1.11 What is a small business policy?

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To the extent permitted by the provincial PPP program legislation, Circular Materials is committed to minimizing the administrative burden on small businesses participating in PPP stewardship programs. 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 stewardship organization in consultation with stakeholders and approved by the government. Circular Materials recognizes that stewardship fees need to be proportional to the amount of packaging and paper product supplied into the residential marketplace by stewards and does not intend to place an undue burden on small contributors.

When considering if your organization qualifies for a small business exemption, be sure to consider and include any affiliates. Affiliates of a parent company are required to report under a single account and do not qualify for small business exemptions, unless the quantity of PPP supplied and the revenue generated by all related corporations, in aggregate, is less than the small business limit in the particular province. The following table outlines the small business (or de minimis) policies in BC, SK, MB and ON.

	BC	SK	MB	ON
Regulatory or legislative policy	In May 2014, the BC government amended the Recycling Regulation to exempt some categories of small businesses from the obligations of the BC Recycling Regulation.	The MMSW Program Plan was revised in December 2014 to exempt some small businesses.	The MB Packaging and Paper Product Stewardship Regulation does not provide exemptions for any class of producer but MMSM has established a Small Business Policy as set out in the Steward Rules.	The allowance for a de minimis policy is established in the Waste Diversion Transition Act, 2016 Sect. 33(e) and is further defined in the Blue Box Program Plan (section 9.4.1) for a de minimis policy as required by the Minister’s Request Letter.
Registration Requirements	Businesses that supply less than 1,000 kg of PPP or have revenues in B.C. of less than $1M are exempt from the Regulation and do not need to register with Recycle BC.	Businesses that supply less than 1,000 kg of waste packaging and paper (WPP) to SK consumers or with revenues in SK less than $2M are exempt from registration and reporting requirements with MMSW.	All stewards are required to register with MMSM regardless of their size.	Stewards with revenues in ON of less than $2M/year do not need to register with Stewardship Ontario.
Revenue-based threshold	Businesses with revenue in BC of less than $1M are exempt from the Regulation. Charitable organizations registered under the Income Tax Act (Canada) are also exempt from the Regulation.	A permanent exemption has been granted to businesses (including newspapers) that generate less than $2 million in gross annual revenue in SK. MMSW Transition Period: Eligible organizations can choose to pay a fixed fee in 2015 and 2016 as part of the MMSW 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 (888) 980-9549 to learn if you are eligible for the Transition Period.	Stewards are exempt from filing a Steward’s Report and paying the fees otherwise due, if during the data year, the steward, its affiliates, and franchisees had combined gross revenues from the sale of all products and services in Manitoba of less than $750,000.	A steward is exempt from collecting and reporting data to Stewardship Ontario if the steward (including affiliates/subsidiaries) has less than $2 million gross revenue from the combined sale of all of its products and services in Ontario in a calendar year.
Weight-based threshold	Only businesses that supply less than one tonne (1,000 kg) of PPP are exempt from the Regulation and reporting to Recycle BC.	A permanent exemption has been granted to businesses that generate less than 1,000 kg of WPP in SK annually.	N/A	Stewards with gross sales over $2 million but total reported packaging and paper product quantities of less than 15,000 kg (15 tonnes) must report their materials to Stewardship Ontario but are exempt from paying fees.
Single Point of Retail Sale	Stewards that are a single point of retail sale are exempt from the Regulation and registering with Recycle BC. To qualify, the steward must only operate one retail location and not supply products on-line, or as part of a chain or franchise.	Stewards that are a single point of retail sale are exempt from the Regulation and registering with MMSW To qualify, the steward must only operate one retail location and not supply products on-line, or as part of a chain or franchise.	N/A	N/A
Low volume steward fees	Businesses that distribute between 1,000 and 4,999 kg of PPP qualify as Low Volume Stewards and are eligible for a flat fee payment. There are two categories of Low Volume stewards: organizations that distribute between 1,000 and 2,499 kg of material and those that distribute between 2,500 – 4,999 kg. Visit here to find out more about eligibility. Please review the Terms and Conditions for filing.	Low Volume stewards are defined as businesses that distribute between 1,000 and 5,000 kg of WPP to SK consumers Please visit the MMSW site for more information on flat fees for low volume stewards. Please review the Terms and Conditions for filing.	Low volume stewards are eligible for flat fees for two reporting categories: 1,000 to 2,499 kg 2,500 to 4,999 kg Flat fees associated with these categories will be provided in the Fall of each year. . Please contact Customer Relations for additional guidance Eligible stewards are encouraged to review the Terms and Conditions.	There are no flat fees for low volume stewards.
Flat Fee Categories	Flat fees are available for stewards that: distribute between 5,000 to 9,999 kg, and Stewards that distribute between 10,000 - 15,000 kg of materials. Flat fees associated with these categories will be provided in the Fall of each year.	N/A		N/A
Franchisors & Franchisee Obligations	Franchisors with headquarters located both inside and outside of the province, with franchisees operating in British Columbia, are responsible for reporting and paying fees on all PPP supplied by all of its franchisees to residential consumers in BC.	Franchisors with headquarters located both inside and outside of the province, with franchisees operating in SK, are responsible for reporting and paying fees on all PPP supplied by all of its franchisees to residential consumers in SK.	Franchisors with headquarters located both inside and outside of the province, with franchisees operating in MB, are responsible for reporting and paying fees on all PPP supplied by all of its franchisees to residential consumers in MB.	Franchisors with headquarters located both inside and outside of the province, with franchisees operating in ON, are responsible for reporting and paying fees on all the PPP supplied by all of its franchisees to residential consumers in ON.