California vs Manitoba EPR: Rules Compared
Last verified
California and Manitoba both run packaging EPR, but the rules differ. Manitoba exempts only producers below the lower revenue floor, CA$750,000 against $1,000,000 in California. Both require producers to register. Manitoba publishes the higher per-kilogram fee in 4 of 4 shared material classes.
California and Manitoba side by side
4 of 9 rows have a verified figure on each side of California and Manitoba; a cell reads “not yet published” when a side has none, and an exemption row reads “none recorded; see thresholds” when no exemption is on record.
| Measure | California | Manitoba | Stricter |
|---|---|---|---|
| Registration duty | Required | Required | Same |
| Producer organisation | one producer responsibility organisation | one producer responsibility organisation | Not comparable |
| Lowest revenue exemption | $1,000,000 | CA$750,000 | Manitoba |
| Lowest weight exemption | none recorded; see thresholds | none recorded; see thresholds | Not comparable |
| First annual report date | not yet published | May 31 | Not comparable |
| Published penalties | 1 published | not yet published | Not comparable |
| Report file | csv | csv | Not comparable |
| Paper fee, cheapest matched rate | 0.4 cents per pound | 18.23 cents per kilogram | Manitoba |
| Plastic fee, cheapest matched rate | 2.5 cents per pound | 79.03 cents per kilogram | Manitoba |
The lowest revenue exemption is $1,000,000 in California and CA$750,000 in Manitoba ($536,557 at the Bank of Canada 2025 annual average rate). Manitoba therefore reaches smaller sellers: a business with revenue between the two lines is exempt in California but still in scope in Manitoba.
Both programmes require a producer to register, in California and in Manitoba.
Across 4 shared material classes, Manitoba publishes the higher cheapest per-kilogram fee in 4, and California in 0. A higher fee is not the same as a stricter rule; it is simply a larger published number per kilogram.
Who runs the programme in California and Manitoba
Who collects and who the producer files with, in California and then Manitoba.
| Aspect | California | Manitoba |
|---|---|---|
| Regime | California SB 54, Plastic Pollution Prevention and Packaging Producer Responsibility Act (Public Resources Code, Division 30, Part 3, Chapter 3.1) | Packaging and Printed Paper Stewardship Regulation, M.R. 195/2008 |
| Regulator | CalRecycle (Department of Resources Recycling and Recovery), through its PEPRS portal | not yet published |
| Producers obligated | Yes | Yes |
| Registration | Required, PEPRS (CalRecycle Packaging Extended Producer Responsibility System) | Required, WeRecycle Portal |
| Producer organisation | one producer responsibility organisation: Circular Action Alliance; membership required | one producer responsibility organisation: Recycle Manitoba (MMSM); membership required |
| Transfer of responsibility | Not allowed | not yet published |
| Revenue counted as | gross revenue inside the jurisdiction, USD, calendar year | gross revenue inside the jurisdiction, CAD, given year |
| Who counts as the producer | other: manufacturer or brand owner, brand licensee, first distributor; primary: manufacturer or brand owner, brand licensee, first distributor; secondary: manufacturer or brand owner, brand licensee, first distributor; service: manufacturer or brand owner, brand licensee, first distributor; shipping: manufacturer or brand owner, brand licensee, first distributor; tertiary: manufacturer or brand owner, brand licensee, first distributor | other: brand owner, importer; primary: brand owner, importer; secondary: brand owner, importer; service: brand owner, importer; shipping: brand owner, importer; tertiary: brand owner, importer |
Both programmes organise producer responsibility the same way: one producer responsibility organisation. The practical differences between California and Manitoba therefore sit in thresholds, fees, dates and report formats rather than in whom a producer deals with.
What California and Manitoba cover, side by side
Each row below is one published feature of the two programmes; a cell reads “not yet published” when California or Manitoba has no verified entry for it in the dataset.
| Aspect | California | Manitoba |
|---|---|---|
| Materials covered | single use packaging, plastic single use food service ware | not yet published |
| Product classes covered | primary packaging, secondary packaging, tertiary packaging, packaging components and ancillary elements | not yet published |
| Excluded from scope | medical products and drugs, animal medicines, infant formula, medical food, fifra products, dangerous goods plastic containers, hazcom hazardous or flammable products, beverage containers subject to crv, long term product protection 5 years, architectural paint program packaging, agricultural commodity packaged on site | not yet published |
| Sales channels addressed | retail, wholesale, remote offering, online | not yet published |
| Producer duty: primary packaging | manufacturer_brand_owner; licensee; first_distributor | brand_owner; importer |
| Producer duty: secondary packaging | manufacturer_brand_owner; licensee; first_distributor | brand_owner; importer |
| Producer duty: tertiary packaging | manufacturer_brand_owner; licensee; first_distributor | brand_owner; importer |
| Producer duty: shipping packaging | manufacturer_brand_owner; licensee; first_distributor | brand_owner; importer |
| Producer duty: service packaging | manufacturer_brand_owner; licensee; first_distributor | brand_owner; importer |
| Producer duty: other packaging | manufacturer_brand_owner; licensee; first_distributor | brand_owner; importer |
| Published targets | plastic_source_reduction 10 by 2027-01-01; plastic_source_reduction 20 by 2030-01-01; plastic_source_reduction 25 by 2032-01-01; plastic_recycling_rate 30 by 2028-01-01; plastic_recycling_rate 40 by 2030-01-01; plastic_recycling_rate 65 by 2032-01-01; recyclable_or_compostable_share 100 by 2032-01-01 | not yet published |
| Exemption 1 | Temporary, renewable exemption from most reporting and fee requirements for producers with gross annual California sales under $1 million. Long-term duty remains: all packaging recyclable or compostable by 2032. (application needed) | Under CAD 750,000 gross Manitoba revenue, including affiliates and franchisees |
| Exemption 2 | A person who produces, harvests and packages an agricultural commodity on the site where it was grown or raised is not a producer. | not yet published |
| Exemption 3 | Beverage containers subject to the California Beverage Container Recycling and Litter Reduction Act are not covered material. | not yet published |
| Exemption 4 | Covered material meeting a 65% (through 2026) or 70% (2027 on) recycling rate, outside curbside collection and commingled sorting, recycled at responsible end markets, is not covered material once CalRecycle approves the producer's demonstration. (application needed) | not yet published |
| Reporting categories | not yet published | 23, material category |
Thresholds and exemptions in California and Manitoba
Every verified threshold California and Manitoba publish, as each states it.
| Place | Measure | Amount | Effect | Basis as published |
|---|---|---|---|---|
| California | revenue | $1,000,000 | exempt below | gross annual sales in California, most recent calendar year |
| Manitoba | revenue | CA$750,000 | exempt below | gross Manitoba revenue including affiliates and franchisees |
| Manitoba | packaging weight | 5,000 kg | flat-fee band | A steward supplying under 5,000 kg a year may pay a flat fee instead of material fees, in two bands: 1,000 to 2,499 kg and 2,500 to 5,000 kg. The amounts are published each year and are on that year's fee schedule. |
California exemption: Temporary, renewable exemption from most reporting and fee requirements for producers with gross annual California sales under $1 million. Long-term duty remains: all packaging recyclable or compostable by 2032. It must be applied for.
California exemption: A person who produces, harvests and packages an agricultural commodity on the site where it was grown or raised is not a producer. It does not have to be applied for.
California exemption: Beverage containers subject to the California Beverage Container Recycling and Litter Reduction Act are not covered material. It does not have to be applied for.
California exemption: Covered material meeting a 65% (through 2026) or 70% (2027 on) recycling rate, outside curbside collection and commingled sorting, recycled at responsible end markets, is not covered material once CalRecycle approves the producer's demonstration. It must be applied for.
Manitoba exemption: Under CAD 750,000 gross Manitoba revenue, including affiliates and franchisees It does not have to be applied for.
Read the basis column first: the same amount can exempt a producer in one programme and only simplify its report in another.
The lowest revenue exemption is $1,000,000 in California and CA$750,000 in Manitoba ($536,557 at the Bank of Canada 2025 annual average rate). Manitoba therefore reaches smaller sellers: a business with revenue between the two lines is exempt in California but still in scope in Manitoba.
Fees per kilogram for shared materials
4 material classes have a published rate on both sides; each row shows the cheapest rate that fits the class.
| Material class | California (USD per kg) | Manitoba (CAD per kg) | Manitoba in USD, approx. | Higher fee |
|---|---|---|---|---|
| paper and board | 0.4 cents per pound | 18.23 cents per kilogram | $0.1304 | Manitoba |
| plastic | 2.5 cents per pound | 79.03 cents per kilogram | $0.5654 | Manitoba |
| glass | 0.3 cents per pound | 22.41 cents per kilogram | $0.1603 | Manitoba |
| steel | 0.8 cents per pound | 30.96 cents per kilogram | $0.2215 | Manitoba |
Scaling the cheapest published rate by weight shows what the gap between California and Manitoba amounts to for a given tonnage of one material. The amounts are the rate times the weight, nothing added.
| Material class | Kilograms | California fee (USD) | Manitoba fee (CAD) | Manitoba in USD, approx. | Manitoba minus California (USD) |
|---|---|---|---|---|---|
| paper and board | 1 | $0.01 | CA$0.18 | $0.13 | +$0.12 |
| paper and board | 10 | $0.09 | CA$1.82 | $1.30 | +$1.22 |
| paper and board | 100 | $0.88 | CA$18.23 | $13.04 | +$12.16 |
| paper and board | 1,000 | $8.82 | CA$182.30 | $130.42 | +$121.60 |
| paper and board | 10,000 | $88.18 | CA$1,823.00 | $1,304.19 | +$1,216.01 |
| paper and board | 100,000 | $881.85 | CA$18,230.00 | $13,041.92 | +$12,160.07 |
| plastic | 1 | $0.06 | CA$0.79 | $0.57 | +$0.51 |
| plastic | 10 | $0.55 | CA$7.90 | $5.65 | +$5.10 |
| plastic | 100 | $5.51 | CA$79.03 | $56.54 | +$51.03 |
| plastic | 1,000 | $55.12 | CA$790.30 | $565.39 | +$510.27 |
| plastic | 10,000 | $551.16 | CA$7,903.00 | $5,653.88 | +$5,102.73 |
| plastic | 100,000 | $5,511.56 | CA$79,030.00 | $56,538.85 | +$51,027.29 |
| glass | 1 | $0.01 | CA$0.22 | $0.16 | +$0.15 |
| glass | 10 | $0.07 | CA$2.24 | $1.60 | +$1.54 |
| glass | 100 | $0.66 | CA$22.41 | $16.03 | +$15.37 |
| glass | 1,000 | $6.61 | CA$224.10 | $160.32 | +$153.71 |
| glass | 10,000 | $66.14 | CA$2,241.00 | $1,603.23 | +$1,537.09 |
| glass | 100,000 | $661.39 | CA$22,410.00 | $16,032.34 | +$15,370.95 |
| steel | 1 | $0.02 | CA$0.31 | $0.22 | +$0.20 |
| steel | 10 | $0.18 | CA$3.10 | $2.21 | +$2.04 |
| steel | 100 | $1.76 | CA$30.96 | $22.15 | +$20.39 |
| steel | 1,000 | $17.64 | CA$309.60 | $221.49 | +$203.85 |
| steel | 10,000 | $176.37 | CA$3,096.00 | $2,214.91 | +$2,038.54 |
| steel | 100,000 | $1,763.70 | CA$30,960.00 | $22,149.09 | +$20,385.39 |
Converted from CAD to USD at the Bank of Canada annual average for 2025. A converted figure is approximate and moves with the year of the rate; the published amount is the one in the programme’s own currency.
Manitoba: the 2027 fee schedule of Recycle Manitoba, effective January 1, 2027, is the source of the per-kilogram rates used on this page.
California: the 2026 fee schedule of Circular Action Alliance (California PRO), early fee, effective January 1, 2026, is the source of the per-kilogram rates used on this page.
California 2026: the category “Paper/Fiber” is published at 0.4 cents per pound.
California 2026: the category “Plastic - Flexible” is published at 2.5 cents per pound.
California 2026: the category “Glass and Ceramics” is published at 0.3 cents per pound.
California 2026: the category “Metal” is published at 0.8 cents per pound.
Manitoba 2027: the category “Boxboard” is published at 18.23 cents per kilogram.
Manitoba 2027: the category “Plastic Film” is published at 79.03 cents per kilogram.
Manitoba 2027: the category “Coloured Glass” is published at 22.41 cents per kilogram.
Manitoba 2027: the category “Steel Food & Beverage Cans” is published at 30.96 cents per kilogram.
Real packs usually land in a dearer category, so use the calculator for California and Manitoba.
Deadlines in California and Manitoba
Each verified date, with the period it covers when one is given.
| Place | Kind | Date | Covers |
|---|---|---|---|
| California | registration | January 1, 2027 | not yet published |
| California | taxonomy update | January 1, 2027 | not yet published |
| Manitoba | report | May 31 | the previous calendar year |
| Manitoba | payment | January 31 | each quarter |
| Manitoba | registration | December 1 | voluntary producer agreement |
Penalties in California and Manitoba
What each side has published; a side without an amount says so.
California penalty for failure to comply with the chapter or its regulations: up to $50,000 per day per violation.
Report formats in California and Manitoba
How the report file for California compares with the one for Manitoba.
| Aspect | California | Manitoba |
|---|---|---|
| Layout | California SB 54 producer data by covered material category 2026-09-29 (built from PRC 42052(a)(1) and CalRecycle guidance of 4 August 2026) | Recycle Manitoba annual report Fee-year categories, reviewed 2026-09-29 |
| Recipient | Circular Action Alliance (PRO) or CalRecycle through PEPRS for self-reporting producers | Recycle Manitoba (MMSM) |
| How it is submitted | CAA producer portal, or CalRecycle PEPRS when the producer reports directly. The customer signs in and submits. | WeRecycle Portal |
| File type | csv | csv |
| Encoding | utf-8 | utf-8 |
| Delimiter | , | , |
| Decimal separator | . | |
| Columns | 5 | 4 |
| Required columns | 5 of 5 | 4 of 4 |
| Weight unit | lb | kg |
| Period basis | calendar year | calendar year |
The two layouts share a file type and a delimiter, but each programme names its own columns and categories, so one file cannot be sent to both programmes. Each report is built from the same underlying measurements and exported separately.
Which to plan for first, California or Manitoba
Check the exemption thresholds before anything else. Manitoba reaches smaller sellers than California, so a seller that is exempt in California may still have to register in Manitoba.
Questions about comparing these two programmes
Is California or Manitoba stricter on packaging EPR?
Manitoba exempts only producers below the lower revenue floor, CA$750,000 against $1,000,000 in California. Both require producers to register. Manitoba publishes the higher per-kilogram fee in 4 of 4 shared material classes.
Do I register in both California and Manitoba?
California requires producers to register. Manitoba requires producers to register.
How do the fees per kilogram compare in California and Manitoba?
Across 4 shared material classes, Manitoba publishes the higher cheapest per-kilogram fee in 4, and California in 0. A higher fee is not the same as a stricter rule; it is simply a larger published number per kilogram.
Which deadline comes first, California or Manitoba?
The dataset does not hold a verified annual report date on both sides, so this page does not say which comes first.
How these figures are made
Sources
- calrecycle.ca.gov: packaging epr retrieved
Original wording: SB 54 establishes a new extended producer responsibility (EPR) program to manage packaging and single-use plastic food service ware products
Original wording: Circular Action Alliance has been approved to serve as the first Producer Responsibility Organization.
Original wording: This updated information will inform the next update to the Covered Material Categories List, which will be published by January 1, 2027.
- calrecycle.ca.gov: producerguidance retrieved
Original wording: PEPRS is CalRecycle’s online portal for: Producer Registration Data Submission Compliance Tracking
Original wording: Circular Action Alliance manages registration, reporting, and submissions of certain exemptions and exclusions on the producers’ behalf.
Original wording: 65% Single-Use Plastic Recycled
- leginfo.legislature.ca.gov: codes displaySection.xhtml (faces) retrieved
Original wording: a producer shall not sell, offer for sale, import, or distribute covered materials in the state unless the producer is approved to participate
Original wording: upon approval of a plan pursuant to Section 42063, or commencing January 1, 2027, whichever is sooner
- leginfo.legislature.ca.gov: codes displaySection.xhtml (faces) retrieved
Original wording: The owner or operator of the online marketplace shall not be considered the retailer or wholesaler for such sales.
Original wording: the producer of the covered material is the person who sells, offers for sale, or distributes the product that uses the covered material
Original wording: “Producer” does not include a person who produces, harvests, and packages an agricultural commodity on the site where the agricultural commodity was grown or raised.
Original wording: the sale of covered materials shall be deemed to occur in the state if the covered materials are delivered to the purchaser in the state
- www2.calrecycle.ca.gov: 138910 retrieved
Original wording: Enter the amount of total gross annual sales (U.S. dollar) in California, as found on the most recent calendar year's tax returns.
- calrecycle.ca.gov: exemptionsexclusions retrieved
Original wording: Small producers with gross annual sales of less than $1 million may apply to be exempt from most of the law’s reporting and fee requirements.
Original wording: To apply, first register in CalRecycle’s reporting system, known as PEPRS, as a Packaging EPR producer. Then fill out the small producer exemption application.
Original wording: Achieve 65% recycling rates from 2024 to 2026, and 70% in 2027 and after
- www2.calrecycle.ca.gov: 131538 retrieved
Original wording: Beverage containers subject to the California Beverage Container Recycling and Litter Reduction Act (Division 12.1 (commencing with Section 14500)).
- leginfo.legislature.ca.gov: codes displaySection.xhtml (faces) retrieved
Original wording: an administrative civil penalty not to exceed fifty thousand dollars ($50,000) per day per violation
- recyclemanitoba.ca: 195.08 retrieved
Original wording: Packaging and Printed Paper Stewardship Regulation
- recyclemanitoba.ca: for producers retrieved
Original wording: had gross revenues of more than $750,000 from the combined sale of all its products and services in Manitoba
Original wording: Does your company have a gross Manitoba revenue greater than $750,000 in a given year?
Original wording: Is your company a Brand Owner, First Importer or Franchisor?
Original wording: A Producer is “obligated” if it and/or its Affiliates and Franchisees had gross revenues of more than $750,000
Original wording: Registered producers file an annual report of the packaging and printed paper they supplied into Manitoba during the previous calendar year.
Original wording: Quarterly payment dates Q1 January 31 Q2 April 30 Q3 July 31 Q4 October 31
Original wording: Submit by December 1 Cancel by December 1 Voluntary Producer Agreement
- recyclemanitoba.ca: epr transition retrieved
Original wording: Communities run or contract collection services and are funded for up to 80% of eligible net costs.
- recyclemanitoba.ca: Circular Materials Report to Producers 2025 retrieved
Original wording: eligible stewards (supplying less than 5,000 kg annually), can continue filing their detailed reports and paying material fee rates
- recyclemanitoba.ca: 2026CauseOfChange FeeSchedule MMSM retrieved
Original wording: 2026 Cause of Change Fee Schedule
- Bank of Canada, FXAUSDCAD (annual average 2025) retrieved
- circularactionalliance.org: CA 2026 Early Fee Schedule retrieved
Original wording: 2026 California Early Fee Schedule Fees for Program Year 2026
Original wording: Paper/Fiber $0.004 /lb
Original wording: Plastic - Flexible $0.025 /lb
Original wording: Glass and Ceramics $0.003 /lb
Original wording: Metal $0.008 /lb
- recyclemanitoba.ca: 2027CauseOfChange FeeSchedule RecycleManitoba retrieved
Original wording: RECYCLE MANITOBA FEE SCHEDULE (CENTS/KG)
Original wording: PAPER Boxboard 18.23 15.65 16.5%
Original wording: Plastic Film 79.03 73.04 8.2%
Original wording: Coloured Glass 22.41 21.66 3.5%
Original wording: Steel Food & Beverage Cans 30.96 27.88 11.0%
The free plan is enough to start. We estimate and prepare; you sign and submit.