Québec vs Washington EPR: Rules Compared
Last verified
Québec and Washington both run packaging EPR, but the rules differ. Québec exempts only producers below the lower revenue floor, CA$1,300,000 against $5,000,000 in Washington. Washington has the lower weight floor, 907.2 kg against 1 tonne in Québec. Both require producers to register. Both programmes set their first annual report for May 31.
Québec and Washington side by side
4 of 9 rows have a verified figure on each side of Québec and Washington; 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 | Québec | Washington | Stricter |
|---|---|---|---|
| Registration duty | Required | Required | Same |
| Producer organisation | one producer responsibility organisation | one producer responsibility organisation | Not comparable |
| Lowest revenue exemption | CA$1,300,000 | $5,000,000 | Québec |
| Lowest weight exemption | 1 tonne | 907.2 kg | Washington |
| First annual report date | May 31 | May 31 | Same |
| Published penalties | not yet published | 1 published | Not comparable |
| Report file | csv | csv | Not comparable |
| Paper fee, cheapest matched rate | 806.84 CAD/tonne | not yet published | Not comparable |
| Plastic fee, cheapest matched rate | 1,882.29 CAD/tonne | not yet published | Not comparable |
The lowest revenue exemption is CA$1,300,000 in Québec and $5,000,000 in Washington (CA$6,989,000 at the Bank of Canada 2025 annual average rate). Québec therefore reaches smaller sellers: a business with revenue between the two lines is exempt in Washington but still in scope in Québec.
The lowest weight exemption is 1 tonne of packaging in Québec and 907.2 kg in Washington, about 1.1 times as much in Québec as in Washington. A seller whose packaging falls between the two lines is exempt in Québec but counted in Washington.
Both programmes require a producer to register, in Québec and in Washington.
The first annual report date is the same on both sides, May 31.
Who runs the programme in Québec and Washington
Who collects and who the producer files with, in Québec and then Washington.
| Aspect | Québec | Washington |
|---|---|---|
| Regime | Regulation respecting a system of selective collection of certain residual materials (Q-2, r. 46.01) | Washington Recycling Reform Act, chapter 70A.208 RCW |
| Regulator | not yet published | Washington State Department of Ecology |
| Producers obligated | Yes | Yes |
| Registration | Required, ÉEQ declaration portal | Required, Producer registers with a PRO; the PRO registers with Ecology |
| Producer organisation | one producer responsibility organisation: Éco Entreprises Québec (ÉEQ); membership required | one producer responsibility organisation: Circular Action Alliance; membership required |
| Revenue counted as | gross revenue inside the jurisdiction, CAD, year | worldwide gross revenue, USD, prior fiscal year |
| Who counts as the producer | 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 | primary: manufacturer, brand licensee, brand owner, importer |
Both programmes organise producer responsibility the same way: one producer responsibility organisation. The practical differences between Québec and Washington therefore sit in thresholds, fees, dates and report formats rather than in whom a producer deals with.
What Québec and Washington cover, side by side
Each row below is one published feature of the two programmes; a cell reads “not yet published” when Québec or Washington has no verified entry for it in the dataset.
| Aspect | Québec | Washington |
|---|---|---|
| Materials covered | paper, plastic, metal, glass, printed paper, packaging | packaging, paper products |
| Product classes covered | containers, packaging, printed matter | packaging, paper |
| Sales channels addressed | retail, online, distance sale | physical retail, remote sale, other distribution |
| Producer duty: primary packaging | brand_owner; first_distributor; marketplace; seller | manufacturer; licensee; brand_owner; importer |
| Producer duty: secondary packaging | brand_owner; first_distributor; marketplace; seller | not yet published |
| Producer duty: tertiary packaging | brand_owner; first_distributor; marketplace; seller | not yet published |
| Producer duty: shipping packaging | brand_owner; first_distributor; marketplace; seller | not yet published |
| Producer duty: service packaging | brand_owner; first_distributor; marketplace; seller | not yet published |
| Producer duty: other packaging | brand_owner; first_distributor; marketplace; seller | not yet published |
| Reporting categories | 21, material category | not yet published |
| Labelling | 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. | not yet published |
| Exemption 1 | Under 1 tonne AND sales under 1.3 million: no report | A de minimis producer is under one ton, or under the global revenue limit, or an agricultural employer within limits. |
| Excluded from scope | not yet published | exempt materials |
| Exemption 2 | not yet published | Registered 501(c)(3) and 501(c)(4) organizations are excluded from the producer definition. |
Thresholds and exemptions in Québec and Washington
Every verified threshold Québec and Washington publish, as each states it.
| Place | Measure | Amount | Effect | Basis as published |
|---|---|---|---|---|
| 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) |
| Washington | packaging tonnage | 1 short ton | exempt below | covered materials introduced, most recent fiscal year |
| Washington | revenue | $5,000,000 | exempt below | global gross revenue, prior fiscal year |
Québec exemption: Under 1 tonne AND sales under 1.3 million: no report It does not have to be applied for.
Washington exemption: A de minimis producer is under one ton, or under the global revenue limit, or an agricultural employer within limits. It does not have to be applied for.
Washington exemption: Registered 501(c)(3) and 501(c)(4) organizations are excluded from the producer definition. 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$1,300,000 in Québec and $5,000,000 in Washington (CA$6,989,000 at the Bank of Canada 2025 annual average rate). Québec therefore reaches smaller sellers: a business with revenue between the two lines is exempt in Washington but still in scope in Québec.
The lowest weight exemption is 1 tonne of packaging in Québec and 907.2 kg in Washington, about 1.1 times as much in Québec as in Washington. A seller whose packaging falls between the two lines is exempt in Québec but counted in Washington.
Fees per kilogram for shared materials
Québec publishes per-kilogram rates in the dataset; Washington does not. The rows therefore show Québec only. Until both sides publish per-kilogram rates for the same material class, a fee comparison between Québec and Washington would mean inventing a figure, and this page does not do that.
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.
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.
Deadlines in Québec and Washington
Each verified date, with the period it covers when one is given.
| Place | Kind | Date | Covers |
|---|---|---|---|
| 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 |
| Washington | other | March 1, 2026 | not yet published |
| Washington | report | May 31, 2026 | not yet published |
| Washington | registration | July 1, 2026 | not yet published |
| Washington | other | October 1, 2028 | not yet published |
| Washington | other | March 1, 2029 | not yet published |
| Washington | other | January 1, 2030 | not yet published |
| Washington | payment | February 15, 2031 | not yet published |
| Washington | payment | February 15, 2032 | not yet published |
The first annual report date is the same on both sides, May 31.
Penalties in Québec and Washington
What each side has published; a side without an amount says so.
Washington penalty for producer violating chapter 70A.208 RCW: up to $1,000 per day.
Report formats in Québec and Washington
How the report file for Québec compares with the one for Washington.
| Aspect | Québec | Washington |
|---|---|---|
| Layout | ÉEQ annual declaration Fee-year categories, reviewed 2026-09-29 | Washington interim producer supply report by material class 2026-09-29 (interim, built from CAA guidance) |
| Recipient | Éco Entreprises Québec | Circular Action Alliance (Washington PRO) |
| How it is submitted | declaration.eeq.ca | CAA producer portal. The customer signs in and submits. |
| 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 | tonne | lb |
| 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, Québec or Washington
Check the exemption thresholds before anything else. Québec reaches smaller sellers than Washington, so a seller that is exempt in Washington may still have to register in Québec.
Questions about comparing these two programmes
Is Québec or Washington stricter on packaging EPR?
Québec exempts only producers below the lower revenue floor, CA$1,300,000 against $5,000,000 in Washington. Washington has the lower weight floor, 907.2 kg against 1 tonne in Québec. Both require producers to register. Both programmes set their first annual report for May 31.
Do I register in both Québec and Washington?
Québec requires producers to register. Washington requires producers to register.
How do the fees per kilogram compare in Québec and Washington?
The dataset does not hold per-kilogram rates for the same material class on both sides, so this page does not compare fees.
Which deadline comes first, Québec or Washington?
The first annual report date is the same on both sides, May 31.
How these figures are made
Sources
- 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
- 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
- circularactionalliance.org: washington retrieved
Original wording: required in the Recycling Reform Act
Original wording: By January 1, 2026 Washington Department of Ecology must establish and appoint the initial membership of the advisory council.
Original wording: July 1, 2026 Washington regulatory deadline for Producers to register with a PRO.
Original wording: By March 1, 2026 A PRO must register with Washington Department of Ecology on behalf of its producers.
Original wording: By May 31, 2026 Reporting (Interim State Addendum Signed & Simplified Reporting)
- app.leg.wa.gov: default retrieved
Original wording: After July 1, 2026, be a member of a producer responsibility organization registered in this state
Original wording: Has a global gross revenue, not including on-premises alcohol sales, for the prior fiscal year of
Original wording: the producer is the person that manufactures the item
Original wording: In their most recent fiscal year introduced less than one ton of covered materials
Original wording: Until January 1, 2031, less than $5,000,000
Original wording: "De minimis producer" means a producer that
Original wording: Registered 501(c)(3) charitable organizations and 501(c)(4) social welfare organizations
Original wording: By October 1, 2028, and every five years thereafter, submit a plan that meets the requirements of this chapter
Original wording: Beginning March 1, 2029, a producer that is not a member in good standing with a registered producer responsibility organization
Original wording: By January 1, 2030, or within six months of plan approval, whichever is later, implement the plan approved by the department
Original wording: No less than 75 percent of the net costs by February 15, 2031
Original wording: No less than 90 percent of the net costs by February 15, 2032, and each year thereafter
Original wording: civil penalty of up to $1,000 per violation per day on any producer who violates this chapter
Original wording: "Covered material" means packaging and paper products introduced into the state.
- ecology.wa.gov: producer responsibility organization retrieved
Original wording: The Circular Action Alliance is the PRO representing producers in Washington. We encourage all potentially obligated producers to register with CAA.
- Bank of Canada, FXAUSDCAD (annual average 2025) retrieved
The free plan is enough to start. We estimate and prepare; you sign and submit.