Canada EPR Update: 2024 Review & 2025 Outlook
Although the year ended with much uncertainty on the North American political landscape, we expect Extended Producer Responsibility (EPR) regulations in Canada to continue to evolve and expand. A growing awareness among Canadians of environmental issues will largely drive this. We expect that it will continue to support the expansion of EPR regulations and the circular economy. For producers, this, in turn, will mean increased customer expectations for environmental compliance and a competitive advantage for those who successfully adapt to EPR regulations and demonstrate sustainable practices.
Below, we’ve gathered some of the highlights from 2024 – as well as a few of the changes we expect in 2025.
Important 2024 Events:
Alberta’s Extended Producer Responsibility Implementation
- On April 1, 2024, the implementation of EPR programs for single-use products, packaging, and printed paper products (PPP), as well as hazardous and special products (HSP), began. This date also marked the deadline for PPP producers to provide verification of collection and management plans to the ARMA.
- Once fully operational in April 2025, the EPR framework will embrace Alberta’s ‘polluter-pay’ principle.
New Brunswick Regulations Expansion with Battery and Lamp Waste
- In July, the Province repealed regulation 2008–54, replacing it with the Designated Materials Regulation – Clean Environment Act. This Act expanded the regulations to include battery and lamp waste diversion programs.
- These new programs required producers to register with Recycle NB by October 31, 2024, and submit a stewardship plan for approval by December 31, 2024.
Nova Scotia’s Packaging and Battery EPR Programs Rollout
- Multiple programs began their implementation in 2024.
- For packaging, the implementation of the EPR model began with initial reporting requirements from the previous year (weights of designated materials) to Divert NS by October 1, 2024, with full program implementation commencing on December 1, 2025. Producers can expect to receive their first invoice in the fall of 2025.
- For battery producers, 2024 marked two important dates: January 1, 2024 being the deadline to sign up with a PRO, and July 1, 2024, as the battery Extended Producer Responsibility program implementation date.
Prince Edward Island’s EPR Implementation and Stewardship Program Changes
- Prince Edward Island has followed the lead of other provinces with the implementation of an EPR program for batteries in July 2024.
- On June 21, 2024, the Government of Prince Edward Island announced that it would be adding additional electronic devices to its electronics stewardship program, pursuant to amendments to its Materials Stewardship and Recycling Regulations. These amendments came into force on October 1, 2024.
Saskatchewan’s Transition to SK Recycles EPR Program
- The Saskatchewan Ministry of Environment approved Multi-Material Stewardship Western’s (MMSW) Household Packaging and Paper Stewardship Program Plan on May 14, 2024.
- This full, newly rebranded Extended Producer Responsibility program for packaging began on December 1, 2024. Known as SK Recycles, it has taken the place of the Province’s previous stewardship program.
- The full transition to SK Recycles is anticipated by the end of 2027.
Ontario Environmental Compliance: Key Penalties in 2024
- In June 2024, the RPRA issued its first Administrative Penalty in Ontario. The penalty was for ‘failing to establish and operate a collection system for Blue Box materials pursuant to s.19 of Ontario Regulation 391/21’ and for ‘failing to implement a promotion and education program pursuant to s.69 of Ontario Regulation 391/21’. The penalty was $340,457.04.
- The Province issued its second administrative penalty in September 2024 for $119,475.18.
- Learn more about the risks of non-compliance in our recent blog.
What to Expect for Environmental Compliance in 2025:
Yukon’s Extended Producer Responsibility Progress
- Effective January 25, 2024, Yukon’s Extended Producer Responsibility Regulationcame into effect, continuing the Territory’s implementation of EPR. The regulation outlines the requirements for producers to manage PPP and HSP that have reached the end of their life cycle. Yukon is expected to develop and approve program plans for the implementation of EPR by the end of 2025.
Update on Reporting of PFAS (‘Forever Chemicals’)
On July 27, 2024, Environment and Climate Change Canada (ECCC) released its PFAS Reporting Guidance Manual in response to a Section 71 Notice under the Canadian Environmental Protection Act (CEPA).
Any company that, during the 2023 calendar year, participated in any of the following activities is required to submit their data on per- and polyfluoroalkyl substances (PFAS) by January 29, 2025:
- Manufactured more than 1,000 g of any substance listed in Schedule 1
- Imported more than 10 g of a substance listed in Part 1 of Schedule 1 or more than 100 kg of Substances in Parts 2 or 3
- Imported more than 100 kgs of any substance listed in Schedule 1 at a concentration of one ppm or more in a manufactured item
- Used more than 10 g of any substance listed in Schedule 1
If you are unsure if your company is obligated to report or what data needs to be reported, contact us at canada@rev-log.com for a consultation with one of our environmental compliance specialists.
First Year of Reporting Under the Federal Plastics Registry
Reporting requirements for the Federal Plastics Registry will be introduced in phases to allow time for those obligated to report to meet the requirements. Phase 1 reporting deadline to the Federal Plastics Registry is on September 29, 2025, requiring reporting on plastic placed on the market in three categories for the 2024 calendar year.
These categories are Packaging, Electronic and Electrical Equipment (EEE), and Single-use or disposable plastic products.
Reporting entities will also be required to report on the methods used to determine the amounts of plastic reported.
The reporting requirements apply to a broad range of entities, including:
- Manufacturers, importers, and market placers of plastic resins and resin sources
- Producers of plastic products and plastic packaging (“producers” is broadly defined as brand owners, intellectual property holders, or the first importers and distributors of plastic products)
- Generators of packaging and plastic product waste at industrial, commercial, or institutional facilities
- Service providers for the management of plastics or plastic products (including collecting or hauling plastic waste, refurbishing, repairing, recycling, composting, incineration, landfilling of plastic products, and other activities).
Overview for 2025
In 2025, we expect many new environmental regulations intended to progress Canada towards a truly circular economy. These constantly evolving regulations, however, create challenges for businesses, often making it difficult for them to stay up-to-date and compliant – despite their best intentions.
As a leader in environmental compliance and circular solutions, we are here to help. Contact us today to ensure your continued compliance in 2025.
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This article is for informational purposes only and should not be regarded as legal counsel. Information is valid as of the time of publication and is subject to change. Always refer to primary sources for the most up-to-date information.