Canadian product stewardship and EPR: 2025 summer update

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.

A. How have programs already changed in 2025, and what changes are expected in the rest of 2025 and beyond?

(1) British Columbia

Upcoming changes

• In March 2025, the British Columbia Ministry of Environment and Parks published the 2025/26 – 2027/28 Service Plan,[2] which advances the multi-phased implementation of new products under the Extended Producer Responsibility Five-Year Action Plan.[3] As part of the next phase of this Action Plan, the province is preparing changes to its Recycling Regulation to implement EPR programs in 2025 for products such as mattresses, single-use compressed canisters, refillable propane and spray foam tanks, fire extinguishers, automotive containers, hybrid and electronic vehicle batteries, and medical sharps.[4]

• From March 3, 2025, to April 16, 2025, the Canadian Battery Association presented its draft BC stewardship plan for lead-acid batteries, the Extended Producer Responsibility Program Plan, for stakeholder feedback.[5] The Canadian Battery Association has operated an approved Stewardship Program for lead-acid batteries in British Columbia since 2011.[6] Next steps in this EPR transition are anticipated in the coming months.

(2) Alberta

Recent developments

• On March 26, 2025, amendments to Alberta’s Extended Producer Responsibility Regulation came into force.[7] Packaging-like products, made wholly or partially of flexible plastic and used by households and intended for the containment, protection or handling of food, are now excluded as a designated material under the Regulation.[8] The narrow range of flexible plastic items exempted from the regulation include freezer/sandwich bags, plastic wrap/cling film, vacuum bags, and garbage and compost bags.[9]

• On April 1, 2025, Phase I of Alberta’s EPR program for single-use products, packaging and paper products (“PPP”) and hazardous and special products (“HSP”) was launched.[10] For the PPP program, the Alberta Recycling Management Authority (“ARMA”) has paused verification requirements for 2025 supply reporting. The first year requiring verified supply reporting data will be 2026.[11] On October 1, 2026, Phase II will expand the program to include multi-family dwellings and any new communities that register.

• On April 1, 2025, Call2Recylce also announced the launch of its provincial battery recycling program in Alberta.[12] ARMA approved Call2Recycle as a Producer Responsibility Organization ("PRO"), working to support producers in meeting their regulatory obligations under the EPR regulation.

Upcoming changes

• On April 15, 2025, the Government of Alberta announced amendments to the Administrative Penalty Regulation.[13] Effective April 1, 2026, suppliers and producers in Alberta may face penalties under two updated regulations:

• Designated Material Recycling and Management Regulation: Suppliers of designated materials, including electronics, can be penalized for failing to remit surcharges, register with ARMA, or submit required reports.[14]

• Extended Producer Responsibility Regulation: Producers may be penalized for failing to register or for not meeting collection, service, and material management standards.[15]

(3) Saskatchewan

Upcoming changes

• As part of achieving the goal of safe communities and a healthy environment, the Saskatchewan Ministry of Environment’s 2025-26 Business Plan aims to implement the Solid Waste Management Strategy. In addition to reviewing the Strategy itself, this involves exploring regulatory options for materials not yet subject to EPR programs but identified in the Canada-Wide Action Plan for Extended Producer Responsibility. The Ministry also plans to engage on potential changes to The Household Hazardous Waste Product Stewardship Regulations and The Used Petroleum and Antifreeze Products and Stewardship Regulations.[16]

(4) Manitoba

Upcoming changes

• On March 27, 2025, Multi-Material Stewardship Manitoba (“MMSM”) published a Draft Transition Plan for Manitoba’s transition to EPR.[17] The plan sets out the process by which MMSM will assume operational and financial responsibility for residential PPP collection and management in the province.

(5) Ontario

Recent developments

• On March 25, 2025, the Resource Productivity and Recovery Authority (“RPRA”) issued Notices of Intention in March 2025, indicating it intended to issue Administrative Penalty Orders against battery and tire producers unless producers complied with regulatory requirements.[18]

• On April 28, 2025, the RPRA issued Administrative Penalty Orders totalling $2,781,725.72 to three battery producers for failing to meet their 2023 recycling targets under the Resource Recovery and Circular Economy Act, 2016’s Batteries Regulation.[19] All three producers have appealed the Administrative Penalty Order.

Upcoming changes

• On June 4, 2025, the Government of Ontario announced proposals to amend the Resource Recovery and Circular Economy Act, 2016,[20] and the Blue Box Regulation under the Act.[21] Proposed legislative amendments under the Act are intended to address transparency and cost disclosure, by requiring PROs to provide more information to producers and the RPRA.

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.

• Additionally, as part of the Blue Box Transition, on April 8, 2025, Stewardship Ontario published an announcement[22] reminding producers to download their historical data from the WeRecycle Portal.[23] Stewardship Ontario is winding up operations, and as of December 12, 2025, this data will no longer be available online.

(6) Quebec

Recent developments

• On January 1, 2025, a modernized curbside recycling system for containers, packaging, and printed paper, operated by Éco Entreprises Québec—the designated PRO—began.[24] The 2024 Annual Report[25] was published on April 30, 2025, and ongoing discussions with the province could lead to the implementation of measures in 2025 to mitigate the impact of the increase on curbside recycling rates on producers.[26] Mitigation measures already in place include the lifting of interest and administrative fees for late payments until March 31, 2025, and a procedure for staggering 2025 producer financial participation payments.

• In February 2025, amendments which increased the length of a Designated Management Body designation from five to 10 years were made to the Regulation respecting a system of selective collection of certain residual materials.[27] These changes aim to increase predictability in the EPR system by extending the duration for which any one organization can be designated under the regulation to manage an EPR program.[28]

• In February 2025, all plastic 100 mL to 2 L ready-to-drink beverage containers were brought within the scope of EPR in Quebec.[29] Further amendments to the Regulation respecting the development, implementation and financial support of a deposit-refund system for certain containers were also introduced.[30] These changes postponed system rollout for containers made of glass, other breakable materials or fibers, including multilayer containers by two years to March 1, 2027, and provided Designated Management Bodies with more flexibility to optimize the network of return locations across the province.[31]

• On May 28, 2025, Bill 81, An Act to amend various provisions relating to the environment, came into force.[32] While no immediate changes have been made, the bill grants new regulatory powers under the Environment Quality Act related to residual materials management.[33] These powers enable the government to:

• expand EPR over new products and sectors;
• set minimum proportions for recovered, recycled, and reclaimed materials to be used in packaging;
• prohibit the use of certain materials in packaging;
• expand obligations to ensure a product’s re-use;
• obligate certain producers to compensate for the costs of recovery; and
• regulate the marketing, distribution, and sale of single-use products and control the management of certain unsold goods.

(7) New Brunswick

Recent developments

• On May 1, 2025, New Brunswick’s EPR program for PPP, transitioned to phase 1 (school and multi-family residence integration). Phase 2 will begin on November 1, 2025.[34] Schools and multi-family dwellings can register to be included in phase 2 on the Circular Materials website before May 31, 2025. A new five-year Stewardship Plan must be submitted to Recycle NB before the end of June, as required under the Designated Materials Regulation.

(8) Nova Scotia

Upcoming changes

• As reported in our last update, producers were required to register with the Divert NS PPP EPR Program by January 1, 2024, and initial reporting from 2023 by October 1, 2024 was required. Nova Scotia’s PPP EPR program is expected to be operational by December 1, 2025.[35] Producers of recyclable PPP will be fully responsible for the delivery of curbside recycling in the province by December 1, 2025.[36]

(9) Prince Edward Island

Recent developments

• On May 9, 2025, the PEI government introduced Bill 17, to repeal the Beverage Containers Act.[37] A stakeholder consultation process to transition from beverage container stewardship to an EPR model is now underway, with the possibility of the new EPR program being in place as early as Fall 2025.[38] 

• On May 16, 2025, Bill 16, An Act to Amend the Environmental Protection Act received royal assent, establishing regulation-making powers respecting fees, deposits and refunds to be paid in relation to designated materials.[39] The Materials Stewardship and Recycling Regulations define “designated material” as a material diverted from disposal and managed under a stewardship plan or a permit endorsement pursuant to the regulations.[40] Designated materials under the regulation include:

• automotive salvage and scrap metal;
• electronic products;
• rechargeable and single-use batteries;
• lead-acid batteries;
• consumer paint products;
• lamp products;
• oil and glycol products;
• pharmaceutical products;
• medical sharps; and
• agricultural plastic products.

(10) Yukon

Recent developments

• In January 2025, the government of Yukon approved Call2Recycle’s battery recycling program plan.[41] The program for household batteries launched on June 24, 2025. Resident brand holders of batteries sold, offered for sale or otherwise distributed in or into the Yukon, battery importers, and direct-to-end-user retailers should enroll via Call2Recycle’s online Member Request Form.

Upcoming changes

• On February 1, 2025, the Government of Yukon approved Circular Materials’ Stewardship Plan for Packaging, Paper and Single-Use Products, with a program start date of November 1, 2025.[42] Producers will be notified when registration for this new EPR program is open.[43]

• Product Care has committed to submitting a stewardship plan for HSP to the Government of Yukon by end of summer 2025, with an anticipated start in the fall of 2025.[44] The draft HSP stewardship plan was made available online on June 6, 2025, with the deadline for written comments set for August 9, 2025.[45]

B. Next steps

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.