Alberta, and Manitoba have well-established deposit systems, with deposits ranging from 5 to 20 cents per container.

  • Single-Use Plastic Bans


    Several Canadian provinces have implemented restrictions on single-use plastics in alignment with the federal government’s goal to reduce plastic waste. Federally, the Single-Use Plastics Prohibition Regulations ban items like plastic checkout bags, stir sticks, six-pack rings, cutlery, and certain plastic straws. Provincial and municipal bans often extend these rules, with some areas enacting additional restrictions or faster implementation schedules.

Benefits of EPR

Eco-Modulation

Eco-modulation in Canada’s EPR framework uses financial incentives to encourage producers to adopt more sustainable packaging materials. Under eco-modulation, producers pay fees based on the environmental impact of their packaging choices—higher fees for non-recyclable or difficult-to-recycle materials and lower fees for eco-friendly options, such as packaging with high post-consumer recycled (PCR) content. For instance, producers using hard-to-recycle materials, like black plastics or certain multi-layered packaging, might face higher eco-fees, while those incorporating recyclable or compostable materials could benefit from reduced costs. This approach not only helps balance the financial gap between traditional and sustainable materials but also directly supports the development of a circular economy. By incentivizing eco-friendly choices, eco-modulation encourages businesses to make responsible decisions that reduce overall waste and resource consumption.

Provincial Consistency

One of the major challenges in Canada’s recycling system has been the inconsistency in accepted recyclable materials across municipalities, leading to confusion and reduced recycling rates. EPR legislation aims to address this by establishing standardized, province-wide lists of recyclable materials and creating consistent guidelines for waste sorting and disposal. This approach ensures that residents across a province follow the same recycling rules, simplifying the process and enhancing public trust in the recycling system. Additionally, EPR programs provide funding to Material Recovery Facilities (MRFs), enabling them to invest in equipment and staff needed to handle a more uniform recycling stream. By streamlining the materials collected and sorted, standardized EPR regulations create a more effective and reliable recycling system that encourages greater public participation and reduces contamination in recycling streams.

Most EPR legislation aims to address this issue by establishing a consistent, statewide list of recyclable materials. The idea is that everyone, no matter where they live within the state, will follow the same recycling guidelines. Stewardship organizations would then collaborate with and financially support MRFs to ensure they have the capacity to recycle the materials being collected, creating a more efficient and reliable recycling system overall.

Improved Labeling

Canada’s EPR legislation also seeks to eliminate misleading labeling practices that can confuse consumers and lead to contamination in recycling bins. Packaging materials, such as #5 and #6 plastics or industrially compostable PLA (marked with #7), often feature the chasing arrows symbol, implying recyclability even when local facilities don’t process these materials. Misleading symbols result in items being improperly disposed of, adding contaminants to recycling streams and reducing the efficiency of recycling operations. EPR regulations can set clear standards for labeling, requiring producers to use accurate, transparent labels that reflect a material’s true recyclability. By establishing clear labeling standards and banning ambiguous icons, EPR in Canada helps consumers make informed disposal decisions, reducing waste contamination and promoting a more effective recycling process.

Challenges of EPR

  • Cost Implications for Consumers

    In a competitive market, producers are likely to pass the costs associated with EPR compliance down to consumers. Although EPR aims to hold producers accountable, the costs of eco-fees, reporting, and other compliance requirements may ultimately be reflected in product pricing. While these fees are necessary to build sustainable waste management systems, transparency around cost allocation is crucial to maintaining public trust in EPR programs. At EcoPackables, we support EPR’s goals, as they can increase awareness about the environmental impact of packaging. However, it’s important for advocates and policymakers to communicate clearly that these changes may impact consumer pricing.

  • Carbon Emissions vs. Material Recyclability

    One of the central challenges with EPR policies in Canada is the focus on material recyclability, which may sometimes conflict with carbon reduction goals. For instance, flexible plastic packaging often has a lower carbon footprint than heavier materials like paper or glass but is harder to recycle. EPR policies often incentivize recyclable materials, which could inadvertently discourage packaging options that may have a lower carbon impact. Balancing recyclability with carbon footprint reduction remains a complex issue within EPR programs, and future policies should seek to encourage both recyclable and low-carbon options.
  • However, the paper industry still has a long way to go in terms of sustainability. While a 65% recycling rate is commendable, it also means that 35% of this easily recyclable material ends up in landfills, where it occupies more space and weight than plastic. Additionally, the cost of sourcing virgin paper often remains significantly lower than using recycled content, which undermines efforts to promote a circular economy. Moreover, the logging industry, which frequently harvests trees from ancient and endangered forests, contributes to further environmental degradation.
    The fact that EPR legislation is so heavily focused on recycling, without adequately addressing carbon emissions and the sourcing of virgin materials, represents a significant oversight. Balancing these factors is crucial for creating truly sustainable packaging solutions.

  • Provincial Variability and Compliance Complexity

    EPR programs in Canada are regulated at the provincial level, meaning each province has its own rules and eco-fee structures. For example, British Columbia’s Recycle BC program differs significantly from Ontario’s Blue Box Program, creating challenges for companies that operate nationwide. Brands must navigate different recycling targets, accepted materials, and fee structures, much like managing sales tax variations across jurisdictions. This variability complicates compliance and may require companies to adjust their packaging strategies by region, leading to increased administrative costs and logistical burdens.

  • How does this affect my packaging artwork?

    Canada’s EPR programs are increasingly focusing on reducing greenwashing by establishing clear standards for environmental claims. For example, labeling a package as “compostable” requires proof that it meets specific composting standards, ensuring it breaks down in home or industrial compost facilities as claimed. Similar to U.S. legislation like California’s SB 343, Canadian EPR programs are likely to implement more stringent truth-in-labeling laws in the future, particularly for terms like “biodegradable” and “recyclable.” These standards help prevent misleading claims and ensure that consumers receive accurate information about the end-of-life options for packaging.

  • Recyclability Labeling

    Some Canadian provinces, such as British Columbia and Ontario, are exploring stricter guidelines on recyclability labeling to ensure that only materials widely accepted by recycling facilities can bear the chasing arrows symbol. The chasing arrows symbol has often led consumers to believe that any marked plastic is recyclable, when in reality, only certain types, like polyethylene and PET, are widely recyclable. Future EPR programs in Canada may introduce regulations on recyclability labeling to clarify which materials are truly recyclable, helping consumers make informed disposal decisions and reducing contamination in recycling streams.

Wrapping Up

  • Staying informed about Canada’s EPR regulations and adhering to each province’s requirements is essential for brands seeking a foothold in the Canadian market. From registering with a PRO to auditing packaging for recyclability, brands that prioritize sustainability will not only meet regulatory standards but also resonate more with Canada’s environmentally conscious consumers.
    For more details or to start implementing EPR-compliant packaging solutions, consult with experts who can guide your company through Canada’s evolving regulatory landscape.