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I purchase non-branded bags from a wholesaler and provide them to consumers at point of sale. I am not putting my brand name on the bags but the packaging manufacturer’s name is on the bottom of the bag. Who is obligated to report this?

For MMSW, MMSM and Stewardship Ontario stewards that supply bags as service packaging to consumers, you are the obligated steward to report this material. Even though you are purchasing packaging as a product from a manufacturer whose brand is on the packaging, you are then distributing this material to consumers as ‘service packaging’ containing your product, making you the obligated steward for this material.

For Recycle BC stewards, amendments to the BC Recycling Regulation announced in September 2020, which designated Single-Use Products and Packaging-Like Products, has resulted in a change to the obligated party required to report and pay fees on Service Packaging. The obligated party shifts from the “filler” who previously reported such packaging supplied to consumers at point of sale, to either the brand owner, first importer or franchisor of the packaging that is ultimately supplied to consumers in British Columbia. If the service packaging carries a brand name it will remain the obligation of the brand owner. Please refer to this Explanatory Note on the Recycle BC website for more information.