Manitoba vs Québec EPR: Rules Compared
Last verified
Manitoba and Québec both run packaging EPR, but the rules differ. Manitoba exempts only producers below the lower revenue floor, CA$750,000 against CA$1,300,000 in Québec. Both require producers to register. Both programmes set their first annual report for May 31. Québec publishes the higher per-kilogram fee in 4 of 4 shared material classes.
Manitoba and Québec side by side
5 of 9 rows have a verified figure on each side of Manitoba and Québec; 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 | Manitoba | Québec | Stricter |
|---|---|---|---|
| Registration duty | Required | Required | Same |
| Producer organisation | one producer responsibility organisation | one producer responsibility organisation | Not comparable |
| Lowest revenue exemption | CA$750,000 | CA$1,300,000 | Manitoba |
| Lowest weight exemption | none recorded; see thresholds | 1 tonne | Not comparable |
| First annual report date | May 31 | May 31 | Same |
| Published penalties | not yet published | not yet published | Not comparable |
| Report file | csv | csv | Not comparable |
| Paper fee, cheapest matched rate | 18.23 cents per kilogram | 806.84 CAD/tonne | Québec |
| Plastic fee, cheapest matched rate | 79.03 cents per kilogram | 1,882.29 CAD/tonne | Québec |
The lowest revenue exemption is CA$750,000 in Manitoba and CA$1,300,000 in Québec. Manitoba therefore reaches smaller sellers: a business with revenue between the two lines is exempt in Québec but still in scope in Manitoba.
Both programmes require a producer to register, in Manitoba and in Québec.
The first annual report date is the same on both sides, May 31.
Across 4 shared material classes, Québec publishes the higher cheapest per-kilogram fee in 4, and Manitoba 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 Manitoba and Québec
Who collects and who the producer files with, in Manitoba and then Québec.
| Aspect | Manitoba | Québec |
|---|---|---|
| Regime | Packaging and Printed Paper Stewardship Regulation, M.R. 195/2008 | Regulation respecting a system of selective collection of certain residual materials (Q-2, r. 46.01) |
| Producers obligated | Yes | Yes |
| Registration | Required, WeRecycle Portal | Required, ÉEQ declaration portal |
| Producer organisation | one producer responsibility organisation: Recycle Manitoba (MMSM); membership required | one producer responsibility organisation: Éco Entreprises Québec (ÉEQ); membership required |
| Revenue counted as | gross revenue inside the jurisdiction, CAD, given year | gross revenue inside the jurisdiction, CAD, year |
| Who counts as the producer | other: brand owner, importer; primary: brand owner, importer; secondary: brand owner, importer; service: brand owner, importer; shipping: brand owner, importer; tertiary: brand owner, importer | other: brand owner, first distributor, online marketplace, seller; primary: brand owner, first distributor, online marketplace, seller; secondary: brand owner, first distributor, online marketplace, seller; service: brand owner, first distributor, online marketplace, seller; shipping: brand owner, first distributor, online marketplace, seller; tertiary: brand owner, first distributor, online marketplace, seller |
Both programmes organise producer responsibility the same way: one producer responsibility organisation. The practical differences between Manitoba and Québec therefore sit in thresholds, fees, dates and report formats rather than in whom a producer deals with.
What Manitoba and Québec cover, side by side
Each row below is one published feature of the two programmes; a cell reads “not yet published” when Manitoba or Québec has no verified entry for it in the dataset.
| Aspect | Manitoba | Québec |
|---|---|---|
| Producer duty: primary packaging | brand_owner; importer | brand_owner; first_distributor; marketplace; seller |
| Producer duty: secondary packaging | brand_owner; importer | brand_owner; first_distributor; marketplace; seller |
| Producer duty: tertiary packaging | brand_owner; importer | brand_owner; first_distributor; marketplace; seller |
| Producer duty: shipping packaging | brand_owner; importer | brand_owner; first_distributor; marketplace; seller |
| Producer duty: service packaging | brand_owner; importer | brand_owner; first_distributor; marketplace; seller |
| Producer duty: other packaging | brand_owner; importer | brand_owner; first_distributor; marketplace; seller |
| Reporting categories | 23, material category | 21, material category |
| Exemption 1 | Under CAD 750,000 gross Manitoba revenue, including affiliates and franchisees | Under 1 tonne AND sales under 1.3 million: no report |
| Materials covered | not yet published | paper, plastic, metal, glass, printed paper, packaging |
| Product classes covered | not yet published | containers, packaging, printed matter |
| Sales channels addressed | not yet published | retail, online, distance sale |
| Labelling | not yet published | Required: Charter of the French Language: s. 51: every inscription on the product, its container or wrapping, and on documents supplied with it (directions for use, warranty certificates) must be in French; a translation may accompany it but never be more prominent than the French.; s. 51.1 and Regulation C-11, r. 9, s. 7.1 (from June 1, 2025): a registered trademark with no French version on the Canadian register may stay in another language, but any generic or descriptive words in it must appear in French on the product or on a medium permanently attached to it. |
Thresholds and exemptions in Manitoba and Québec
Every verified threshold Manitoba and Québec publish, as each states it.
| Place | Measure | Amount | Effect | Basis as published |
|---|---|---|---|---|
| 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. |
| Québec | packaging tonnage | 1 tonne | exempt below | targeted materials |
| Québec | packaging tonnage | 1 tonne | exempt below | targeted materials placed on the market |
| Québec | revenue | CA$1,300,000 | exempt below | annual sales (the fee schedule page says 1M or less, 1.3M as of 2024; the step-by-step reporting page says less than 1.3M) |
Manitoba exemption: Under CAD 750,000 gross Manitoba revenue, including affiliates and franchisees It does not have to be applied for.
Québec exemption: Under 1 tonne AND sales under 1.3 million: no report 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 CA$750,000 in Manitoba and CA$1,300,000 in Québec. Manitoba therefore reaches smaller sellers: a business with revenue between the two lines is exempt in Québec 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 | Manitoba (CAD per kg) | Québec (CAD per kg) | Higher fee |
|---|---|---|---|
| paper and board | 18.23 cents per kilogram | 806.84 CAD/tonne | Québec |
| plastic | 79.03 cents per kilogram | 1,882.29 CAD/tonne | Québec |
| glass | 22.41 cents per kilogram | 654.24 CAD/tonne | Québec |
| steel | 30.96 cents per kilogram | 703.17 CAD/tonne | Québec |
Scaling the cheapest published rate by weight shows what the gap between Manitoba and Québec amounts to for a given tonnage of one material. The amounts are the rate times the weight, nothing added.
| Material class | Kilograms | Manitoba fee (CAD) | Québec fee (CAD) | Québec minus Manitoba (CAD) |
|---|---|---|---|---|
| paper and board | 1 | CA$0.18 | CA$0.81 | +CA$0.62 |
| paper and board | 10 | CA$1.82 | CA$8.07 | +CA$6.25 |
| paper and board | 100 | CA$18.23 | CA$80.68 | +CA$62.45 |
| paper and board | 1,000 | CA$182.30 | CA$806.84 | +CA$624.54 |
| paper and board | 10,000 | CA$1,823.00 | CA$8,068.40 | +CA$6,245.40 |
| paper and board | 100,000 | CA$18,230.00 | CA$80,684.00 | +CA$62,454.00 |
| plastic | 1 | CA$0.79 | CA$1.88 | +CA$1.09 |
| plastic | 10 | CA$7.90 | CA$18.82 | +CA$10.92 |
| plastic | 100 | CA$79.03 | CA$188.23 | +CA$109.20 |
| plastic | 1,000 | CA$790.30 | CA$1,882.29 | +CA$1,091.99 |
| plastic | 10,000 | CA$7,903.00 | CA$18,822.90 | +CA$10,919.90 |
| plastic | 100,000 | CA$79,030.00 | CA$188,229.00 | +CA$109,199.00 |
| glass | 1 | CA$0.22 | CA$0.65 | +CA$0.43 |
| glass | 10 | CA$2.24 | CA$6.54 | +CA$4.30 |
| glass | 100 | CA$22.41 | CA$65.42 | +CA$43.01 |
| glass | 1,000 | CA$224.10 | CA$654.24 | +CA$430.14 |
| glass | 10,000 | CA$2,241.00 | CA$6,542.40 | +CA$4,301.40 |
| glass | 100,000 | CA$22,410.00 | CA$65,424.00 | +CA$43,014.00 |
| steel | 1 | CA$0.31 | CA$0.70 | +CA$0.39 |
| steel | 10 | CA$3.10 | CA$7.03 | +CA$3.94 |
| steel | 100 | CA$30.96 | CA$70.32 | +CA$39.36 |
| steel | 1,000 | CA$309.60 | CA$703.17 | +CA$393.57 |
| steel | 10,000 | CA$3,096.00 | CA$7,031.70 | +CA$3,935.70 |
| steel | 100,000 | CA$30,960.00 | CA$70,317.00 | +CA$39,357.00 |
Both schedules are in CAD, so the figures compare directly.
Québec: the 2027 fee schedule of Éco Entreprises Québec (ÉEQ), effective January 1, 2027, is the source of the per-kilogram rates used on this page.
Manitoba: the 2027 fee schedule of Recycle Manitoba, effective January 1, 2027, is the source of the per-kilogram rates used on this page.
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.
Québec 2027: the category “Boxboard, other paper packaging and alternative fibres” is published at 806.84 CAD/tonne.
Québec 2027: the category “HDPE and LDPE films or shopping bags” is published at 1,882.29 CAD/tonne.
Québec 2027: the category “Clear glass” is published at 654.24 CAD/tonne.
Québec 2027: the category “Steel” is published at 703.17 CAD/tonne.
Real packs usually land in a dearer category, so use the calculator for Manitoba and Québec.
Deadlines in Manitoba and Québec
Each verified date, with the period it covers when one is given.
| Place | Kind | Date | Covers |
|---|---|---|---|
| Manitoba | report | May 31 | the previous calendar year |
| Manitoba | payment | January 31 | each quarter |
| Manitoba | registration | December 1 | voluntary producer agreement |
| Québec | report | May 31, 2026 | 2026 report (supply data used for the 2027 producer financial participation, PFP 2027) |
| Québec | other | June 30, 2026 | 2026 report |
| Québec | payment | January 31, 2027 | PFP 2027 (contribution based on the 2026 report), installment 1 of 4 |
| Québec | payment | April 30, 2027 | PFP 2027 (contribution based on the 2026 report), installment 2 of 4 |
| Québec | payment | July 31, 2027 | PFP 2027 (contribution based on the 2026 report), installment 3 of 4 |
| Québec | payment | October 31, 2027 | PFP 2027 (contribution based on the 2026 report), installment 4 of 4 |
| Québec | other | May 31, 2028 | 2026 report |
The first annual report date is the same on both sides, May 31.
Penalties in Manitoba and Québec
What each side has published; a side without an amount says so.
Report formats in Manitoba and Québec
How the report file for Manitoba compares with the one for Québec.
| Aspect | Manitoba | Québec |
|---|---|---|
| Layout | Recycle Manitoba annual report Fee-year categories, reviewed 2026-09-29 | ÉEQ annual declaration Fee-year categories, reviewed 2026-09-29 |
| Recipient | Recycle Manitoba (MMSM) | Éco Entreprises Québec |
| How it is submitted | WeRecycle Portal | declaration.eeq.ca |
| File type | csv | csv |
| Encoding | utf-8 | utf-8 |
| Delimiter | , | , |
| Decimal separator | . | |
| Columns | 4 | 4 |
| Required columns | 4 of 4 | 4 of 4 |
| Weight unit | kg | tonne |
| 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, Manitoba or Québec
Check the exemption thresholds before anything else. Manitoba reaches smaller sellers than Québec, so a seller that is exempt in Québec may still have to register in Manitoba.
Questions about comparing these two programmes
Is Manitoba or Québec stricter on packaging EPR?
Manitoba exempts only producers below the lower revenue floor, CA$750,000 against CA$1,300,000 in Québec. Both require producers to register. Both programmes set their first annual report for May 31. Québec publishes the higher per-kilogram fee in 4 of 4 shared material classes.
Do I register in both Manitoba and Québec?
Manitoba requires producers to register. Québec requires producers to register.
How do the fees per kilogram compare in Manitoba and Québec?
Across 4 shared material classes, Québec publishes the higher cheapest per-kilogram fee in 4, and Manitoba 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, Manitoba or Québec?
The first annual report date is the same on both sides, May 31.
How these figures are made
Sources
- 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
- eeq.ca retrieved
Original wording: Regulation respecting a system of selective collection of certain residual materials
- eeq.ca: preparing and submitting your report step by step retrieved
Original wording: You run an online store, with or without a place of business in Quebec.
Original wording: annual sales of less than $1.3 million.
Original wording: your business generates less than one metric ton of targeted materials and has annual sales of less than $1.3 million.
- legisquebec.gouv.qc.ca: Q 2, r. 46.01 retrieved
Original wording: incombent à la personne domiciliée ou qui a un établissement au Québec qui y agit à titre de premier fournisseur, à l’exclusion du fabricant
- eeq.ca: fee schedule to help with your report retrieved
Original wording: Are a retailer with a single outlet with a floor space of less than 929 m²
Original wording: Newspapers
Original wording: 2027 Producer financial participation (PFP)
Original wording: Boxboard and other paper packaging Alternative fibers $806.84
Original wording: HDPE and LDPE plastic films or shopping bags $1,882.29
Original wording: Clear glass $654.24
Original wording: Containers, including aerosol containers $703.17
- eeq.ca: important dates for your report retrieved
Original wording: Reporting deadline: May 31, 2026
Original wording: Deadline to submit a Bonus application: June 30, 2026
- eeq.ca: les dates a retenir pour votre declaration retrieved
Original wording: Date limite pour payer chacun des quatre versements de PFP 2027 : 31 janvier 2027, 30 avril 2027, 31 juillet 2027, 31 octobre 2027
Original wording: Date limite pour formuler une demande de modifications : 31 mai 2028
- legisquebec.gouv.qc.ca: C 11 retrieved
Original wording: if a generic term or a description of the product is included in the trademark, it must appear in French on the product
- 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.