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Manitoba EPR small business

Last verified

Under the rules we hold, Manitoba has a packaging EPR obligation, and the producer is the brand owner or importer. The size limit on record is CA$750,000, so small producers may fall below it. The answer depends first on whose brand is on the packaging.

Decision card for the Manitoba packaging EPR check: who the producer is, which limits apply and what each result means.Obligation checker: Do I owe packaging EPR in Manitoba?. 40 rule fields with a source 2 size limits on record 6 cases worked throughObligation checkerDo I owe packaging EPR in Manitoba?40 rule fields with a source2 size limits on record6 cases worked through
Source: Manitoba rules in the Instica data set, last reviewed November 4, 2026

Check your own case

Choose your role, add your revenue and the packaging you supply, and the checker applies the rules this page describes to your figures. It runs in your browser and stores nothing.

Revenue
Packaging materials
Packaging levels
Whose brand is on the products

Preliminary. This is what the encoded rules indicate for your answers, not legal advice. You check it, then sign and submit yourself.

My packaging EPR check

The Instica free plan covers the threshold check, exemption tracking, the deadline calendar, packaging templates and fee sources, so you can start without paying. See what the free plan includes

How the checker reaches a result

The checker asks the same questions in the same order for every place, and it stops with a result as soon as a question settles the matter. It never fills a missing answer in for you.

  1. Whose brand is on the packaging? If it is another company's brand, you are not the producer for those goods under the roles recorded for Manitoba. If you have not said, the checker asks first.
  2. Do you sell into Manitoba? A place where you report no sales returns not obligated.
  3. Does a size limit apply? The checker compares your revenue or packaging weight with each limit on record and, where a limit is not met, returns below threshold.
  4. Is an exemption on record for your case? An exemption that is not yet verified is never assumed, and the checker asks for more data instead.
  5. Are related companies counted together? Where the rules add up affiliated companies, their figures are combined before the limits are compared.

Who is the producer in Manitoba?

The first question is whose duty it is. Manitoba assigns the duty by packaging level, and the table shows which roles count as the producer at each level.

Producer by packaging level in Manitoba
Packaging levelProducer
other packagingbrand owner or importer
primary (sales) packagingbrand owner or importer
secondary packagingbrand owner or importer
service packagingbrand owner or importer
shipping packagingbrand owner or importer
tertiary (transport) packagingbrand owner or importer

Find the row that describes you. Where more than one role appears in a row, the checker asks whose brand is on the product before it gives a result.

Does revenue matter in Manitoba?

Where a revenue limit applies, Manitoba counts revenue earned in the jurisdiction. The revenue figure is taken over the year in question. Limits are stated in CAD; a figure in another currency is converted with a published rate before it is compared.

Affiliated companies are counted together, so the revenue and tonnage of related companies add up before the limits are applied. The rules define an affiliate as follows: Affiliates and franchisees count towards the threshold.

Size limits in Manitoba

Some rules switch the duty on or off by size. These are the limits on record for Manitoba, each with what happens when you meet it.

The revenue limit: CA$750,000

Manitoba: the revenue limit is CA$750,000. Manitoba: at the revenue limit of CA$750,000, the producer is exempt below it. Manitoba: the revenue rule reads, in plain words: Obligated only above CAD 750,000 gross Manitoba revenue. Manitoba: the revenue limit is counted as follows: gross Manitoba revenue including affiliates and franchisees.

Original wording

had gross revenues of more than $750,000 from the combined sale of all its products and services in Manitoba
Paraphrase: The source sets the revenue limit at CA$750,000.

Source: recyclemanitoba.ca: for producers

The packaging weight limit: 5,000 kg

Manitoba: the packaging weight limit is 5,000 kg. Manitoba: at the packaging weight limit of 5,000 kg, a flat-fee band applies. Manitoba: the packaging weight limit of 5,000 kg applies to figures below it. Manitoba: the packaging weight limit is counted as follows: 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.

Original wording

eligible stewards (supplying less than 5,000 kg annually), can continue filing their detailed reports and paying material fee rates
Paraphrase: The source sets the packaging weight limit at 5,000 kg.

Source: recyclemanitoba.ca: Circular Materials Report to Producers 2025

Exemptions in Manitoba

An exemption removes the duty for a producer that meets its conditions. Some must be applied for; others apply on their own.

Exemption 1

Exemption 1: Under CAD 750,000 gross Manitoba revenue, including affiliates and franchisees. Manitoba: exemption 1 applies without an application.

What the rules cover in Manitoba

A duty applies only to the packaging and the sales channels that the rules cover. This is what is on record for Manitoba.

Every case, worked through

Below, the same engine that powers the checker is run on a set of standard cases for Manitoba. Each case states the input, the result and the next step. The figures are test inputs set at half, equal to and twice each recorded limit, read as of November 4, 2026; they are not rules.

Revenue of CA$375,000: below the limit

Your own brand is on the goods and your revenue is CA$375,000, half the limit of CA$750,000. The figure is under the CA$750,000 limit, so the engine returns below threshold: the exemption on record applies. Result: below threshold. Next: keep the figures that put you below the limit, and check again as you grow.

Revenue of CA$750,000: exactly at the limit

Your own brand is on the goods and your revenue is CA$750,000, exactly the limit of CA$750,000. The figure is under the CA$750,000 limit, so the engine returns below threshold: the exemption on record applies. Result: below threshold. Next: keep the figures that put you below the limit, and check again as you grow.

Revenue of CA$1,500,000: above the limit

Your own brand is on the goods and your revenue is CA$1,500,000, twice the limit of CA$750,000. The limit is met, so the engine returns obligated. Result: obligated. Next: register, report and pay as the sections below describe, and prepare your figures in a workspace.

Packaging of 2,500 kg: below the limit

Your own brand is on the goods and you supply 2,500 kg of packaging, half the limit of 5,000 kg. The rules for Manitoba set a limit that needs a figure this case does not supply, such as a different measure or unit, so the engine asks for more data. Result: more data needed. Next: supply the missing answer in the checker to get a result.

Packaging of 10,000 kg: above the limit

Your own brand is on the goods and you supply 10,000 kg of packaging, twice the limit of 5,000 kg. The rules for Manitoba set a limit that needs a figure this case does not supply, such as a different measure or unit, so the engine asks for more data. Result: more data needed. Next: supply the missing answer in the checker to get a result.

Above every limit

Your own brand is on the goods and every figure is above every limit on record. The limit is met, so the engine returns obligated. Result: obligated. Next: register, report and pay as the sections below describe, and prepare your figures in a workspace.

If you owe: what happens next

If the result is obligated, these are the steps on record for Manitoba. You register, report and pay yourself; Instica prepares the figures and the files.

Manitoba: registration is made with WeRecycle Portal. Manitoba: registration is made by this party: The obligated producer.

Manitoba: producers meet the duty through a single producer responsibility organisation. Manitoba: the organisations on record are Recycle Manitoba (MMSM). Manitoba: membership of an organisation is required. Manitoba: an authorised representative is not required.

Flat fees on record

Frequently asked questions

Do I owe packaging EPR in Manitoba?

Under the rules we hold, Manitoba has a packaging EPR obligation, and the producer is the brand owner or importer. The size limit on record is CA$750,000, so small producers may fall below it. The answer depends first on whose brand is on the packaging.

Who is the producer in Manitoba?

At the primary packaging level the producer is the brand owner or importer. The table above lists the other levels.

Is there a size limit in Manitoba?

Yes. The limit on record is CA$750,000; below it the rules treat you differently, as the cases above show.

Do I have to join a producer responsibility organisation in Manitoba?

Membership of an organisation is required. The organisations on record: Recycle Manitoba (MMSM).

Will Instica register or file for me in Manitoba?

No. Instica measures, estimates and prepares your figures and files. You register, sign and submit each filing yourself, and Instica never stores portal credentials.

How to read these figures

Every figure in the app carries a data-quality label: measured, supplier, estimated or declared. How we measure and label figures. This page is information, not legal advice.

Our reviewers.

Sources

  1. 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: Is your company a Brand Owner, First Importer or Franchisor?
    Original wording: Does your company have a gross Manitoba revenue greater than $750,000 in a given year?
    Original wording: A Producer is “obligated” if it and/or its Affiliates and Franchisees had gross revenues of more than $750,000
  2. 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
    Original wording: 1,000 - 2,499 $ 1,000 $ 900 11.1%
    Original wording: 2,500 - 5,000 $ 2,000 $ 1,900 5.3%
  3. recyclemanitoba.ca: epr transition retrieved
    Original wording: Communities run or contract collection services and are funded for up to 80% of eligible net costs.
  4. knowledge.werecycle.ca: Report to Producers 2026 OCT15 retrieved
    Original wording: 1,000 - 2,499 $1,100 $1,000 10.0%
    Original wording: 2,500 - 5,000 $2,300 $2,000 15.0%