Mark Youden
Partner
Article
In the first half of 2025, we have seen the continuation of innovative product stewardship and extended producer responsibility (“EPR”) programs across the country. These initiatives aim to divert waste from landfills and cover a broad range of product categories, including tires, batteries, electronic products, packaging and printed paper, beverage containers, and hazardous and special products.
This article is the latest update in Gowling WLG’s ongoing bi-annual series providing an overview of current developments in Canadian product stewardship and EPR programs.[1]
This review includes new and expanded programs and shifts from product stewardship to EPR models. Emerging initiatives, as well as program delays and changes, are also discussed, with a view to what companies can expect moving forward.
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The proposed changes to the Blue Box Regulation would notably delay the implementation of any recovery target for another five years, despite the fact that system participants have been planning for the full implementation of the blue box system on January 1, 2026, for many years. The government has indicated that these proposed regulatory changes are intended to help manage higher than expected costs for blue box collection and recycling services. Other proposed changes include removing the planned expansion for multi-residential buildings, schools, and retirement homes, requiring producers to be responsible only for the collection of beverage containers from residential consumers, and allowing for energy recovery (via energy from waste facilities) to count towards a portion of diversion targets
The comment period for the proposed changes to the Resource Recovery and Circular Economy Act and Blue Box Regulation were open until July 21, 2025, and July 4, 2025, respectively. An announcement on which of these proposed changes will move forward is expected in the fall, and may only be a first step towards amending the blue box system to manage costs to producers.
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Product stewardship and EPR programs in Canada are rapidly evolving, with new product categories, expanded responsibilities, and stricter enforcement. Companies must stay informed of these changes to ensure compliance and avoid penalties.
Gowling WLG continues to monitor these programs closely and will publish further biannual updates and other updates on key changes to these programs. If you have questions about your company's obligations under these programs, we encourage you to contact any member of our experienced environmental law team.
[1] https://gowlingwlg.com/en-ca/insights-resources/articles/2025/canadian-product-stewardship-and-epr
[2] British Columbia Ministry of Environment and Parks, 2025/26 – 2027/28 Service Plan.
[3] British Columbia Ministry of Environment and Climate Change Strategy, Extended Producer Responsibility Five-Year Action Plan.
[4] See Government of British Columbia, Advancing recycling in B.C.
[5] Canadian Battery Association, Current Stakeholder Consultation: British Columbia.
[6] See Government of British Columbia, EPR plans and reports.
[7] Extended Producer Responsibility Regulation, Alta Reg 194/2022.
[8] Extended Producer Responsibility Regulation, Alta Reg 194/2022, s. 13(1.1); Government of Alberta, Guide to Exemption for Flexible Packaging Like Products.
[9]Government of Alberta, Guide to Exemption for Flexible Packaging Like Products.
[11] ARMA, EPR in Alberta.
[12] Call2Recylce, Call2Recylce increases its national presence and launches its new provincial battery recycling program in Alberta.
[13] Administrative Penalty Regulation, Alta Reg 23/2003.
[14] Designated Material Recycling and Management Regulation, Alta Reg 93/2004.
[15] Extended Producer Responsibility Regulation, Alta Reg 194/2022.
[16] Saskatchewan Ministry of Environment, Business Plan 2025-26.
[17] MMSM, Draft Transition Plan (March 27, 2025).
[18] RPRA, Statement from the Registrar: Registrants must submit reports on time or face compliance and enforcement action.
[19] RPRA, Statement from the Registrar: RPRA issues Administrative Penalty Orders to battery producers. Two of the penalties were capped at $1,000,000 in accordance with the Regulation, but actual calculated penalties were more than $2 million per producer
[20] Environmental Registry of Ontario, Amendments to the Resource Recovery and Circular Economy Act, 2016.
[21] Environmental Registry of Ontario, Amendments to the Blue Box Regulation.
[22] Stewardship Ontario, Reminder to Download Stewardship Ontario Historical Data.
[23] Circular Materials, WeRecycle Portal.
[25] Éco Entreprises Québec, 2024 Annual Report.
[26] Éco Entreprises Québec, Minister Benoit Charette responds positively to Éco Entreprises Québec’s proposals.
[27] Regulation respecting a system of selective collection of certain residual materials, CQLR c Q-2 r 46.01.
[28]Québec Ministère de l’Environnement, de la Lutte contre les changements climatiques, de la Faune et des Parcs, Modernized Selective Collection.
[29]Québec Ministère de l’Environnement, de la Lutte contre les changements climatiques, de la Faune et des Parcs, Modernized Deposit-Refund.
[30]Regulation respecting the development, implementation and financial support of a deposit-refund system for certain containers, CQLR c Q-2, r 16.1.
[31]Québec Ministère de l’Environnement, de la Lutte contre les changements climatiques, de la Faune et des Parcs, Modernized Deposit Refund.
[33]Environment Quality Act, CQLR c Q-2.
[34] Circular Materials, Circular Materials celebrates the expansion of recycling across New Brunswick.
[35] Divert NS, Producers of Recyclable Waste.
[36] Divert NS, For Producers of Recyclable Packaging and Paper.
[37] Retail Council of Canada, PEI Introducers Legislation to Repeal Beverage Containers Act.
[38] Government of Prince Edward Island, Beverage Container Refunds – Proposed Changes.
[39] Bill 16, An Act to Amend the Environmental Protection Act, SPEI 2025.
[40] Materials Stewardship and Recycling Regulations, PEI Reg EC349/14.
[41] Call2Recycle, Battery Stewardship Program Plan for Yukon.
[42] Circular Materials, Yukon Stewardship Plan for Packaging, Paper and Single-use Products.
[43] Circular Materials, Packaging and paper extended producer responsibility in the Yukon.
[44] Product Care, Hazardous and Special Products: Yukon.
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