New Brunswick vs Québec EPR: Rules Compared
Last verified
New Brunswick and Québec both run packaging EPR, but the rules differ. Québec exempts only producers below the lower revenue floor, CA$1,300,000 against CA$2,000,000 in New Brunswick. Both set the lowest weight exemption at 1 tonne. Both require producers to register. Both programmes set their first annual report for May 31.
New Brunswick and Québec side by side
6 of 9 rows have a verified figure on each side of New Brunswick 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 | New Brunswick | Québec | Stricter |
|---|---|---|---|
| Registration duty | Required | Required | Same |
| Producer organisation | one producer responsibility organisation | one producer responsibility organisation | Not comparable |
| Lowest revenue exemption | CA$2,000,000 | CA$1,300,000 | Québec |
| Lowest weight exemption | 1 tonne | 1 tonne | Same |
| 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 | 68 cents per kilogram | 806.84 CAD/tonne | Québec |
| Plastic fee, cheapest matched rate | 195 cents per kilogram | 1,882.29 CAD/tonne | New Brunswick |
The lowest revenue exemption is CA$2,000,000 in New Brunswick and CA$1,300,000 in Québec. Québec therefore reaches smaller sellers: a business with revenue between the two lines is exempt in New Brunswick but still in scope in Québec.
The lowest weight exemption is the same on both sides: 1 tonne of packaging.
Both programmes require a producer to register, in New Brunswick and in Québec.
The first annual report date is the same on both sides, May 31.
Across 5 shared material classes, New Brunswick publishes the higher cheapest per-kilogram fee in 3, and Québec in 2. 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 New Brunswick and Québec
Who collects and who the producer files with, in New Brunswick and then Québec.
| Aspect | New Brunswick | Québec |
|---|---|---|
| Regime | Designated Materials Regulation, N.B. Reg. 2024-37 (Clean Environment Act) | Regulation respecting a system of selective collection of certain residual materials (Q-2, r. 46.01) |
| Regulator | Recycle New Brunswick (stewardship board) | not yet published |
| Producers obligated | Yes | Yes |
| Registration | Required, Recycle New Brunswick (stewardship board) | Required, ÉEQ declaration portal |
| Producer organisation | one producer responsibility organisation: Circular Materials; membership required | one producer responsibility organisation: Éco Entreprises Québec (ÉEQ); membership required |
| Transfer of responsibility | Allowed | not yet published |
| Revenue counted as | gross revenue inside the jurisdiction, CAD, year | gross revenue inside the jurisdiction, CAD, year |
| Who counts as the producer | 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 | 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 New Brunswick and Québec therefore sit in thresholds, fees, dates and report formats rather than in whom a producer deals with.
What New Brunswick and Québec cover, side by side
Each row below is one published feature of the two programmes; a cell reads “not yet published” when New Brunswick or Québec has no verified entry for it in the dataset.
| Aspect | New Brunswick | Québec |
|---|---|---|
| Materials covered | paper, plastic, metal, glass, printed paper, packaging | paper, plastic, metal, glass, printed paper, packaging |
| Product classes covered | packaging, paper products | containers, packaging, printed matter |
| Excluded from scope | small producers | not yet published |
| Sales channels addressed | retail, online, distance sale | retail, online, distance sale |
| Producer duty: primary packaging | brand_owner; importer; seller; marketplace | brand_owner; first_distributor; marketplace; seller |
| Producer duty: secondary packaging | brand_owner; importer; seller; marketplace | brand_owner; first_distributor; marketplace; seller |
| Producer duty: tertiary packaging | brand_owner; importer; seller; marketplace | brand_owner; first_distributor; marketplace; seller |
| Producer duty: shipping packaging | brand_owner; importer; seller; marketplace | brand_owner; first_distributor; marketplace; seller |
| Producer duty: service packaging | brand_owner; importer; seller; marketplace | brand_owner; first_distributor; marketplace; seller |
| Producer duty: other packaging | brand_owner; importer; seller; marketplace | brand_owner; first_distributor; marketplace; seller |
| Reporting categories | 36, material category | 21, material category |
| Exemption 1 | Under CAD 2,000,000 NB revenue, under one tonne, or a registered charity | Under 1 tonne AND sales under 1.3 million: no report |
| 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 New Brunswick and Québec
Every verified threshold New Brunswick and Québec publish, as each states it.
| Place | Measure | Amount | Effect | Basis as published |
|---|---|---|---|---|
| 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 |
| 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) |
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.
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$2,000,000 in New Brunswick and CA$1,300,000 in Québec. Québec therefore reaches smaller sellers: a business with revenue between the two lines is exempt in New Brunswick but still in scope in Québec.
The lowest weight exemption is the same on both sides: 1 tonne of packaging.
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 | New Brunswick (CAD per kg) | Québec (CAD per kg) | Higher fee |
|---|---|---|---|
| paper and board | 68 cents per kilogram | 806.84 CAD/tonne | Québec |
| plastic | 195 cents per kilogram | 1,882.29 CAD/tonne | New Brunswick |
| glass | 47 cents per kilogram | 654.24 CAD/tonne | Québec |
| aluminium | 100 cents per kilogram | 476.19 CAD/tonne | New Brunswick |
| steel | 83 cents per kilogram | 703.17 CAD/tonne | New Brunswick |
Scaling the cheapest published rate by weight shows what the gap between New Brunswick and Québec amounts to for a given tonnage of one material. The amounts are the rate times the weight, nothing added.
| Material class | Kilograms | New Brunswick fee (CAD) | Québec fee (CAD) | Québec minus New Brunswick (CAD) |
|---|---|---|---|---|
| paper and board | 1 | CA$0.68 | CA$0.81 | +CA$0.13 |
| paper and board | 10 | CA$6.80 | CA$8.07 | +CA$1.27 |
| paper and board | 100 | CA$68.00 | CA$80.68 | +CA$12.68 |
| paper and board | 1,000 | CA$680.00 | CA$806.84 | +CA$126.84 |
| paper and board | 10,000 | CA$6,800.00 | CA$8,068.40 | +CA$1,268.40 |
| paper and board | 100,000 | CA$68,000.00 | CA$80,684.00 | +CA$12,684.00 |
| plastic | 1 | CA$1.95 | CA$1.88 | -CA$0.07 |
| plastic | 10 | CA$19.50 | CA$18.82 | -CA$0.68 |
| plastic | 100 | CA$195.00 | CA$188.23 | -CA$6.77 |
| plastic | 1,000 | CA$1,950.00 | CA$1,882.29 | -CA$67.71 |
| plastic | 10,000 | CA$19,500.00 | CA$18,822.90 | -CA$677.10 |
| plastic | 100,000 | CA$195,000.00 | CA$188,229.00 | -CA$6,771.00 |
| glass | 1 | CA$0.47 | CA$0.65 | +CA$0.18 |
| glass | 10 | CA$4.70 | CA$6.54 | +CA$1.84 |
| glass | 100 | CA$47.00 | CA$65.42 | +CA$18.42 |
| glass | 1,000 | CA$470.00 | CA$654.24 | +CA$184.24 |
| glass | 10,000 | CA$4,700.00 | CA$6,542.40 | +CA$1,842.40 |
| glass | 100,000 | CA$47,000.00 | CA$65,424.00 | +CA$18,424.00 |
| aluminium | 1 | CA$1.00 | CA$0.48 | -CA$0.52 |
| aluminium | 10 | CA$10.00 | CA$4.76 | -CA$5.24 |
| aluminium | 100 | CA$100.00 | CA$47.62 | -CA$52.38 |
| aluminium | 1,000 | CA$1,000.00 | CA$476.19 | -CA$523.81 |
| aluminium | 10,000 | CA$10,000.00 | CA$4,761.90 | -CA$5,238.10 |
| aluminium | 100,000 | CA$100,000.00 | CA$47,619.00 | -CA$52,381.00 |
| steel | 1 | CA$0.83 | CA$0.70 | -CA$0.13 |
| steel | 10 | CA$8.30 | CA$7.03 | -CA$1.27 |
| steel | 100 | CA$83.00 | CA$70.32 | -CA$12.68 |
| steel | 1,000 | CA$830.00 | CA$703.17 | -CA$126.83 |
| steel | 10,000 | CA$8,300.00 | CA$7,031.70 | -CA$1,268.30 |
| steel | 100,000 | CA$83,000.00 | CA$70,317.00 | -CA$12,683.00 |
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.
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.
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.
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 “Aluminum” is published at 476.19 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 New Brunswick and Québec.
Deadlines in New Brunswick and Québec
Each verified date, with the period it covers when one is given.
| Place | Kind | Date | Covers |
|---|---|---|---|
| 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 |
| 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 New Brunswick and Québec
What each side has published; a side without an amount says so.
Report formats in New Brunswick and Québec
How the report file for New Brunswick compares with the one for Québec.
| Aspect | New Brunswick | Québec |
|---|---|---|
| Layout | New Brunswick producer annual report Fee-year categories, reviewed 2026-09-29 | ÉEQ annual declaration Fee-year categories, reviewed 2026-09-29 |
| Recipient | Recycle NB / Circular Materials | 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, New Brunswick or Québec
Check the exemption thresholds before anything else. Québec reaches smaller sellers than New Brunswick, so a seller that is exempt in New Brunswick may still have to register in Québec.
Questions about comparing these two programmes
Is New Brunswick or Québec stricter on packaging EPR?
Québec exempts only producers below the lower revenue floor, CA$1,300,000 against CA$2,000,000 in New Brunswick. Both set the lowest weight exemption at 1 tonne. Both require producers to register. Both programmes set their first annual report for May 31. New Brunswick publishes the higher per-kilogram fee in 3 of 5 shared material classes.
Do I register in both New Brunswick and Québec?
New Brunswick requires producers to register. Québec requires producers to register.
How do the fees per kilogram compare in New Brunswick and Québec?
Across 5 shared material classes, New Brunswick publishes the higher cheapest per-kilogram fee in 3, and Québec in 2. A higher fee is not the same as a stricter rule; it is simply a larger published number per kilogram.
Which deadline comes first, New Brunswick or Québec?
The first annual report date is the same on both sides, May 31.
How these figures are made
Sources
- 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%
- 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 and packaging, including aerosol containers $476.19
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
- 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.