New Brunswick EPR obligation
Last verified
Under the rules we hold, New Brunswick has a packaging EPR obligation, and the producer is the brand owner, importer, seller, or online marketplace. The size limit on record is CA$2,000,000, so small producers may fall below it. The answer depends first on whose brand is on the packaging.
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.
Preliminary. This is what the encoded rules indicate for your answers, not legal advice. You check it, then sign and submit yourself.
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.
- 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 New Brunswick. If you have not said, the checker asks first.
- Do you sell into New Brunswick? A place where you report no sales returns not obligated.
- 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.
- 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.
- 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 New Brunswick?
The first question is whose duty it is. New Brunswick assigns the duty by packaging level, and the table shows which roles count as the producer at each level.
| Packaging level | Producer |
|---|---|
| other packaging | brand owner, importer, seller, or online marketplace |
| primary (sales) packaging | brand owner, importer, seller, or online marketplace |
| secondary packaging | brand owner, importer, seller, or online marketplace |
| service packaging | brand owner, importer, seller, or online marketplace |
| shipping packaging | brand owner, importer, seller, or online marketplace |
| tertiary (transport) packaging | brand owner, importer, seller, or online marketplace |
- New Brunswick: for other packaging the producer is the brand owner, importer, seller, or online marketplace.
- New Brunswick: for primary (sales) packaging the producer is the brand owner, importer, seller, or online marketplace.
- New Brunswick: for secondary packaging the producer is the brand owner, importer, seller, or online marketplace.
- New Brunswick: for service packaging the producer is the brand owner, importer, seller, or online marketplace.
- New Brunswick: for shipping packaging the producer is the brand owner, importer, seller, or online marketplace.
- New Brunswick: for tertiary (transport) packaging the producer is the brand owner, importer, seller, or online marketplace.
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 New Brunswick?
Where a revenue limit applies, New Brunswick counts revenue earned in the jurisdiction. The revenue figure is taken over the year. Limits are stated in CAD; a figure in another currency is converted with a published rate before it is compared.
Size limits in New Brunswick
Some rules switch the duty on or off by size. These are the limits on record for New Brunswick, each with what happens when you meet it.
The revenue limit: CA$2,000,000
New Brunswick: the revenue limit is CA$2,000,000. New Brunswick: at the revenue limit of CA$2,000,000, the producer is exempt below it. New Brunswick: the revenue rule reads, in plain words: Section 59 exemption. New Brunswick: the revenue limit is counted as follows: gross annual New Brunswick revenue.
Original wording
the producer generates less than $2,000,000 in gross annual revenue in the Province;Source: laws.gnb.ca: 2024 37
The tonnage limit: 1 tonne
New Brunswick: the tonnage limit is 1 tonne. New Brunswick: at the tonnage limit of 1 tonne, the producer is exempt below it. New Brunswick: the tonnage rule reads, in plain words: Section 59 exemption. New Brunswick: the tonnage limit is counted as follows: packaging and paper per year.
Original wording
the producer manufactures, distributes, sells or offers for sale less than one tonne of packaging and paper annually in the Province; orSource: laws.gnb.ca: 2024 37
Exemptions in New Brunswick
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 2,000,000 NB revenue, under one tonne, or a registered charity. New Brunswick: exemption 1 applies without an application.
What the rules cover in New Brunswick
A duty applies only to the packaging and the sales channels that the rules cover. This is what is on record for New Brunswick.
New Brunswick: the rules cover these sales channels: retail, online sales, and distance sales. New Brunswick: a producer may pass the duty to another party under the rules.
Every case, worked through
Below, the same engine that powers the checker is run on a set of standard cases for New Brunswick. 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$1,000,000: below the limit
Your own brand is on the goods and your revenue is CA$1,000,000, half the limit of CA$2,000,000. The figure is under the CA$2,000,000 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$2,000,000: exactly at the limit
Your own brand is on the goods and your revenue is CA$2,000,000, exactly the limit of CA$2,000,000. The rules for New Brunswick 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.
Revenue of CA$4,000,000: above the limit
Your own brand is on the goods and your revenue is CA$4,000,000, twice the limit of CA$2,000,000. The rules for New Brunswick 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 0.5 tonnes: below the limit
Your own brand is on the goods and you supply 0.5 tonnes of packaging, half the limit of 1 tonne. The figure is under the 1 tonne 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.
Packaging of 2 tonnes: above the limit
Your own brand is on the goods and you supply 2 tonnes of packaging, twice the limit of 1 tonne. The rules for New Brunswick 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 New Brunswick. You register, report and pay yourself; Instica prepares the figures and the files.
New Brunswick: registration is made with Recycle New Brunswick (stewardship board). New Brunswick: registration is made by this party: The producer.
New Brunswick: producers meet the duty through a single producer responsibility organisation. New Brunswick: the organisations on record are Circular Materials. New Brunswick: membership of an organisation is required. New Brunswick: an authorised representative is not required.
Deadlines on record
Frequently asked questions
Do I owe packaging EPR in New Brunswick?
Under the rules we hold, New Brunswick has a packaging EPR obligation, and the producer is the brand owner, importer, seller, or online marketplace. The size limit on record is CA$2,000,000, so small producers may fall below it. The answer depends first on whose brand is on the packaging.
Who is the producer in New Brunswick?
At the primary packaging level the producer is the brand owner, importer, seller, or online marketplace. The table above lists the other levels.
Is there a size limit in New Brunswick?
Yes. The limit on record is CA$2,000,000; below it the rules treat you differently, as the cases above show.
Do I have to join a producer responsibility organisation in New Brunswick?
Membership of an organisation is required. The organisations on record: Circular Materials.
Will Instica register or file for me in New Brunswick?
No. Instica measures, estimates and prepares your figures and files. You register, sign and submit each filing yourself, and Instica never stores portal credentials.
Is this legal advice?
No. This page is information about published rules and an estimate from them, not legal advice. Check the sources named beside each figure before you act.
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.
Sources
- laws.gnb.ca: 2024 37 retrieved
Original wording: the producer generates less than $2,000,000 in gross annual revenue in the Province;
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: 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: 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.
The free plan is enough to start. We estimate and prepare; you sign and submit.