Canadian Packaging EPR: A Province-by-Province Guide
Background
Canada's Extended Producer Responsibility (EPR) regulations are not unified, but they all have one goal: shift the operational responsibility for residential recycling from municipalities to the companies that place packaging onto the market.
British Columbia pioneered the first EPR program for packaging and paper was the first in North America, launching in 2014. Every province to adopt EPR since has used the BC program as a model, but each province differs somewhat on the details. Thresholds, PROs, covered materials, and penalties may be different, and not all provinces have shifted from partial cost-sharing to full producer funding.
Who Does Canada EPR Affect?
Companies that supply packaging and paper to Canadian consumers are potentially obligated in every province where those products reach households. Some provinces, like Saskatchewan, include "packaging-like products" in scope, like gift bags, plant pots, or other products that act like packaging.
In general, Canada EPR programs define the "producer" as the brand owner. If there is no Canadian-resident brand owner, the obligation passes to the importer. If there is no importer, obligation passes to the first seller or retailer. However, exact legal hierarchy may differ.
Because obligations are tied to each individual province, a company selling nationally has separate obligations in each of the nine provinces it sells in.
The provinces with EPR programs are: Alberta, British Columbia, Manitoba, New Brunswick, Nova Scotia, Ontario, Quebec, Saskatchewan, and Yukon.
What Products Are Affected?
All Canada EPR programs cover these core materials:
Paper and printed paper
Paperboard and corrugated cardboard
Rigid and flexible plastic
Glass
Metal packaging
There are several notable divergences in individual provinces:
Saskatchewan defines "packaging-like products" broadly, including items such as paper gift bags, resealable plastic bags, and plant pots and trays.
Nova Scotia's regulation explicitly carves out pressurized gas and hazardous products, waste containment products, refillable beer container packaging, and books.
Alberta runs packaging and paper as one program (PPP) and hazardous and special products (HSP) as a separate program with its own PRO and its own thresholds.
Newspapers get a partial carve-out in Ontario if they make up more than 70% of a producer's Blue Box material by weight.
"Packaging" is not a term you can broadly apply. It's critical to check specific SKUs on a per-province basis to account for inconsistencies between provincial definitions.
Province-by-Province EPR Breakdown
| PRO | Recycle BC (packaging and paper) |
| Governing regulation | Recycling Regulation, B.C. Reg. 449/2004, under the Environmental Management Act |
| Revenue/volume threshold | Small producers are exempt if they meet any one of: under $1 million in annual B.C. revenue, under one tonne of packaging and paper supplied, or a single point of retail sale not part of a chain or franchise. |
| Covered products | Packaging and printed paper (PPP); B.C. separately expanded EPR to single-use items and other packaging-like products starting in 2023. |
| Timeline | Live since May 2014. No pending transition; this is the most mature program in Canada. |
| PRO | Circular Materials |
| Governing regulation | Extended Producer Responsibility Regulation (Alta Reg 194/2022) under the Environmental Protection and Enhancement Act, plus ARMA's PPP Bylaws. |
| Revenue/volume threshold | Exempt if annual gross revenue in Alberta is under $1.5 million. Producers above that revenue line but below material-specific supply thresholds (paper: 9 tonnes; rigid plastic: 2 tonnes; flexible plastic: 2 tonnes; metal: 1 tonne; glass: 1 tonne). |
| Covered products | Single-use products, packaging, and printed paper (PPP). |
| Timeline | Regulation took effect November 30, 2022. Phase 1 launched April 1, 2025 for communities with pre-existing recycling service. Phase 2 launches October 1, 2026 for communities that didn't have service as of November 30, 2022. |
| PRO | SK Recycles (formerly Multi-Material Stewardship Western), working with Circular Materials. |
| Governing regulation | The Household Packaging and Paper Stewardship Program Regulations, 2023. |
| Revenue/volume threshold | Exempt if generating less than $1 million in gross annual revenue or annually supplying or distributing less than one tonne of household packaging and paper products to Saskatchewan residents. |
| Covered products | Packaging, paper, and packaging-like products, defined broadly enough to include items like paper gift bags, resealable bags, and plant pots and trays. |
| Timeline | The 2023 regulations replaced a 2016 shared-cost model (producers previously covered up to 75% of costs) with a fully producer-funded model. Saskatchewan also recently moved from a provincial-residency requirement to a national-residency model for determining obligated producers. |
| PRO | Multi-Material Stewardship Manitoba (MMSM). |
| Governing regulation | Packaging and Printed Paper Stewardship Regulation, Manitoba Regulation 195/08. |
| Revenue/volume threshold | Historically referenced at $750,000 in annual revenue, with MMSM's draft program plan reportedly proposing to raise it to $1 million as part of the transition to full EPR. |
| Covered products | Packaging and printed paper only, at this point. Single-use products and packaging-like products are not yet included. |
| Timeline | Manitoba's program dates to 2009 and has historically required producers to fund about 80% of program costs, one of the earlier partial-funding models in Canada. It is transitioning toward full EPR. |
| PRO | Circular Materials Ontario is the primary PRO; Landbell Canada, Ryse Solutions, and EnviroFocus also operate as PROs in the province. |
| Governing regulation | Blue Box, O. Reg. 391/21, under the Resource Recovery and Circular Economy Act, 2016. Regulator: Resource Productivity and Recovery Authority (RPRA). |
| Revenue/volume threshold | Producers with gross annual Ontario revenue under $2,000,000 are fully exempt from registration, reporting, collection, management, and promotion and education obligations. Above that, separate tonnage thresholds by material category determine whether performance obligations apply. |
| Covered products | Blue Box materials: paper, glass, metal, plastic, and combinations, across seven material categories including beverage containers and certified compostable packaging. Newspapers get a partial exemption if they're over 70% of a producer's Blue Box material by weight. |
| Timeline | Full transition to producer funding (100% of program costs) completed December 31, 2025. |
| PRO | Éco Entreprises Québec (ÉEQ), the designated management organization since October 2022. |
| Governing regulation | Environment Quality Act and the Regulation respecting compensation for municipal services provided to recover and reclaim residual materials. |
| Revenue/volume threshold | Exempt if a producer generated $1.3 million or less in revenue in the reference year, or supplied one tonne or less of materials. |
| Covered products | Containers, packaging, and printed matter placed on the Quebec market. |
| Timeline | Quebec is mid-transition from a retroactive municipal compensation model to full EPR, with producers taking on full financial responsibility from 2025 and expansion to multi-unit buildings, businesses, and institutions rolling out gradually through 2031. Retroactive contributions under the old compensation plan wind down through 2026. |
| PRO | Circular Materials, operating as Circular Materials Atlantic. |
| Governing regulation | Designated Materials Regulation, under the Clean Environment Act. Regulator: Recycle NB. |
| Revenue/volume threshold | New Brunswick's framework describes obligated "brand holders/owners" without a threshold figure. |
| Covered products | Paper, and packaging and packaging-like products, ranging from corrugated cardboard to PET bottles and jars to various plastics, aluminum, and glass. |
| Timeline | New Brunswick was the first Atlantic province to transition to EPR. Phase 1 ran November 2023 to May 2024. As of November 1, 2024, the residential program was fully transitioned. A new Stewardship Plan takes effect January 1, 2026, with expansion to multi-unit buildings, schools, and public spaces continuing through 2027. |
| PRO | Circular Materials Atlantic. |
| Governing regulation | EPR for Packaging, Paper Products and Packaging-Like Products Regulations, enacted August 2, 2023. |
| Revenue/volume threshold | Exempt if gross annual revenue under $1 million in the province or who supply less than one tonne of designated packaging and paper products per year. |
| Covered products | Packaging, paper products, and packaging-like products (paper, rigid plastic, flexible plastic, glass, metal). Explicitly excludes pressurized gas and hazardous products, waste-containment products, refillable beer container packaging, and books. |
| Timeline | Regulations came into force December 1, 2025. |
| PRO | Circular Materials. |
| Governing regulation | Yukon's Extended Producer Responsibility Regulations, in effect since January 25, 2024. |
| Revenue/volume threshold | Exempt if gross annual revenue under $1 million in the territory or who supply less than one tonne of designated packaging and paper products per year. |
| Covered products | Packaging, paper, and single-use products. |
| Timeline | Regulations in effect since January 2024; program implementation targeted for late 2025 into 2026. |
Gain EPR Confidence With Snaplinc
The patchwork of EPR laws in Canada makes compliance a complication many businesses can't untangle alone. Snaplinc's experience with Canadian EPR and complex data sets makes us the right EPR partner for any company looking to align with Canadian EPR requirements in any province. Schedule a 30-minute call with one of our experts to get your compliance strategy started.