Eight provinces now bill packaging producers, and no two set the fee on the same base

Eight provinces, eight rulebooks

Every Canadian packaging EPR program answers the same four questions differently: when producers took over, who runs the system for them, what the fee is charged on, and which businesses are too small to count. Exhibit 2 sets out the answers for each province, from each regulator’s or producer body’s own pages.

The obligated producer is similar everywhere: the brand holder resident in Canada or the province first, then an importer, then the retailer, with marketplace facilitators and franchisors caught in their own cases in Ontario, Saskatchewan and Québec (RPRA; SK Recycles; PR-CA-006). British Columbia is the exception that matters most for cross-border sellers. Recycle BC applies a residence test, so a non-resident company shipping straight to B.C. homes is not obligated, and the first importer, often the retailer, reports and pays instead (SPI fee-market note for British Columbia, from Recycle BC’s producer FAQs).

Start dates mean different things. In Nova Scotia, section 5 of N.S. Reg. 139/2023 sets 1 December 2025 as the implementation date, after which a producer must establish and operate a collection system; registration had been due by 1 January 2024. In Saskatchewan, the 2024 plan approved by the province’s environment ministry in May 2024 moves producers from paying up to 75% of costs to running the whole system, in three phases that SK Recycles expects to finish by February 2028. In Manitoba, Recycle Manitoba says its full EPR plan is still under provincial review, with a draft revised on 26 August 2025.

Two Atlantic provinces remain outside the map. Newfoundland and Labrador’s Multi-Materials Stewardship Board lists What We Heard reports from June 2022 and March 2023 on an EPR approach to packaging and paper, but its program list covers beverage containers, tires, paint, electronics, and oil and glycol only. SPI has not yet confirmed a packaging and paper EPR regulation or start date in either Newfoundland and Labrador or Prince Edward Island.

Who counts as small

For many mid-sized brands the first question is not the fee but whether they are in at all. Exhibit 3 compares the published revenue thresholds, which are a like-for-like measure: each is gross annual revenue in the province, in Canadian dollars.

The tonnage tests are closer to each other. British Columbia, Saskatchewan, Nova Scotia, New Brunswick and Québec all exempt producers supplying under one tonne a year (B.C. Reg. 449/2004 section 3(2); SK Recycles; N.S. Reg. 139/2023 section 2; Circular Materials New Brunswick plan, page 4; ÉEQ). Ontario works differently: above the CAD 2,000,000 revenue line every producer registers and reports, but collection and recovery duties apply only once supply in a category passes 9,000 kg for paper, 2,000 kg for rigid or flexible plastic, or 1,000 kg for glass, metal or beverage containers (RPRA producers page).

An exemption rarely ends all paperwork. Nova Scotia’s small producers must still keep records under section 32, Ontario’s exempt producers keep records for five years in a form accessible in Ontario, and Alberta’s exempt producers keep financial records that ARMA may audit (N.S. Reg. 139/2023; RPRA; ARMA).

Four models of producer responsibility

Exhibit 4 is SPI’s organising device for this piece. It sorts the provinces on two questions: who carries the cost (all of it, or a share with municipalities) and how producers deliver the service (through one body that sets a public fee table, or through individual obligations that producers meet by contracting a PRO).

Model A, single body. Five provinces fit here, and all publish a fee that a producer can price in advance. Recycle BC’s Four-Step Fee Methodology allocates each material its share of cost, credits commodity revenue only to the material that earned it, and loads extra cost onto uncollectable or underperforming categories (SPI fee-market note, from the 2025 approved plan). ÉEQ publishes per-tonne rates with an ecodesign bonus and maluses, including a 75% malus for PVC and 50% for PLA and other degradable plastics (ÉEQ fee schedule page).

Model B, individual targets. Ontario is the only province where the regulation sets a management requirement for each producer: prior-year supply in a category multiplied by a recovery percentage (PR-CA-003). The September 2025 amendments made 2026 and 2027 effort-based years in which the required amounts do not bind, let energy from waste count for up to 15% of each requirement, and removed away-from-home beverage containers from producer responsibility (RPRA, 18 December 2025, via PR-CA-003).

Model C, shared cost. Saskatchewan’s producers fund up to 75% of the shared program, and Manitoba’s up to 80% (SK Recycles regulation page; Circular Materials Manitoba page). Both already charge per material in cents per kilogram, so a producer’s bill can be priced today, but the base will change once each province completes its transition.

Model D. Two provinces have no confirmed packaging EPR program. For a national brand that is a reporting gap rather than a saving to bank, because consultations have run in Newfoundland and Labrador since 2022.

What each program says it costs

Exhibit 5 sets out what each producer body publishes about its total cost. The rows are not ranked and should not be compared. Circular Materials, which runs or supports most of these programs, says fees between programs are not directly comparable given differences in regulatory requirements, program scope, funding responsibilities, system costs, recovery performance and material definitions (2025 Report to Producers, pages 5 and 8).

Inside each row, the year-on-year change tells a producer more than the level. Manitoba’s 6.8% rise reflects a larger budget spread over fewer supplied tonnes (Circular Materials, page 58). Alberta’s 1% reflects supply chain costs from the phased transition of communities (page 37), and New Brunswick drew down CAD 0.6 million of reserves to soften its 2026 fees (same report).

The 2027 rates are already set for most of these programs. Circular Materials presented 2027 budgets and fees at its Annual Producer Meeting on 15 October 2026 and posted cause-of-change fee schedules for Nova Scotia, New Brunswick, Manitoba, Saskatchewan, Alberta, Recycle BC and Yukon, while Ontario’s 2027 fees went to producers through a separate advisory group and the WeRecycle Portal (Circular Materials fee consultation page). SPI has not yet confirmed the 2027 rate lines in those schedules, so this piece prices 2026.

British Columbia: the fee schedule in full

British Columbia has run a full producer-funded residential program since 2014 and publishes every line in cents per kilogram. Exhibit 6 shows all 23 material lines in Recycle BC’s 2026 schedule beside the 2025 rate, shown per tonne.

Recycle BC puts the average 2026 increase at 17.6%, with a drawdown of reserves softening a larger rise in the fee budget, and attributes the large moves in film and plastic laminates to its Step 4 investments (2026 Fee Schedule). Its 2025 accounts show why the reserve mattered: fee revenue of CAD 168,972,983 and interest of CAD 3,203,304 against expenses of CAD 184,912,592, a deficit of CAD 12,736,305, after a CAD 11,265,917 surplus in 2024 (Recycle BC 2025 Annual Report, statement of operations).

Two 2026 splits change bills more than the average suggests. Kraft paper left corrugated cardboard and now pays CAD 0.77 per kg against CAD 0.60, and PET thermoforms left PET bottles and pay CAD 1.34 per kg against CAD 0.97. A producer whose clamshells were reported as bottles in 2025 sees a 36.7% rise on that line, twice the program average.

Exhibit 7 sets these rates in context with ratios inside each scheme. Ratios cancel the base, so they show how each province prices one material against another without comparing what each province charges.

An SPI basket priced in British Columbia

SPI uses the same 100-tonne household basket as its EPR fees per tonne piece, priced here on Recycle BC’s full 2026 table in Canadian dollars only (Exhibit 8). The earlier piece priced 96 tonnes because SPI’s calculator lacked an aluminium row and used the steel aerosol line; this edition uses Recycle BC’s aluminium food and other containers line (CAD 0.48 per kg) and its other steel packaging line (CAD 0.68), so all 100 tonnes are priced.

SPI calculation: 45 x 600 + 25 x 580 + 8 x 970 + 6 x 470 + 6 x 1,840 + 4 x 480 + 6 x 680 = CAD 69,120, or CAD 691.20 per tonne. At 2025 rates the same basket is CAD 60,930, so the bill rises CAD 8,190, or 13.4%, below Recycle BC’s 17.6% average because the basket holds PET bottles and aluminium food containers, the only two lines in the schedule that fell. Plastic is 20 tonnes and CAD 21,620, or 31.3% of the bill.

Film is the line to watch. The 6 tonnes of film cost CAD 11,040, or 76% of what the 25 tonnes of glass cost (CAD 14,500), and they account for CAD 2,280 of the CAD 8,190 increase. Corrugated cardboard, at 45% of the weight, adds CAD 3,150 because a 7-cent rise applies to so many kilograms.

SPI’s fee-market data includes a second example, built around a real format change (Exhibit 9). A B.C.-resident grower-packer sells berries in PET clamshells, salad greens in film bags and both in printed boxboard sleeves.

SPI calculation: 61 tonnes cost CAD 74,600 in 2026 against CAD 56,060 in 2025, a rise of 33.1%, and the clamshells carry 71.9% of the 2026 bill. At 61,000 kg this producer is far above the 15,000 kg ceiling for flat-rate reporting, so it files a full weight report by 31 May and pays quarterly on 31 January, 30 April, 31 July and 31 October (Recycle BC fee schedule page).

Small producers: flat fee or per kilogram

Recycle BC lets producers supplying 1,000 to 5,000 kg report as low-volume producers for a fixed fee, and offers a flat-rate option from 5,000 to 15,000 kg (SPI fee-market note). Its fee page shows flat fees for 2024 and 2025 only, so SPI tests the option at 2025 rates (Exhibit 10).

The flat fees rose 5% to 8% between 2024 and 2025, from CAD 1,200 to CAD 1,300 in the lowest band and from CAD 11,200 to CAD 11,800 in the highest (Recycle BC fee schedule page). Québec’s equivalent bands rose too: ÉEQ’s 2026 flat fees run from CAD 1,430 for more than 1 tonne and less than 2.5 tonnes to CAD 10,240 for 10 to 15 tonnes, and the 2027 fees from CAD 1,580 to CAD 11,270, an increase ÉEQ limits to about 10% (ÉEQ fee schedule page; 2027 PFP summary). SK Recycles listed CAD 840 and CAD 1,760 for its two low-volume bands in 2024 and has not posted later amounts on its page.

Scenarios: the 2027 British Columbia bill

Recycle BC’s 2027 schedule was among those Circular Materials posted for its 15 October 2026 meeting, but SPI has not yet confirmed its rate lines. Exhibit 11 therefore brackets the 2027 basket with stated assumptions, in Canadian dollars only.

SPI calculation: in the mid case, film would reach CAD 2,318.90 per tonne and glass CAD 700.83, while aluminium would fall to CAD 390.51 and PET bottles to CAD 960.10. The mid case is lower than the high case because two of the basket’s seven lines fell in 2026 and would fall again if the pattern repeated.

Three forces will decide where the real 2027 schedule lands. The approved plan commits Recycle BC to a community onboarding strategy by 31 December 2026, an Indigenous Advisory Committee in 2026 and service to at least five First Nations a year, all of which add collection cost (PR-CA-004). The reserve drawdown that softened 2026 cannot repeat indefinitely after a CAD 12.7 million deficit in 2025. And its main post-collection contract, held by GFL Environmental since 2020, concluded in May 2026 as Recycle BC moves to an in-house model for receiving, sorting and logistics, according to the 2025 Annual Report.

Québec: one body, a smaller total and higher rates

Québec moved its curbside system onto producers on 1 January 2025, with ÉEQ as the single designated management body. RECYC-QUÉBEC selected ÉEQ on 24 October 2022, and the February 2025 amendments extended designations from five to ten years (Ministère de l’Environnement du Québec). ÉEQ’s producer financial participation (PFP) is published in dollars per tonne, by material (Exhibit 12).

ÉEQ explains the paradox in its 2027 summary. The amount to be financed falls from CAD 483.4 million to CAD 468.3 million, but reported tonnes fall 18.4%, about 14 points of it because the deposit-refund expansion from 1 March 2027 moves many beverage containers out of curbside. Higher fuel prices push up collection, transport and sorting, and resale revenue is now averaged over five years instead of three. ÉEQ caps increases at 20% for targeted materials and about 10% for flat fees.

The regulation itself is moving. A government mémoire to the Conseil des ministres dated 12 June 2026 proposed pushing service to the remaining residential sector, mainly large multi-unit buildings and remote territories, from 1 January 2025 to 1 April 2030; non-university post-secondary institutions to 1 April 2029; the outdoor public spaces plan from 24 October 2025 to 1 April 2031; and the 14 northern villages in stages to 1 April 2036. It put the saving to businesses at about CAD 15.7 million a year and referred to one-off support of CAD 27 million to ÉEQ, announced in March 2026, to ease pressure on smaller firms. The ministry confirms that amendments introduced in June 2026 allow more time for certain components.

The mémoire also announces lower and postponed performance rates without giving the values. The ministry page still lists 2027 recovery rates such as 85% for cardboard, 80% for rigid PET, 70% for glass and 50% for flexible plastics, so SPI has not yet confirmed which 2027 rates now apply.

Ontario: targets instead of a public fee table

Ontario is the largest market and the least transparent on price. RPRA names Circular Materials as the operator of the Blue Box collection system for producers, and Circular Materials shares Ontario fees through its WeRecycle Portal and a producer advisory group rather than a public schedule (RPRA, 5 January 2026; Circular Materials fee consultation page). What is public is the obligation (Exhibit 13) and the regulator’s own fee.

Producers report supply in seven categories, including certified compostable products and packaging, by 31 May each year, together with performance reports and RPRA’s program fee (RPRA producers page). The first three-yearly audit is due in 2027 and covers 2024, 2025 and 2026 performance data.

RPRA’s fee is small but rising. For 2026 it charges CAD 95 flat to producers supplying 50,000 kg or less and CAD 0.0097 per kg above that, after a 30.0% increase that was cut from a proposed 41% (RPRA, 1 December 2025). For 2027 it proposes CAD 0.0109 per kg, up 12.4%, on a revenue requirement of CAD 9,549,539 and about 867 million kg of supply, with the flat fee unchanged; its forecast adds 8% in 2028 and 7% in 2029 (RPRA, 21 July 2026). SPI calculation: a producer supplying 1,000 tonnes would pay RPRA CAD 9,700 in 2026 and CAD 10,900 in 2027 at the proposed rate, before any PRO fee.

Enforcement is real. RPRA’s first Blue Box administrative penalty order, on 28 June 2024, totalled CAD 340,457.04 for two 2023 contraventions: failing to run a collection system and failing to run a promotion and education program (PR-CA-003).

The federal layer: registry, ban and the Supreme Court

Ottawa does not charge an EPR fee, but two federal measures sit on top of every provincial bill. The Federal Plastics Registry requires producers placing 1,000 kg or more of plastic products or packaging on the Canadian market in a year to report Phase 1 data for 2024, 2025 and 2026; reporting for Phases 2 and 3 has been postponed, and a notice of intent of 14 March 2026 announced a new notice for 2027 to 2029 data (ECCC registry page; PR-CA-002). Reports on 2026 data fall due on 29 September 2027 under the 2024 notice.

The Single-use Plastics Prohibition Regulations bar six items: checkout bags, cutlery, certain foodservice ware, ring carriers, stir sticks and straws (PR-CA-001). On 15 October 2026 the Supreme Court of Canada granted leave to appeal in docket 42277, with costs in the cause, against the Federal Court of Appeal’s January 2026 ruling that upheld the toxic listing behind the ban (Supreme Court docket, modified 16 October 2026). SPI News covers the case in Canada’s Supreme Court will hear the plastics toxic listing appeal. The regulations remain in force while the appeal runs.