California vs New Brunswick EPR: Rules Compared
Last verified
California and New Brunswick both run packaging EPR, but the rules differ. California exempts only producers below the lower revenue floor, $1,000,000 against CA$2,000,000 in New Brunswick. Both require producers to register. New Brunswick publishes the higher per-kilogram fee in 5 of 5 shared material classes.
California and New Brunswick side by side
4 of 9 rows have a verified figure on each side of California and New Brunswick; 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 | New Brunswick | 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$2,000,000 | California |
| Lowest weight exemption | none recorded; see thresholds | 1 tonne | 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 | 68 cents per kilogram | New Brunswick |
| Plastic fee, cheapest matched rate | 2.5 cents per pound | 195 cents per kilogram | New Brunswick |
The lowest revenue exemption is $1,000,000 in California and CA$2,000,000 in New Brunswick ($1,430,820 at the Bank of Canada 2025 annual average rate). California therefore reaches smaller sellers: a business with revenue between the two lines is exempt in New Brunswick but still in scope in California.
Both programmes require a producer to register, in California and in New Brunswick.
Across 5 shared material classes, New Brunswick publishes the higher cheapest per-kilogram fee in 5, 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 New Brunswick
Who collects and who the producer files with, in California and then New Brunswick.
| Aspect | California | New Brunswick |
|---|---|---|
| Regime | California SB 54, Plastic Pollution Prevention and Packaging Producer Responsibility Act (Public Resources Code, Division 30, Part 3, Chapter 3.1) | Designated Materials Regulation, N.B. Reg. 2024-37 (Clean Environment Act) |
| Regulator | CalRecycle (Department of Resources Recycling and Recovery), through its PEPRS portal | Recycle New Brunswick (stewardship board) |
| Producers obligated | Yes | Yes |
| Registration | Required, PEPRS (CalRecycle Packaging Extended Producer Responsibility System) | Required, Recycle New Brunswick (stewardship board) |
| Producer organisation | one producer responsibility organisation: Circular Action Alliance; membership required | one producer responsibility organisation: Circular Materials; membership required |
| Transfer of responsibility | Not allowed | Allowed |
| Revenue counted as | gross revenue inside the jurisdiction, USD, calendar year | gross revenue inside the jurisdiction, CAD, 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, seller, online marketplace; primary: brand owner, importer, seller, online marketplace; secondary: brand owner, importer, seller, online marketplace; service: brand owner, importer, seller, online marketplace; shipping: brand owner, importer, seller, online marketplace; tertiary: brand owner, importer, seller, online marketplace |
Both programmes organise producer responsibility the same way: one producer responsibility organisation. The practical differences between California and New Brunswick therefore sit in thresholds, fees, dates and report formats rather than in whom a producer deals with.
What California and New Brunswick cover, side by side
Each row below is one published feature of the two programmes; a cell reads “not yet published” when California or New Brunswick has no verified entry for it in the dataset.
| Aspect | California | New Brunswick |
|---|---|---|
| Materials covered | single use packaging, plastic single use food service ware | paper, plastic, metal, glass, printed paper, packaging |
| Product classes covered | primary packaging, secondary packaging, tertiary packaging, packaging components and ancillary elements | packaging, paper products |
| 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 | small producers |
| Sales channels addressed | retail, wholesale, remote offering, online | retail, online, distance sale |
| Producer duty: primary packaging | manufacturer_brand_owner; licensee; first_distributor | brand_owner; importer; seller; marketplace |
| Producer duty: secondary packaging | manufacturer_brand_owner; licensee; first_distributor | brand_owner; importer; seller; marketplace |
| Producer duty: tertiary packaging | manufacturer_brand_owner; licensee; first_distributor | brand_owner; importer; seller; marketplace |
| Producer duty: shipping packaging | manufacturer_brand_owner; licensee; first_distributor | brand_owner; importer; seller; marketplace |
| Producer duty: service packaging | manufacturer_brand_owner; licensee; first_distributor | brand_owner; importer; seller; marketplace |
| Producer duty: other packaging | manufacturer_brand_owner; licensee; first_distributor | brand_owner; importer; seller; marketplace |
| 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 2,000,000 NB revenue, under one tonne, or a registered charity |
| 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 | 36, material category |
Thresholds and exemptions in California and New Brunswick
Every verified threshold California and New Brunswick 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 |
| New Brunswick | revenue | CA$2,000,000 | exempt below | gross annual New Brunswick revenue |
| New Brunswick | packaging tonnage | 1 tonne | exempt below | packaging and paper per year |
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.
New Brunswick exemption: Under CAD 2,000,000 NB revenue, under one tonne, or a registered charity 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$2,000,000 in New Brunswick ($1,430,820 at the Bank of Canada 2025 annual average rate). California therefore reaches smaller sellers: a business with revenue between the two lines is exempt in New Brunswick but still in scope in California.
Fees per kilogram for shared materials
5 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) | New Brunswick (CAD per kg) | New Brunswick in USD, approx. | Higher fee |
|---|---|---|---|---|
| paper and board | 0.4 cents per pound | 68 cents per kilogram | $0.4865 | New Brunswick |
| plastic | 2.5 cents per pound | 195 cents per kilogram | $1.395 | New Brunswick |
| glass | 0.3 cents per pound | 47 cents per kilogram | $0.3362 | New Brunswick |
| aluminium | 0.8 cents per pound | 100 cents per kilogram | $0.7154 | New Brunswick |
| steel | 0.8 cents per pound | 83 cents per kilogram | $0.5938 | New Brunswick |
Scaling the cheapest published rate by weight shows what the gap between California and New Brunswick 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) | New Brunswick fee (CAD) | New Brunswick in USD, approx. | New Brunswick minus California (USD) |
|---|---|---|---|---|---|
| paper and board | 1 | $0.01 | CA$0.68 | $0.49 | +$0.48 |
| paper and board | 10 | $0.09 | CA$6.80 | $4.86 | +$4.78 |
| paper and board | 100 | $0.88 | CA$68.00 | $48.65 | +$47.77 |
| paper and board | 1,000 | $8.82 | CA$680.00 | $486.48 | +$477.66 |
| paper and board | 10,000 | $88.18 | CA$6,800.00 | $4,864.79 | +$4,776.60 |
| paper and board | 100,000 | $881.85 | CA$68,000.00 | $48,647.88 | +$47,766.03 |
| plastic | 1 | $0.06 | CA$1.95 | $1.40 | +$1.34 |
| plastic | 10 | $0.55 | CA$19.50 | $13.95 | +$13.40 |
| plastic | 100 | $5.51 | CA$195.00 | $139.50 | +$133.99 |
| plastic | 1,000 | $55.12 | CA$1,950.00 | $1,395.05 | +$1,339.93 |
| plastic | 10,000 | $551.16 | CA$19,500.00 | $13,950.49 | +$13,399.34 |
| plastic | 100,000 | $5,511.56 | CA$195,000.00 | $139,504.94 | +$133,993.38 |
| glass | 1 | $0.01 | CA$0.47 | $0.34 | +$0.33 |
| glass | 10 | $0.07 | CA$4.70 | $3.36 | +$3.30 |
| glass | 100 | $0.66 | CA$47.00 | $33.62 | +$32.96 |
| glass | 1,000 | $6.61 | CA$470.00 | $336.24 | +$329.63 |
| glass | 10,000 | $66.14 | CA$4,700.00 | $3,362.43 | +$3,296.29 |
| glass | 100,000 | $661.39 | CA$47,000.00 | $33,624.27 | +$32,962.88 |
| aluminium | 1 | $0.02 | CA$1.00 | $0.72 | +$0.70 |
| aluminium | 10 | $0.18 | CA$10.00 | $7.15 | +$6.98 |
| aluminium | 100 | $1.76 | CA$100.00 | $71.54 | +$69.78 |
| aluminium | 1,000 | $17.64 | CA$1,000.00 | $715.41 | +$697.77 |
| aluminium | 10,000 | $176.37 | CA$10,000.00 | $7,154.10 | +$6,977.73 |
| aluminium | 100,000 | $1,763.70 | CA$100,000.00 | $71,540.99 | +$69,777.29 |
| steel | 1 | $0.02 | CA$0.83 | $0.59 | +$0.58 |
| steel | 10 | $0.18 | CA$8.30 | $5.94 | +$5.76 |
| steel | 100 | $1.76 | CA$83.00 | $59.38 | +$57.62 |
| steel | 1,000 | $17.64 | CA$830.00 | $593.79 | +$576.15 |
| steel | 10,000 | $176.37 | CA$8,300.00 | $5,937.90 | +$5,761.53 |
| steel | 100,000 | $1,763.70 | CA$83,000.00 | $59,379.02 | +$57,615.33 |
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.
New Brunswick: the 2027 fee schedule of Circular Materials New Brunswick (Recycle NB), 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.
New Brunswick 2027: the category “Boxboard and Other Paper Packaging” is published at 68 cents per kilogram.
New Brunswick 2027: the category “LDPE/HDPE Film” is published at 195 cents per kilogram.
New Brunswick 2027: the category “Clear Glass” is published at 47 cents per kilogram.
New Brunswick 2027: the category “Aluminum Food Containers” is published at 100 cents per kilogram.
New Brunswick 2027: the category “Other Steel Containers and Packaging” is published at 83 cents per kilogram.
Real packs usually land in a dearer category, so use the calculator for California and New Brunswick.
Deadlines in California and New Brunswick
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 |
| New Brunswick | report | May 31 | the previous calendar year |
| New Brunswick | registration | June 30, 2025 | not yet published |
| New Brunswick | plan | June 30, 2025 | not yet published |
Penalties in California and New Brunswick
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 New Brunswick
How the report file for California compares with the one for New Brunswick.
| Aspect | California | New Brunswick |
|---|---|---|
| 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) | New Brunswick producer annual report Fee-year categories, reviewed 2026-09-29 |
| Recipient | Circular Action Alliance (PRO) or CalRecycle through PEPRS for self-reporting producers | Recycle NB / Circular Materials |
| 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 New Brunswick
Check the exemption thresholds before anything else. California reaches smaller sellers than New Brunswick, so a seller that is exempt in New Brunswick may still have to register in California.
Questions about comparing these two programmes
Is California or New Brunswick stricter on packaging EPR?
California exempts only producers below the lower revenue floor, $1,000,000 against CA$2,000,000 in New Brunswick. Both require producers to register. New Brunswick publishes the higher per-kilogram fee in 5 of 5 shared material classes.
Do I register in both California and New Brunswick?
California requires producers to register. New Brunswick requires producers to register.
How do the fees per kilogram compare in California and New Brunswick?
Across 5 shared material classes, New Brunswick publishes the higher cheapest per-kilogram fee in 5, 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 New Brunswick?
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
- laws.gnb.ca: 2024 37 retrieved
Original wording: This Regulation may be cited as the Designated Materials Regulation – Clean Environment Act
Original wording: The stewardship board established by the Minister under section 22.1 of the Act, to be known as Recycle New Brunswick, is continued.
Original wording: the producer generates less than $2,000,000 in gross annual revenue in the Province;
Original wording: An application for registration shall be submitted on a form provided by the stewardship board
Original wording: On or before May 31 in each year, a producer shall submit an annual report to the stewardship board
Original wording: the brand holder of the designated material if the brand holder has a permanent establishment in Canada;
Original wording: the producer manufactures, distributes, sells or offers for sale less than one tonne of packaging and paper annually in the Province; or
Original wording: A producer who was not a brand owner shall submit an application for registration referred to in section 16 no later than June 30, 2025.
Original wording: a stewardship plan under this Regulation, including the performance measures and targets referred to in section 44 , no later than June 30, 2025.
- circularmaterials.ca: Circular Materials Report to Producers 2025 retrieved
Original wording: Newspapers 74 80 -7.5%
- 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
- knowledge.werecycle.ca: Report to Producers 2026 OCT15 retrieved
Original wording: Circular Materials in New Brunswick Fee Schedule (Cents/Kg)
Original wording: Boxboard and Other Paper Packaging 68 65 4.6%
Original wording: LDPE/HDPE Film 195 187 4.3%
Original wording: Clear Glass 47 46 2.2%
Original wording: Aluminum Food Containers 100 93 7.5 %
Original wording: Other Steel Containers and Packaging 83 82 1.2%
The free plan is enough to start. We estimate and prepare; you sign and submit.