Like the U.S., Canada has no federal EPR law. British Columbia enacted an extended producer responsibility program for packaging and paper products in 2014, the first EPR law in Canada. Other provinces followed, which means companies doing business in Canada must navigate a patchwork of laws, as all but four of its 13 provinces and territories now have packaging EPR laws in place.
That said, the Canadian government has launched the Federal Plastics Registry, a nationwide initiative to collect data to help monitor and track plastics through their life cycle in the Canadian economy. This is part of Canada’s plan to move toward the goal of zero plastic waste by 2030.
RELATED: Guide To Reducing Waste In Packaging For Promotional Products
Plastics producers will be obligated to report the quantities of plastic they place on the Canadian market each year, as well as specify the source of the resins used (i.e., recycled or virgin petroleum). Generators of plastic waste who send waste for disposal or diversion also must report, as well as service providers who collect plastic waste, making Canada’s registry somewhat broader than most EPR programs in the U.S.
“Some of our members are already addressing these requirements and have been making great strides toward this goal by implementing programs within their facilities and among their employees,” says Margaret Williamson Batuszkin, marketing and communications manager for the Promotional Product Professionals of Canada. “Members are continually looking at initiatives and ways to ensure compliancy as we move toward the FPR reporting deadline.”
Registry Reporting Requirements
Many details are still being worked out, but the Canadian government is drafting a guidance document, and the registry portal is expected to launch in the latter half of 2025.
Some elements are already more obvious, however. Importantly, Canada defines “producer” as one of the following:
- A brand owner or intellectual property holder who resides in Canada.
- The first person to manufacture or import a plastic product in Canada.
- A Canadian retailer who supplies the product to the consumer.
Reporting requirements are scheduled in phases, starting in September 2025 with reporting due on plastic placed on the market in three categories – packaging, single-use and disposable plastics and electronics, and electrical equipment destined for the residential waste stream – during the 2024 calendar year.
ICYMI: Canada Sets Stages, Schedule For Single-Use Plastics Ban
Small businesses are exempt from the federal reporting requirements. The reporting obligations do not apply to entities that generate or manage less than 1,000 kilograms (2,204.62 pounds) of plastic products or packaging per calendar year.
In addition to recycling and end-of-life materials handling, some provinces also require the reporting of plastics data under local EPR regulations, although the specific information required by each jurisdiction is different. Circular Materials is one of several nonprofit producer responsibility organizations across Canada that administer programs to help producers meet their EPR obligations. These organizations are good resources to learn more about the regulations and your business’s obligations.
What’s Next For Packaging EPR In Canada?
While the provincial regulations have been established for some time, some people believe the Federal Plastics Registry may fade away before it truly gets started.
“I think I’m more concerned about U.S. EPR than I am about any Canadian EPR regulation, including the Federal Plastics Registry,” says Brianna Mazze, vice president of compliance and sustainability for Ontario-based St Regis Group, the No. 22 supplier in the PPAI 100. She expects Canada’s government to follow its neighbor to the south and elect a conservative government next fall that would likely scrap the registry and other sustainability initiatives.
ICYMI: How Will New Packaging EPR Laws In 5 States Affect Promo?
“There’s still a lot of confusion and vagueness around the EPR rules and where it falls,” says Reba Joy, director of environmental and social impact for Toronto-based Genumark, the No. 35 distributor in the PPAI 100. “It’s tricky with all these regulations, especially around the elections and government changes. How much is going to be undone? Right now, it’s also still vague, so we’re waiting for those details.”
Brianna Mazze
VP of compliance and sustainability, St Regis Group
Opportunity For Innovation, Cost Savings
However, both Mazze and Joy say that the still-active registry requirements present an opportunity, as paying more attention to packaging should reveal prospects for cost savings through more efficient use of materials.
“This has highlighted the need for better data on packaging, not just for EPR, but also doing a carbon footprint on our products,” says Mazze, adding that St Regis is working on a life cycle analysis of its products that includes developing better packaging data. “… That’s never been tracked in the past because it was never needed.”
She expects to have more data from the start for new products but admits that “going backwards is going to be tricky” and will require collaboration across departments. “It can’t be driven from me alone. I have to have the company on board. I have to get purchasing on board, merchandising, marketing – the programmer has to put it in the system. It’s a very collaborative change for the company.”
EPR laws are meant to encourage businesses to redesign their packaging to be less wasteful, but with promo, protecting the decoration is often a critical part of what the packaging does. That doesn’t mean there aren’t opportunities for better choices, says Joy.
Reba Joy
Director of Environmental & Social Impact, Genumark
“I’ve always been curious how much would get damaged – what is the actual risk there?” says Joy. “And which items would be more durable than others, because I think it becomes a blanket solution where they’re like, ‘Just polybag everything,’ and I still get samples that are not breakable and covered in bubble wrap.”
ICYMI: Canada Passes Law Cracking Down On Greenwashing
Joy is hoping the introduction of EPR regulations inspires promo companies not only to take a closer look at their packaging but to make meaningful changes. “Is this the push that we could have to rethink the packaging we’re using and get rid of a bunch that’s not helpful? I think it’s just been on autopilot for so long that it’s like, ‘This is just how we do it. Let’s keep on doing it this way.’ … Sometimes you need it to be a pain in the butt to give that push.”
Mazze agrees and expects that the scrutiny required to comply with EPR regulations will yield cost savings as companies figure out ways to reduce the amount of packaging they use.
“The best, most sustainable packaging is no packaging at all,” she says, “so if we can just eliminate some, there could be cost savings from there, too.”
