Exemptions
Circular Materials is committed to minimizing the administrative burden on small businesses participating in packaging and paper products (PPP) producer/stewardship programs across Canada. Some provinces have regulated or legislated policies specifically recognizing the needs of small businesses. In other provinces, a small business policy has been established by the producer/stewardship organization in the province, in consultation with stakeholders and approved by the government. Circular Materials recognizes that producer/steward fees need to be proportional to the amount of PPP supplied into the residential marketplace by producers/stewards and does not intend to place an undue burden on these contributors.
When considering if your organization qualifies for a small business exemption, be sure to consider and include any affiliates. For a complete understanding of how affiliation can affect your organization’s exemption status, please see the Affiliations page.
The following resource provides an overview of small producer exemptions across Canada: Small Producer Exemptions.
The information below contains the definitions and implications of affiliation for each province. If you have questions with respect to exemptions, please contact our Customer Relations producer onboarding team at 1-877-667-2626.
The Nova Scotia Regulations for Extended Producer Responsibility (EPR) for Packaging, Paper Products, and Packaging-like products (PPP) exempts the following producers from regulatory requirements. If a producer meets any one of these criteria, they are considered fully exempt from registration, reporting and payment requirements in Nova Scotia. Producers will also not need to register with Divert NS, the authority overseeing the implementation of EPR in the province, but can do so voluntarily for record keeping purposes.
Exempt producers must, however, retain records to verify their qualification as a small producer for a period of five years from the date of their creation.
| Exemption Criteria | Registration and Reporting Requirements |
|---|---|
| Gross annual revenue in the province less than $1,000,000 | None |
| Annual supply of designated materials less than 1,000 kg | None |
| Societies, such as charities, that are incorporated under the Nova Scotia Societies Act, with the exception of societies incorporated for educational purposes within the province, which includes universities and colleges. | None |
Exemption calculations
When calculating your organization’s gross annual revenue or supplied tonnage, be sure to include all affiliated entities and franchisees’ revenue and tonnage in Nova Scotia. Affiliated businesses do not qualify for small business exemptions, unless the quantity of packaging and paper supplied and the revenue generated by all related corporations, in aggregate, is less than the small business limit in the province.
An organization’s gross annual revenue calculations must include the revenue generated from all goods and services provided within Nova Scotia only, supplied directly and indirectly, to end-users that are both residential and non-residential consumers.
Tonnage calculations must include all the designated materials that are supplied within Nova Scotia for which the organization is the obligated party. This includes only the materials that are supplied, directly and indirectly, to consumers for their personal, family or household purposes, and excludes any packaging and paper for which the end user is a non-residential consumer.
The Designated Materials Regulation exempts the following producers from regulatory requirements. If a brand holder/owner meets any one of these criteria, they are considered fully exempt from reporting and payment requirements in New Brunswick, but will need to register with Recycle NB, the agency which oversees the packaging and paper program in New Brunswick.
| Exemption Criteria | Registration and Reporting Requirements |
|---|---|
| Gross annual revenue in the province less than $2,000,000 | Register with Recycle NB |
| Annual supply of designated materials less than 1,000 kg | Register with Recycle NB |
| Charitable organizations registered under the Income Tax Act | Register with Recycle NB |
Exemption calculations
When calculating your organization’s gross annual revenue or supplied tonnage, be sure to include all affiliated entities and franchisees’ revenue and tonnage in New Brunswick. As set out in the New Brunswick Stewardship Plan for Packaging and Paper, approved by Recycle NB, a producer’s obligation includes paper and packaging supplied by the producer’s affiliates in the provinces. As such, affiliated businesses “do not qualify for small business exemptions, unless the quantity of packaging and paper supplied and the revenue generated by all related corporations, in aggregate, is less than the small business limit in the province.”
An organization’s gross annual revenue calculations must include the revenue generated from all goods and services provided within New Brunswick only, supplied directly and indirectly, to end-users that are both residential and non-residential consumers.
Tonnage calculations must include all the designated materials that are supplied to within New Brunswick for which the organization is the obligated party. This includes only the materials that are supplied, directly and indirectly, to consumers for their personal, family or household purposes, and excludes any packaging and paper for which the end user is a non-residential consumer.
The Blue Box Regulation in Ontario exempts the following producers from regulatory requirements. Please note that producers supplying packaging and paper into Ontario will need to contact Resource Productivity & Recovery Authority (RPRA), the regulator responsible for enforcing the province’s circular economy laws, for confirmation on their obligation and exemption status. The following information is provided for guidance only.
Producers exempt under the revenue-based criterion must retain records to verify their qualification as a small producer for a period of five years from the date of their creation.
| Exemption Criteria | Registration and Reporting Requirements |
|---|---|
| Gross annual revenue in the province less than $2,000,000 | None |
|
Blue Box Material Category & Supply-based exemption level (kg)
|
As noted on RPRA’s website, if a producer’s annual revenue is more than $2,000,000 and supply weight in all material categories is less than the tonnage exemption threshold, the producer is required to register and report. If a producer’s annual revenue is more than $2,000,000 and supply weight in at least one material category is above the tonnage exemption threshold, the producer is required to meet all obligations (registration, reporting, collection, management, and promotion and education). However, producers are only required to meet their minimum management requirement in material categories where they are above the exemption level. |
| Newspaper producers whose total weight of Blue Box materials in a calendar year includes at least 70% newspapers | None |
Exemption calculations
It is important that producers advise RPRA of any affiliated entities to obtain an accurate assessment of the organization’s obligation and exemption status.
An organization’s gross annual revenue calculations must include the revenue generated from all goods and services provided within the province only, supplied directly and indirectly, to end-users that are both residential and non-residential consumers. Franchisors’ gross annual revenue includes all franchisees located in Ontario.
Tonnage calculations must include all the designated materials that are supplied within Ontario for which the organization is the obligated party. This includes only the materials that are supplied, directly and indirectly, to consumers for their personal, family or household purposes, and excludes any packaging and paper for which the end user is a non-residential consumer. Please note that in Ontario beverages that are supplied for business purposes are also within scope.
While Manitoba’s Packaging & Paper Product Stewardship Regulation does not provide exemptions for any class of steward, Multi-Material Stewardship Manitoba (MMSM) has established a Small Business Policy that is set out in the Steward Rules.
| Exemption Criteria | Registration and Reporting Requirements |
|---|---|
| Gross annual revenue in the province less than $750,000 | Register with MMSM and declare non-obligation each year. No reporting and payment requirements. |
Exemption calculations
When calculating your organization’s gross annual revenue or supplied tonnage, be sure to include all affiliated entities’ revenue and tonnage in Manitoba. Affiliated businesses “do not qualify for small business exemptions, unless the quantity of packaging and paper supplied and the revenue generated by all related corporations, in aggregate, is less than the small business limit in the province.”
An organization’s gross annual revenue calculations must include the revenue generated from all goods and services provided within Manitoba only, supplied directly and indirectly, to end-users that are both residential and non-residential consumers.
Tonnage calculations must include all the designated materials that are supplied within Manitoba for which the organization is the obligated party. This includes only the materials that are supplied, directly and indirectly, to residential consumers, and excludes any packaging and paper for which the end user is a non-residential consumer.
Saskatchewan’s SK Recycles Program Plan, last revised in May 2024, exempts the following small businesses.
| Exemption Criteria | Registration and Reporting Requirements |
|---|---|
| Gross annual revenue in the province less than $1,000,000* | None |
| Annual supply of designated materials less than 1,000 kg | None |
| Registered charity | None |
*Transition period: Eligible organizations can choose to pay a fixed fee in 2015 and 2016 as part of the SK Recycles transition period and are not required to complete a Membership Agreement and file a detailed report. Eligible organizations include:
- Companies with revenue between $2 – 5 million.
- Newspaper publishers with gross revenue in Saskatchewan of over $2 million.
- Contact Customer Relations at 1-877-667-2626 to learn if you are eligible for the transition period.
Exemption calculations
When calculating your organization’s gross annual revenue or supplied tonnage, be sure to include all affiliated entities’ revenue and tonnage in Saskatchewan. Affiliated businesses “do not qualify for small business exemptions, unless the quantity of packaging and paper supplied and the revenue generated by all related corporations, in aggregate, is less than the small business limit in the province.”
An organization’s gross annual revenue calculations must include the revenue generated from all goods and services provided within Saskatchewan only, supplied directly and indirectly, to end-users that are both residential and non-residential consumers.
Tonnage calculations must include all the designated materials that are supplied within Saskatchewan for which the organization is the obligated party. This includes only the materials that are supplied, directly and indirectly, to residential consumers, and excludes any packaging and paper for which the end user is a non-residential consumer.
Alberta’s Extended Producer Responsibility Regulation exempts the following producers from regulatory requirements.
| Exemption Criteria | Registration and Reporting Requirements |
|---|---|
| Gross annual revenue in the province less than $1,5000,000 | Register with ARMA |
|
Annual supply of designated materials less than the following amounts for residential use in Alberta per year:
|
If the producer’s supply is below all of these material categories, they are required to register and report, but will be exempt from paying fees or participating in the common collection system. If they supply above the threshold in any one of these categories, service and performance obligations will apply for all categories. Newspapers producers who supply less than 200 tonnes of newspapers (and no other packaging, paper or packaging-like products) are exempt from the regulations in terms of having to operate a collection system or management targets. |
| Charitable organizations as defined in the Charitable Fund-raising Act | None |
Charitable organizations as well as businesses whose gross annual revenue is below the stated threshold are required to create an account with the Alberta Recycling Management Authority (ARMA), the oversight body, and confirm their exemption status.
Producers supplying materials under the threshold in one or all of the above material categories will need to report annually, while those supplying above the thresholds in any of the above categories will have service and performance obligations applicable to all categories.
Exempt producers must retain records to verify their qualification as a small producer.
Exemption calculations
It is important that producers advise ARMA of any affiliated entities to obtain an accurate assessment of the organization’s obligation and exemption status.
An organization’s gross annual revenue calculations must include the revenue generated from all goods and services provided within the province only, supplied directly and indirectly, to end-users that are both residential and non-residential consumers. Franchisors’ gross annual revenue includes all franchisees located in Alberta.
Tonnage calculations must include all the designated materials that are supplied to within the province for which the organization is the obligated party. This includes only the materials that are supplied, directly and indirectly, to consumers for residential use, and excludes any packaging and paper for which the end user is a non-residential consumer.
British Columbia’s BC Recycling Regulation, last revised in May 2014, exempts some categories of small businesses from the obligations of the Regulation. The Recycle BC program stewardship plan meets regulatory requirements and is approved by the BC Ministry of the Environment and Climate Change Strategy.
| Exemption Criteria | Registration and Reporting Requirements |
|---|---|
| Gross annual revenue in the province less than $1,000,000 | None |
| Annual supply of designated materials less than 1,000 kg | None |
| Charitable organizations registered under the Income Tax Act | None |
| Single point of retail sale | None |
Single point of retail sale
Producers that have only a single point of retail are exempt from the Regulation and registering with Recycle BC. To qualify, the producer must only operate one retail location and not supply products online, through third-party retailers and distributors, or as part of a chain or franchise.
Exemption calculations
When calculating your organization’s gross annual revenue or supplied tonnage, be sure to include all affiliated entities’ revenue and tonnage in British Columbia. Affiliated businesses “do not qualify for small business exemptions, unless the quantity of packaging and paper supplied and the revenue generated by all related corporations, in aggregate, is less than the small business limit in the province.”
An organization’s gross annual revenue calculations must include the revenue generated from all goods and services provided within British Columbia only, supplied directly and indirectly, to end-users that are both residential and non-residential consumers.
Tonnage calculations must include all the designated materials that are supplied within British Columbia for which the organization is the obligated party. This includes only the materials that are supplied, directly and indirectly, to residential consumers, and excludes any packaging and paper for which the end user is a non-residential consumer.