- with readers working within the Business & Consumer Services industries
In 2025, Canadian governments and producer‑responsibility organizations ("PROs") continued advancing innovative product stewardship and extended producer responsibility ("EPR") programs, with significant developments across existing programs and the full producer transition of Ontario's Blue Box recycling system. These initiatives now span a broad range of product categories, including batteries, electronic products, lamps, hazardous and special products ("HSP"), and packaging and printed paper ("PPP").
This article is the latest installment of Gowling WLG's ongoing bi-annual series that provides an overview of current developments in Canadian product stewardship and EPR programs.
This review provides updates on new and expanded initiatives, outlines key timelines, and highlights the shift from product stewardship to EPR models in the latter half of 2025. The article also offers a high-level look at emerging EPR, and stewardship initiatives expected in early 2026.
A. How did programs change in the second half of 2025, and what changes are expected in early 2026 and beyond?
(1) General
Recent developments
- As of October 2025, five PROs – Circular Materials, Éco Entreprises Québec, Multi-Material Stewardship Manitoba, SK Recycles and Recycle BC – developed Ecodesign guidelines to support greater recyclability of PPP. 1The goal of these harmonized guidelines is to provide greater clarity to the thousands of producers who market their goods in more than one province or territory across Canada, with the objective of implementing nationally harmonized guidelines across all provinces and territories in Canada by the end of 2026.
(2) British Columbia
Recent developments
- On November 21, 2025, amendments to the Recycling Regulation came into effect.2 This amendment added five new categories to the definition of "product category" – automotive products, battery-containing products (with batteries weighing no more than 5 kg, e.g. clothing, party supplies, jewelry, electronic cigarettes; and portable products designed primarily to provide an external power source, e.g. generators and power packs, and these products' accessories), canister products (e.g. aerosol, helium, and carbon dioxide canisters), large battery products (e.g. 12-V batteries that have an outer case), and medical sharp products.3 This amendment also requires all producers of products captured within this expanded definition to submit an EPR plan.4 Now, the only exceptions to this requirement are for producers of electronic products and small producers of PPP.5
(3) Saskatchewan
Recent developments
- On September 4, 2025, the Electronic Equipment Stewardship Program Regulations came into force under the Environmental Management and Protection Act, 2010, amending the former Electronic Equipment Stewardship Regulations.6 As a result, "electronic equipment" such as computers, cellphones, and small appliances, are now regulated under the EPR framework of the Act.7
- The Regulations require producers to operate or join an approved product stewardship program that governs the collection and recycling of listed electronic equipment. The Regulations also set out detailed obligations regarding program approval, operational requirements, collection, targets, reporting, and oversight, ensuring that electronic equipment is collected, recycled, and managed in a manner that minimizes environmental impact.
- The Electronic Products Recycling Association (EPRA) has announced that further details related to the product expansion from the amended Electronic Equipment Stewardship Program Regulations will be communicated in 2026.8
(4) Ontario
Recent developments
- Pursuant to recent amendments to the Blue Box Regulation, effective September 3, 2025, PROs must now offer to provide Blue Box services to First Nation communities "as soon as practicable," replacing the previous requirement to do so in six months. Separately, effective January 1, 2026, the management requirement for flexible plastics was reduced from 25% to 10% for the 2026 and 2027 performance years.9
- On September 29, 2025, the Resource Productivity & Recovery Authority ("RPRA") opened consultations on 2026 fee rates for Ontario's EPR programs, proposing fee hikes for tires, batteries, HSP, and blue box materials, plus new late fees starting January 1, 2026.10 Following stakeholder consultation, RPRA applied program surpluses to reduce proposed fee increases across several programs, including for Blue Box (from 41.8% to 30%), tires (from 3.7% to 3.0%), and Excess Soil (from 40% to 12%).11
- On December 11, 2025, amendments to the Resource Recovery and Circular Economy Act, 2016 came into force.12 These amendments authorize the Minister to require producers with resource recovery and waste reduction obligations under the Act to provide specified information, including contracts, agreements, and invoices related to the fulfillment of those obligations, as well as financial information regarding associated costs, fees, and revenues.13 The amendments also broaden the scope of entities that may be assigned recycling obligations, extending responsibility to certain businesses that may not traditionally have been classified as producers, but that have contractual arrangements related to products or packaging subject to recycling obligations under the Act.14
- On December 31, 2025, the Blue Box program managed by Stewardship Ontario ceased operations. Effective January 1, 2026, all Ontario municipalities and eligible First Nation communities transitioned from the legacy program to the province's full EPR framework.15 Under the Blue Box Regulation, producers are now fully responsible for the collection and management of Blue Box materials across Ontario, with operational and financial responsibility having shifted from municipalities to producers following a staged transition between 2023 and 2025.16
- On January 1, 2026, amendments to the Blue Box Regulation came into force. As a result, the definition of eligible residences has been expanded from single-unit homes to include multi-unit residential buildings with up to five units. Producers must establish a collection system for newly eligible residences "as soon as practicable."17
- Effective January 1, 2026, Circular Materials announced that Ontario residents can now recycle coffee cups and other hot and cold paper-based and plastic-lined beverage cups. In addition, materials such as deodorant, toothpaste tubes, and ice cream tubes are now included in Ontario's EPR recycling program.18
(5) New Brunswick
Recent developments
- On January 1, 2026, EPRA New Brunswick began Phase III of its electronic waste program, adding a wide range of newly obligated product categories.19 These additions expand the program to include many common household and office-based electrical products, which are now subject to obligations pursuant to the Designated Materials Regulation.20 This includes products such as e-book readers, handheld video game systems, portable fans and air purifiers, as well as office printers and photocopiers.
- On January 1, 2026, Call2Recycle launched its battery management program under the Designated Materials Regulation.21 As a result, Environmental Handling Fees ("EHFs") now apply in New Brunswick to primary and rechargeable batteries, as well as batteries sold in and with products.22
Upcoming changes
- On November 17, 2025, Recycle NB approved Product Care's New Brunswick Lamp Stewardship Plan,23 a program requiring producers to register with Recycle NB and ensure the collection, transportation, recycling, and management of end-of-life lamps in accordance with the Designated Materials Regulation.24 Under this program, a "lamp" refers to replaceable light bulbs, including compact fluorescent lamps and incandescent lamps.25 The plan, operated by Product Care on behalf of designated producers, applies to all lamp types defined under the Regulation and provides for a province‑wide collection system. The plan will be implemented in May 2026.26
(6) Nova Scotia
Upcoming changes
- Effective April 1, 2026, Nova Scotia's Lamp Stewardship Program will expand its EHFs to include new categories such as small lamps, removable lamps sold in or with products, and string lights.27
(7) Prince Edward Island
Upcoming changes
- Effective April 1, 2026, the Government of Prince Edward Island is transitioning its Beverage Container Program to an EPR model, which will affect deposits and refunds on cans, bottles, and other beverage containers. The EPR program will be overseen by Encorp Atlantic, whose Beverage Container Stewardship Plan was approved in Fall 2025.28 The program will transition to a full deposit-refund structure, and a container recycling fee will be introduced by material type and charged by Encorp to producers to cover the costs of collection, transportation, and processing of post-consumer beverage containers.29
(8) Yukon
Recent developments
- Effective July 1, 2025, Yukon introduced new EHFs for single-use and rechargeable batteries, as well as products sold with batteries included, pursuant to the Yukon Extended Producer Responsibility Regulation.30
- On November 1, 2025, the EPR for household PPP came into effect, making Yukon the first territory in Canada to implement EPR.31
- As noted in our previous update, Product Care submitted an HSP stewardship plan for approval to the Government of Yukon in 2025. Although registration for the HSP program opened in October 2025,32 with an anticipated launch in December 2025, the Yukon Government later requested a revised plan and advised that implementation would not occur prior to August 1, 2026. The program has since been paused, though registration remains open.33
Next steps
Product stewardship and EPR programs in Canada are rapidly evolving, with new product categories, expanded responsibilities, and stricter enforcement. Companies must stay informed of these changes to ensure compliance and avoid penalties.
Footnotes
1. Circular Materials, Taking Steps Towards Canada-Wide Harmonization of Ecodesign Guidelines: Supporting Companies in the Design of More Recyclable Packaging and Paper Products.
2. Recycling Regulation, BC Reg 449/2004; Order of Lieutenant Governor in Council, October 27, 2025.
3. Recycling Regulation, BC Reg 449/2004, Sch. 2, ss. 11 and 14; Sch. 3, s. 5; and Sch. 6.
4. Order of Lieutenant Governor in Council, October 27, 2025, Appendix 3, s 1(e).
5. Order of Lieutenant Governor in Council, October 27, 2025, Appendix 3, s 4.
6. The Electronic Equipment Stewardship Program Regulations, RRS c E-10.22 Reg 10.
7. The Electronic Equipment Stewardship Program Regulations, RRS c E-10.22 Reg 10, s 4.
8. EPRA, December 2025 Steward Update.
11. RPRA, 2026 RPRA Program Fees – Consultation Report; RPRA, 2026 RPRA Program Fees Schedule
12. Legislative Assembly of Ontario, Bill 46; Resource Recovery and Circular Economy Act, 2016, SO 2016, c 12.
13. Resource Recovery and Circular Economy Act, SO 2016, c 12, s 52.1.
14. Resource Recovery and Circular Economy Act, SO 2016, c 12, s 61 and 69.1.
15. Stewardship Ontario, Stewardship Ontario Blue Box Program Ceases Operations.
16. RPRA, Blue Box Transition Schedule, Updated February 2024.
17. Amending O. Reg. 391/21 (Blue Box Regulation), O. Reg.210/25, ss. 1, 4 and 10.
18. Circular Materials, Get ready, Ontario: Recycle more than ever before starting in 2026!.
19. EPRA, New Brunswick Product Definitions and Clarifications – Revised October 2025.
20. Designated Materials Regulation, NB Reg 2024-37
21. Recycle your batteries, Canada!, Recycle Your Batteries, New Brunswick!
22. Call2Recycle, Environmental Handling Fee (EHF) Product Guide.
23. ProductCare, New Brunswick Lamp Stewardship Plan.
24. Designated Materials Regulation, NB Reg 2024-37.
25. Designated Materials Regulation, NB Reg 2024-37, s 69.
26. Designated Materials Regulation, NB Reg 2024-37, s 77(4).
27. ProductCare, Nova Scotia Environmental Handling Fees – Lights.
28. Encorp Atlantic/Atlantique, Stewardship Plan – PEI Beverage Container Program.
29. Encorp Atlantic/Atlantique, Deposits and CRFs in Prince Edward Island.
30. Call2Recycle, 2025 Environmental Handling Fees Schedule.
31. Circular Materials, Yukon to Launch First Territorial Extended Producer Responsibility Program for Recycling Packaging and Paper; Extended Producer Responsibility Regulation, YOIC 2024/19.
32. ProductCare, NOW OPEN: Yukon HSP program registration
33. ProductCare, Update on Status of Yukon HSP Program
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
