Updated October 3, 2026

Guides · Canada

Selling into Canada: are you exempt from provincial packaging EPR?

Each province runs its own packaging program, with its own test for who pays. Most provinces look first for a brand owner or importer based in Canada or the province, and only then at the retailer or marketplace. A US brand shipping direct to consumers is not the first party named, which is why the residency wording matters. The small-business exemptions are generous: under C$2 million in Ontario revenue, under C$1 million or 1 tonne in British Columbia and Saskatchewan, and C$750,000 or less in Manitoba revenue. Quebec is the exception. Its program operator says a brand owner with an online store that Quebec consumers can buy from must report. This page describes the rules. It doesn't tell you whether they reach your company, which is a question for the province or its program.

The common pattern

Each province names a chain of possible obligated parties and stops at the first one that exists:

  1. The brand owner, if it's resident in Canada (Ontario, Saskatchewan), in the province (as Recycle BC and Manitoba's program describe it), or has a place of business in Quebec or sells online to Quebec consumers (Quebec).
  2. If there isn't one, the importer into the province, usually one resident there.
  3. If there isn't one, the retailer that sold the product to the consumer.
  4. In Ontario and Saskatchewan, if that retailer is a marketplace seller, the marketplace facilitator instead.

For a US brand selling from its own website, there is usually no Canadian brand owner and no importer in the province, which leaves the retailer, and the retailer is the brand itself. If the brand sells through a marketplace that qualifies as a "marketplace facilitator", the obligation can move to the marketplace. If the brand sells wholesale to a Canadian distributor or retailer, that company is often the importer. Whether a province can or will enforce its rules against a company with no presence in Canada is something the official pages don't address.

Ontario (RPRA, Blue Box Regulation)

Ontario's Blue Box Regulation (O. Reg. 391/21) is enforced by the Resource Productivity and Recovery Authority (RPRA). It covers packaging, paper products and packaging-like products supplied to consumers in Ontario.

British Columbia (Recycle BC)

BC's Recycling Regulation (B.C. Reg. 449/2004, Schedule 5) covers packaging and paper products. Recycle BC is the stewardship agency most producers join.

Saskatchewan (SK Recycles, formerly Multi-Material Stewardship Western)

Saskatchewan's Household Packaging and Paper Stewardship Program Regulations, 2023 moved the province to a program fully run and paid for by producers. The program, approved May 8, 2024, is operated by SK Recycles, previously Multi-Material Stewardship Western.

Manitoba (MMSM, now Recycle Manitoba)

Manitoba's Packaging and Printed Paper Stewardship Regulation (M.R. 195/2008) is still a shared-cost program. It's run by Multi-Material Stewardship Manitoba (MMSM), which now operates as Recycle Manitoba, with registration and reporting handled by Circular Materials.

Quebec (Éco Entreprises Québec)

Quebec's modernized curbside recycling system is run by Éco Entreprises Québec (ÉEQ), which producers must join by signing a membership contract.

Still uncertain

What to do next

  1. Pull last year's sales by province, in Canadian dollars, and estimate the packaging weight you shipped into each one.
  2. Ontario: under C$2,000,000 in Ontario revenue, you're exempt; keep the records for five years. Over it, compare your weights to RPRA's thresholds.
  3. BC and Saskatchewan: compare against C$1 million and 1 tonne. In Saskatchewan, keep the evidence, since the onus is on you.
  4. Manitoba: check the four-part test, including C$750,000 in Manitoba revenue and whether you have a presence there.
  5. Quebec: if you sell online to Quebec consumers and are over 1 tonne or the revenue figure, contact ÉEQ about registering and reporting.
  6. Work out who's in the chain for each sale: a Canadian distributor, a marketplace that ships for you, or you as the retailer. Your contracts with them may already say who reports.
  7. Where the residency question decides it, ask the program directly: RPRA, Recycle BC, SK Recycles, Recycle Manitoba (Circular Materials) or ÉEQ.

Selling in US states too? Seven states have packaging EPR laws with their own exemption tests.

Check all seven states in two minutes

Sources

General information, not legal advice. Rules change; we re-verify each season.