EPR Alberta: Single-use Products, Packaging and Printed Paper Products (PPP)

SINGLE-USE PRODUCTS, PACKAGING AND PAPER PRODUCTS

REGISTRATIONS ARE still being accepted!

Click on the link to begin the registration process. If you require assistance, please contact epr@albertarecycling.ca

PPP OVERVIEW

Each year, Alberta municipalities collect and process 197,600 tonnes of recyclable packaging and paper products from households at a cost of about $107 million, as estimated by a 2019 study.

One of the first systems of the new EPR framework is single-use products, packaging and printed paper products (PPP).

PPP includes the following materials from the residential sector:

paper products such as newspapers, packaging, cardboard, printed paper and magazines
plastics (both rigid and flexible)
metal and glass

Alberta’s EPR framework does not include PPP from the industrial, commercial and institutional sectors. PPP materials regulated under existing regulated stewardship programs (beverage containers, electronics, paint, tires, and used oil materials) are not included in EPR PPP to avoid duplicating requirements.

ARMA, as the oversight body, will be the central information hub for EPR. See below for further information related to PPP:

REGULATION & BYLAWS
POLICIES & PROCEDURES
PRODUCER OBLIGATIONS & REGISTRATION

Extended Producer Responsibility Regulation

Extended Producer Responsibility Agreement on Administration and Oversight with Alberta Environment and Protected Areas (PDF)

Government of Alberta – EPR

Single‑use Products, Packaging and Paper Products Bylaws

Hazardous and Special Products Bylaws

Procedures and Policies

Collection Service Standards

Material Guides

Supply Reporting Resources

Verification Procedure – Supply & Collection

We understand that EPR implementation will take time, and we are using a phased approach to ensure a smooth transition.

Alberta’s EPR Regulation came into effect on November 30, 2022. The government and ARMA recognize it will take time for producers to develop their EPR systems, including considerations for collection and material management.

Most producers will be required to provide verification of collection and management plans to the ARMA by October 1, 2024. Phase I of the EPR system will be operational by April 1, 2025. Additional key dates in the implementation process can be found here.

DISCOVER THE EPR Virtual Lunch And LEarn Series

FREQUENTLY ASKED QUESTIONS

Click on the icons below to go to see FAQs related to the corresponding categories.

REGISTERED COMMUNITIES

PRODUCER

PRO

PROCESSING FACILITY

FAQ: Communities (unregistered)

What is a community?

A community is a corporation controlled by a municipality or a regional services commission.

A community would fall under one of these provincial acts:

Municipal Government Act, such as city, town, village, summer village, municipal district or improvement district is a community.
A special area that falls under the Special Areas Act
A settlement that falls under the Metis Settlement Act
And a reserve that falls under the Municipal Government act

What is a Community Authority?

How will EPR work for communities that already have waste and recycling programs?

For communities that already have waste and recycling programs, producers will become responsible for the collection system of designated materials. This responsibility will be transferred to producers/PROs through a negotiation process that is facilitated with support from ARMA.

Those who registered for EPR by December 31, 2023, can expect producers/PROs to assume responsibility for these services starting in April 2025.

My community is not sure it whether it wants to participate in the EPR program. Are we required to participate?

No, a community is not required to participate in the EPR program. Likewise, should your community register to engage in service contract negotiations and change your decision, you are able to deregister from the process.

ARMA is committed to ensuring that every municipality feels confident in its decision to register and activate the EPR system in their community. As such, part of ARMA’s role as the oversight body for EPR is to provide accessible and comprehensive information to support your decision. Please email our support team at epr@albertarecycling.ca if you have questions about EPR, or would like more information about registering.

What is a PRO?

A producer responsibility organization (PRO) is a business established to contract with producers to provide collection management and administrative services to help producers meet their regulatory obligations under the Regulation.

What does the registration process look like?

The registration process for a community will look like this:

Pre-Register: Starting October 2, communities can sign up on ARMA Connect to show interest in participating in the EPR program.
Information Gathering: The community will collect the information needed to complete the registration.
Discussion: Concurrently with the previous step, communities can work with PROs to determine a mutually beneficial common collection.
Registration: If you were to participate in Phase I, the required registration information as a community participating in EPR was required by December 31, 2023. Registration information received after this date will place the community in Phase II.
Transition: Communities will work with the registered PROs to establish a contract and determine a transition plan for collection services.
Operational: Phase I of the EPR system will be operational starting April 2025.

Communities can opt-out at any time during the process.

Can a community deregister from EPR?

Yes, once a municipality registers for EPR, they are able to deregister if they choose to no longer proceed with the registration process. A community may deregister from EPR as long as they have not executed a contract with a PRO.

Our community currently handles collection complaints (such as missed pick-up, etc.) through our 311 service. What is the process for handling complaints once EPR is in place?

PROs and/or Producers will provide a telephone number and an email address where a person may submit requests for new collection containers or concerns relating to product collection.

Are there costs associated with PROs?

Yes, PROs are non-profit organizations and charge for their services to producers. Each commercial contract a producer enters with a PRO will have its own set of terms and conditions. It is up to the PRO and producer to determine the terms of their contractual agreement, including fees and payment schedule. ARMA does not set the terms of the contractual arrangements between PROs and producers.

If a community is below the revenue and material thresholds, would the community still need to register as a producer and fulfill reporting requirements, even if they are exempt from fees?

If a community is below the revenue threshold, they do not need to register as a producer, and no report is required. If a community is above the revenue threshold and below all material thresholds, then they still need to register and report.

Can a community register for multiple roles at once (for example: if a community is also a producer for PPP, are they able to register for both simultaneously)?

No, each role is a separate registration record and Communities must register separately for each role.

How will ARMA ensure accountability that a PRO's education efforts are adequate? Will PROs vet educational plans with municipalities before submitting them to ARMA?

PROs and producers will need to annually report on performance. The verification submission will include education and promotion plans, which must be submitted to ARMA by April 1, 2024, for PPP and October 1, 2024, for HSP.

My organization already has an ARMA Connect account. Is it possible to have multiple people on the same account?

Yes, the account administrator on your current ARMA Connect account can add additional users via the “Manage Users” functionality in the drop-down menu on the top right of the Program Selection page next to the current users’ name. This will allow multiple contacts to be associated with an account as well as give the account administrator the ability to specify which program and level of administrative access they have.

What happens if a municipality or indigenous community is not able to supply all the required information in the bylaws?

If a municipality or Indigenous community cannot supply all required information at the time of registration, it may delay the program start date for the community. We ask that you provide as much information as possible during registration to avoid delays.

Please get in touch with the ARMA EPR team at epr@albertarecycling.ca before submitting your registration form to discuss any information you may be lacking.

We are a community that has curbside recycling pick-up for single-family dwellings, but we do not provide curbside or bin collection to multi-family dwellings (apartment building, condos, etc.). The multi-family dwellings in our community are serviced by private contractors under contracts with multi-family dwelling owners/managers. Will the multi-family dwellings in our community be able to receive recycling services under EPR if the community registers?

Yes—if a community registers for EPR the multi-family dwellings within the community can receive recycling services under EPR. Please note that this will be dependent upon the cooperation of the independent multi-family dwelling owners/managers. The PRO will work closely with the community to educate and promote participation in EPR to the multi-family dwellings. If a community registers for EPR, multi-family dwellings in their community will be eligible to receive recycling services in Phase Two of EPR which begins October 1, 2026.

FAQ: Communities (Registered)

The regulation indicates that single-family dwelling collection is every two weeks. What if a community currently has weekly service and would like to maintain that frequency?

Single-family dwelling collection every two (2) weeks is the minimum level of service set in the regulation. A municipality would negotiate their contract with the PRO for the service level that they require.

What is a PRO?

For communities that do not have curbside collection services and need to drop off their products at a depot, as the need for additional depots grows, will more depots have to be built to fit this need and who will be responsible for building these depots?

As a need for additional depots become necessary, producers and PROs would be responsible for the cost of building and developing new service depots to meet the needs of communities and producers.

For communities that do not have curbside collection services and need help to drop off their products at a depot, will there be staff at these depots and if so, who would be employing them?

Where depots are used to fulfill EPR requirements, producers are responsible for employing any staff that are needed to operate these facilities.

Are there costs associated with PROs?

How will ARMA ensure accountability that a PRO's education efforts are adequate? Will PROs vet educational plans with municipalities before submitting them to ARMA?

Can we maintain status quo in the beginning of the transition to meet current service standards? Can the policy include proper signage, missed collection and frequency of bin pickup and types of bins at depots?

The bylaws are intended to set a minimum requirement. The common collection standards will outline additional details with respect to certain performance expectations. This could include things like signage, missed collection and frequency of bin pickups to ensure sites are properly maintained.

Some miunicipalities use a one-page information sheet for residential communications. Can this be included in the promotion and education obligations and can it be provided at no cost to the municipal residents?

ARMA does not communicate directly to consumers, as that is the responsibility of producers and/or PROs. ARMA recommends that communities and community authorities work directly with the producers/PRO to ensure there is an acceptable level of educational materials. As promotion and education could include (but not limited to) handouts for residents, producers and PROs could consider a quick printed reference guide that residents can refer to, as needed.

Do communities with depots that only receive materials need to register as processing facilities? In other words, are they considered processing facilities under the regulation?

No, a community is not required to register as a processing facility solely because the community has a depot. Depots do fall under the EPR Regulation’s definition of a processing facility in Section 1(v), as depots receive “designated materials for recycling, downcycling, treatment or disposal”. However, the EPR Regulation doesn’t require processing facilities to register and the Bylaw 2.2 (HSP and PPP) only requires processing facilities to register if they intend to process designated materials on behalf of producers.

What revenue should municipalities consider when determining whether or not they are an exempt producer from a revenue perspective?

Producers with an annual gross revenue of less than $1.5 million from products and services in Alberta qualify for an exemption under the PPP regulations.

Many of our municipalities do not have curbside collection services, so they will need to drop off their products at a depot. What frequency will products be picked up for processing from those depots?

In the Depot Collection Standards document, it will be specified that the frequency of collection must be suitable for the capacity of the provided collection containers.

When can municipalities expect to receive information on system performance?

The first performance report is scheduled for 2028. The evaluation of the system’s effectiveness will focus on how producers are meeting the material management standards. However, the performance metrics for the common collection system are not anticipated to be detailed at the level of individual municipalities but at a provincial level.

Will communities need to negotiate contracts with multiple PROs to cover both PPP and HSP? Is there a PRO who would manage both?

All registered PROs can be found on the ARMA website. There are no registered PROs operating both programs at this time.

I wanted to clarify/confirm whether Styrofoam collection and processing will be included in the new EPR regulations?

Styrofoam, or expanded polystyrene, falls under the designated Single-use Products, Packaging, and Paper Products (PPP) materials category in Alberta. Specifically, it is classified under rigid plastics and is covered under the Rigid Plastic category. Expanded polystyrene encompasses various items such as meat trays, beverage cups, packing peanuts, cushion packaging, and plastic egg cartons.

Would aluminum cans be included under the PPP material stream?

Metal recycling (under PPP) would include aluminum cans.

How many Blue Box PROs are being considered in Alberta?

Any PRO that can meet the Regulatory requirements to operate in Alberta will be able to apply to register. It is an open market, and the Regulation does not place a limit on the number of PROs that can do business in Alberta.

If a larger municipality or community authority has registered by Dec 31st, do the smaller municipalities (towns within) need to register as well, or can they be included under the community authority's registration?

If the smaller communities are not noted within the registration form, please contact ARMA with the details. We can still consider the smaller communities within if that is the intent.

When will the lists of specific accepted materials be circulated to registered communities?

ARMA has posted the HSP Material Guidelines and the PPP Material Guidelines documents on our website. These are meant to be a guide and may not be an exhaustive list.

Will ARMA have PROs specific for Mattress collections? / Will lighting products be added in Alberta?

Mattresses and Lighting are not material streams currently under the scope of the EPR Regulation.

Will PROs use our existing depots?

PROs will use existing depots and augment them with additional collection points, where possible.

What happens to my existing contracts with service providers?

This will vary depending on several variables such as the terms of the current contract, what changes, if any, the community wants to make, whether the service provider is amendable to modifications and what arrangement the community has with the PRO. This will require a discussion with all three parties together (the communities, contracted service providers, PROs).

Back to top of FAQs.

FAQ: Producer

What is a producer?

A producer supplies material (packaging, paper producers or packaging-like products) comprised of paper, glass, metal or plastic, or a combination of these materials to consumers. This includes both products and the packaging for products.

How do I know if I should register as a PPP producer?

A PPP producer is an entity that supplies materials made of paper, glass, metal, plastic, or a combination of these, to consumers. This includes both products and the packaging for products.

You might need to register as a PPP producer if:

Your annual revenue is $1.5 million or more, and
You supply more than the following amounts for residential use in Alberta per year:
a. 9 Tonnes of paper
b. 2 Tonnes of rigid plastic
c. 2 Tonnes of flexible plastic
d. 1 Tonne of glass
e. 1 Tonne of metal

What is a brand holder?

A brand holder is an organization or company that is the registrant of a trademark. If the brand/trademark is unregistered, then the organization or company that owns the intellectual property rights to the brand/ trademark is the “brand holder.”

If a brand holder is a resident of Canada, then it is the obligated producer of the PPP associated with its brands supplied to residential consumers in the province of Alberta, regardless of whether the products are supplied by a licensee of the brand owner, a distributor, retailer, or supplied directly by the brand holder to the residential consumer.

Where a producer is exempt, do the obligations for the materials for which they are the producer become the responsibility of the organization that is next in line in the producer hierarchy?

No, where a producer is exempt, the regulatory obligations do not become the responsibility of the organization that is next in the producer hierarchy. While the exempt producer remains the “producer” for those materials, they are simply exempt from certain requirements under the regulation as set out in the relevant provisions providing for the exemption.

As a producer, do I need a PRO to meet my collection and management requirements?

No, producers are not required to sign up with a PRO to meet their regulatory requirements. It is a business decision if a producer chooses to work with a PRO, and a producer can choose to meet their obligations without a PRO.

What is a PRO?

Are there costs associated with PROs?

PROs operate as not-for-profit entities and, as such, they charge producers for the services they provide. The specific terms and conditions, including fees and payment schedules, are determined within each individual contract between a PRO and a producer.

What is an aerosol container?

ARMA considers an aerosol container (associated with EPR) to be a non-refillable receptacle that contains a product and a propellant under pressure, and that is filled with a release device allowing the contents to be ejected as solid or liquid particles in suspension in a gas, or as a foam, paste, powder, liquid, or gas.

If we use a delivery company to mail our products or correspondence, who is required to report on the shipping packaging supplied to the consumer?

Each producer of Single-Use Products, Packaging and Paper Products (PPP) is required to report the PPP packaging they add to a product.

For example: a college or university bookstore plans to ship a book to a consumer in Alberta. The bookstore staff packages the book in a small box with the packing slip and inserts the box into a plastic mailer supplied by the delivery service with the required label affixed. In this scenario, the college or university is the obligated producer of the small box and packing slip and must report these materials in their supply report, whereas the delivery company is the obligated producer of the plastic mailer and label and must report these materials in their supply report.

We are a public sector institution and understand that we are a PPP producer. What information do we need to include in our supply report?

Public sector institutions, such as colleges and universities, are suppliers of Single-Use Products, Packaging and Paper Products (PPP) to consumers. They supply the designated materials to consumers on-site (e.g., food service packaging, unprinted paper in photocopiers, etc.) and off-site (e.g., mailings).

For the purposes of supply reporting, colleges, universities, and other public sector institutions must determine the total amount of designated material they supply to consumers in Alberta. One way to gather this data is by canvassing internal departments to obtain annual weights of designated materials supplied to consumers on-site and off-site.

How do newspaper producers report their supply of newspapers?

For the purpose of reporting supply data under the EPR Regulation, the weight of the newspaper, including any protective wrapping and supplemental advertisements and inserts, must be reported in the appropriate material categories.

This means that newspapers must be reported in the “paper” category, while any protective plastic wrapping must be reported as “flexible plastic.” When reporting either their total supply or the percentage of their total supply that is newspaper, a producer should only include the weight of Single-Use Products, Packaging and Paper Products (PPP) materials for which they are the producer.

For example: if flyers have a different brand holder resident in Canada than the newspaper they are supplied with, the flyer insert weight should not be reported by the newspaper producer. Instead, it is the brand holder of those flyers who is required to include the weight of those flyers in their own report.

How can I ensure that my products or packaging are collected and sent for management when I don't know where they end up once a consumer discards them?

Producers are not required to collect and manage their own branded products and materials. Instead, a producer is expected to collect and manage a portion of similar materials in Alberta. The portion of material that a producer collects and manages is known as their minimum management requirement, a total based on calculations outlined in the applicable Regulation. The calculated amount is proportionate to the weight of materials that the producer supplied into the province.

For example, a producer who supplied cardboard boxes to Alberta does not need to collect and manage those exact cardboard boxes. Rather, they need to ensure that an equivalent weight of paper to what they supplied the province is collected and managed. Almost all producers will work with producer responsibility organizations (PROs) for the purposes of meeting their obligations to collect and manage materials. PROs establish collection and management systems across Alberta for different material types. A producer can meet their obligations to collect and manage materials by entering into a contract with a PRO to provide these services on their behalf.

Can a PRO report on behalf of service providers?

During the registration process, a producer can choose a PRO registered with ARMA to handle their reporting duties. The specific terms and conditions, including fees and payment schedules, are determined within each individual contract between a PRO and a producer.

What types of food service packaging does a public sector institution need to include in its supply report?

Public sector institutions must report all branded and unbranded designated materials supplied or sold with food served in their owned and operated on-site facilities. These facilities include but are not limited to cafeterias, pubs, cafes, and in the case of a college or university, faculty offices.

It is important to consider other situations where food service-designated material packaging is supplied to consumers. For example, a college must report the packaging used in its culinary and hospitality programs that allow students to take home food prepared in class.

My institution provides self-serve hot drink machines where students and employees can serve themselves. As a PPP obligated producer, what materials from this service should be included in our supply report?

Any public sector institution, including colleges and universities, that offers a self-serve hot drink machine for students and employees (i.e., consumers) must report all the PPP materials supplied with the machine to serve the hot drinks. This includes but is not limited to, branded and unbranded single-use cups, lids, or cup sleeves.

Who is the obligated producer for PPP on unbranded products?

The supplier of the unbranded product is the obligated producer. Unbranded products are products that do not have any mark, word, name, symbol, design, device or graphical element, or any combination of these, including a registered or unregistered trademark, which identifies a product and distinguishes it from other products.

For example, a cucumber in plastic film sold at a grocery store without stickers, labelling or any other information associated with a brand is considered unbranded. The supplier of the cucumber would be the producer responsible for reporting the plastic film.

My organization already has an ARMA Connect account. Is it possible to have multiple people on the same account?

What is a first importer?

A first importer is a company that is the first to take possession or control of products entering Alberta from outside the province. The first importer of a brand becomes the obligated producer of PPP associated with imported goods if the brand owner is not a resident of Canada (also see “What is a brand holder”).

Who is going to set the penalty rates and how will those rates be set?

Penalty rates for non-compliance are outlined in the bylaws, and these are per non-compliance. Regulation contravention penalties are out of the scope of oversight by ARMA.

What is a free rider?

Free riders are producers that supply designated materials and:

a) have not registered or reported to ARMA,

b) have not established a collection and management system (if they are required to), or

c) are not operating a collection and management system (if they are required to).

Can a PRO report on behalf of a producer?

What if I don't see my PRO when I register in ARMA Connect?

If the PRO you collaborate with in other regions isn’t listed when you attempt to register in ARMA, it usually indicates they haven’t registered with us yet. Please contact your PRO and see if they plan to operate in Alberta.

Will there be a registration guide for producers?

Yes, ARMA has created an interim registration procedure for Producers.

PPP Producer Registration Procedure (Interim)

Is there a need for third party verification of producer information when they register?

No, additional measures are not required since our bylaws mandate third-party verification during the reporting process.

Does ARMA conduct a vetting process for registered PROs to ensure their viability as suitable options for producers to fulfill their regulatory requirements?

At ARMA, we perform a thorough vetting process for Producer Responsibility Organizations (PROs) to verify their compliance with the regulatory prerequisites, which include operating as a non-profit entity and confirming no affiliation with entities or individuals providing recycling or waste management services for designated materials. Nonetheless, it is crucial for producers to exercise their due diligence when choosing a PRO, as they would in any business relationship.

In the producer registration process on the producer/PRO delegation page, what is the specific meaning of the "service start date"?

This is the commencement date of your agreement with a producer. In many cases, we expect this date to be prior to April 1, 2024, allowing PROs to submit verification plans on behalf of producers.

In the producer registration process, what is the specific meaning of the "first supply date"?

This is the commencement date of your agreement with a Producer. In many cases, we expect this date to be prior to April 1, 2024, allowing PROs to submit verification plans on behalf of producers.

What information is required on the Supply Report?

The Supply Report comprises information about the quantities and types of materials supplied to Alberta within a specified time frame. The Verification Procedure will offer more detailed information about the contents of each report.

What information is required for the Management Report?

The Management Report covers the management and processing of designated materials, aligning with EPR regulation objectives. It encompasses data related to the collection, recycling, recovery, and disposal of each material type. The Verification Procedure will provide a comprehensive explanation of the contents of each report.

When do producers need to register by?

Existing producers of designated materials under EPR in Alberta will be required to register with ARMA as a Producer by March 1, 2024. Please note that joining a PRO that operates in Alberta does not mean the producer is registered in Alberta. Producers must still be registered with ARMA directly.

Is a producer that is already registered with ARMA for the Electronics/Paint/Tires/Used Oil Materials stewardship program(s) required to register again?

Yes, registration with ARMA to report as a supplier in any of Alberta’s stewardship programs is independent from the EPR-related obligation to register and report if you are also a PPP or HSP Producer. These are separate regulations. A producer can use the same ARMA Connect account and add a new registration for the PPP and/or HSP material streams under EPR. Additional users may be given access.

Is there a deadline to register with a PRO?

There is no deadline for a producer to decide on working with a PRO or not, nor selecting which PRO. However, there is a hard deadline for the submission of a verification plan—April 1, 2024 for PPP and October 1, 2024 for HSP.

To comply with this obligation by the deadline, a producer may:

a) join a PRO that is submitting a verification plan for a common collection system on behalf of their member producers; OR

b) submit their own alternative collection plan. If a producer has decided to work with a PRO, the delegation relationship must be documented in ARMA’s registry portal through your account.

When is the first supply report due?

Verified supply data is to be provided for 2022 and 2023 (one report for each year) by June 30, 2024, as a part of annual reporting. As outlined in the bylaws posted in September, Producers are required to provide verified supply data for the prior year (2022) as a part of registration (Bylaws sections 2.7(g) & 2.7(i)). To simplify the initial registration process, this more detailed requirement was deferred from the time of registration and shifted it to the same timing as when the 2023 supply data is due—June 30, 2024.

Do I need to sign up with a PRO?

No, producers are not required to sign up with a PRO, producers can meet their regulatory requirements on their own. If using a PRO, producers can also decide on which requirements to use a PRO to help meet such as supply reporting, participation in the common collection system, material management reporting. PROs registered with ARMA will be posted on our website.

Are there or will there be guidelines for what is required in a verification plan?

Yes, the bylaws currently outline what is required in the verification plan. Generally speaking, the verification plan should demonstrate that the producer has arrangements in place to meet its obligations to collect and manage Designated Materials. For further details, please refer to section 12 in the PPP bylaw or section 11 in the HSP bylaw. We have posted both Bylaws on our website.

If we don't know if we will use a PRO, are we able to register?

Yes, a Producer may register in the system even if they do not know at the time of registration whether or not they will use a PRO. They can designate a PRO at a later date if they desire.

Can a producer change PROs?

If a producer needs to switch their producer responsibility organization (PRO), this may be completed through their ARMA Connect account.

Will Third-Party verificiation be a requirement for the first supply reports due on June 30, 2024?

ARMA has waived the third-party verification requirement for the supply reports due on June 30, 2024, but will provide an attestation form to be signed and submitted along with the supply data.

Can you confirm if the revenue threshold for obligated producers is inclusive of total revenue from all sales channels or is it just revenue from sales of designated materials.

The revenue threshold for obligated producers is inclusive of total revenue for the company in Alberta from all sales channels.

What if a Producer exceeds the revenue threshold and falls above the volume threshold on only one of the designated material types?

If a producer exceeds the $1.5 million revenue threshold and surpasses the volume limit for one category of designated material, they are required to submit an annual report to ARMA. This report will include details on the supply of designated materials, collection system requirements, and material management requirements for the prior calendar year. Additionally, third-party verification of these components is required. If a producer has retained the services of a PRO, they may elect to have the PRO report on one or more of these components on their behalf. Where a producer exceeds the revenue threshold but has one category of designated material over the volume limit, they will file an annual report with ARMA. They will also be subject to management targets and required to participate in the common collection system.

Would registration and/or a PRO be required if the volume exemption is met on all designated materials?

Regarding Producers who exceed the revenue threshold but fall below the designated material threshold as specified by the Bylaws, the following obligations apply: Registration: These Producers are required to register, submit supply reports annually, and maintain associated records. Exemptions: They are not obligated to pay fees, provide material management reports, or participate in the common collection system. They have the option to register with a PRO to have them prepare and submit reports on your company’s behalf, but it’s not a requirement.

I was advised that we do not have any obligations for this recycling program. Please advise if there is anything that is required on our end to submit in order to receive this exemption.

Once you access ARMA Connect, you will be guided through the registration process, which includes a series of questions designed to determine your organization’s eligibility and requirements. If your organization qualifies for an exemption based on the responses provided during the registration process, you will receive an automated confirmation of exemption through the system.

How is ARMA addressing the situation if a Producer considers their exact gross revenue to be confidential?

ARMA asks them to provide an estimate based on the following: Estimated Annual Gross Revenue in Alberta = (P1/P2) x Canada National Gross Revenue, Where: “P1” represents the population of Alberta, as reported by Statistics Canada in the most recent official census. “P2” represents the total population of provinces and territories in Canada in which the producer sells the designated material, as reported by Statistics Canada in the most recent official census.

Company A has been in business since 1887. As per their website, in 2013, Company B, Inc. acquired The Company to become part of the Canadian operation known as Company AB. Could Company AB use 2013 as the date for the first supply date?

Yes, since the company came under new ownership in 2013, they can use 2013 as their first supply date.

What is meant by first supply date and business start date.

Business Start Date: This refers to the date of incorporation of the business, which typically corresponds to the date of incorporation in Canada. First Supply Date: This indicates the date that designated material is first supplied into Alberta. It may coincide with the business start date, or it could be the date when your organization initially began shipping products to Alberta.

A Cereal Manufacturer is a manufacturer of Private Label Products for the major Canadian Grocers/Drug and Big Box stores. Their customers (who are large retailers) are marketing their own brands and pick up all products from the manufacturer’s facility located in Ontario. Do they need to register as a Producer?

With respect to Private Label Brands, the retailers are considered the brand owner and are therefore required to register and report on the Private Label Brands. As for the registration and reporting obligations of the Cereal Manufacturer, they would register and report on brands that they manufacture and sell under their own brand name (e.g., Cereal Manufacturer Brand Cereal), when they are supplied into the Province of Alberta through any sales channel (e.g., through retail or online sales).

A Car Manufacturing and Sales Company does not sell packaging products that are intended for “residential use”, would they be exempt from Part 1 of the regulation relating to PPP materials and therefore are not required to register?

PPP is applicable to designated products that end up in the “blue box” of the residential consumer. The Car Manufacturing and Sales Company would supply (they do not necessarily have to “sell”) things like brochures (for cars, etc.), invoices (for cars that consumers purchase), invoices for car service, and they may have owner’s manuals that are provided to consumers with a car purchase. All these things would fall under PPP. They may also fall under HSP depending on the products that are used within their service department.

A Packaging Company buys bags from a manufacturer that is located in Alberta, they then send the bags to a Potato Growing Company who package the potatoes in the bag and sends them to a Retailing Company. Which company is the designated Producer?

The designated Producer will relate to the brand name of the final product to consumers, the Retailing Company is the retailer where I buy the potato, if the bag is “Retailing Company Potatoes” then the Producer is the Retailing Company, if the bag says “Potato Gowing Company Potatoes” then it would be the Potato Growing Company that is the Producer, if the bag says “Packaging Company Potatoes” or there is no brand on the packaging, then the Producer would be the Packaging Company,

When does the collection system that producers are responsible for paying officially begin?

Collection begins April 1, 2025, for HSP and for PPP Phase 1.

What is the target for producer material management requirements?

The material management requirement targets for the purpose of compliance for producers is October 2027.

I wanted to clarify/confirm whether Styrofoam collection and processing will be included in the new EPR regulations?

Would aluminum cans be included under the PPP material stream?

Metal recycling (under PPP) would include aluminum cans.

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FAQ: Pro

What is a producer responsibility organization (PRO)?

What is a brand holder?

A brand owner is an organization or company that is the registrant of a trademark. If the brand/trademark is unregistered, then the organization or company that owns the intellectual property rights to the brand/ trademark is the “brand owner.”

If a brand owner is a resident of Canada, then it is the obligated producer of the PPP associated with its brands supplied to residential consumers in the province of Alberta, regardless of whether the products are supplied by a licensee of the brand owner, a distributor, retailer, or supplied directly by the brand owner to the residential consumer.

How will ARMA ensure accountability that a PRO's education efforts are adequate?

My organization already has an ARMA Connect account. Is it possible to have multiple people on the same account?

Can a PRO report on behalf of a producer?

Will a PRO be able to register after November 17th?

A PRO must register with the authority within 30 calendar days after forming an agreement with a producer. Therefore, there is no strict deadline for registration, provided that the PRO complies with this stipulation.

Therefore, it is permissible for PROs to register after November 17th, as long as they adhere to the 30-day registration period post-agreement with a producer.

When will PRO registrations be activated?

If a PRO completes their registration in ARMA Connect by November 17, ARMA will conduct due diligence and aim to activate them before producer registration opens on November 27. Any PROs registering after November 27 will be activated following the completion of ARMA’s due diligence process for each new registration.

Does ARMA conduct a vetting process for registered PROs to ensure their viability as suitable options for producers to fulfill their regulatory requirements?

What does the supply report for packaging that is due in June consist of and what does the report look like?

In Alberta, the annual reports for EPR compliance consist of several components for the prior calendar year: a) Supply Reporting: This component includes the supply of designated materials, indicating the weight of each designated material supplied into and within the Province of Alberta. The report provides a high-level overview, detailing the total weight per material type. This is similar to the type of report prepared for RPRA. The first Supply Report is due June 30, 2024. b) Materials Management Reporting: This section entails the material management requirements, outlining the amount of designated material types that are recycled, downcycled, or advanced chemical recycled in accordance with the Regulation. Please note that this report will not be required until the Common Collection System is operational. Third-Party Verification: Both components (a) and (b) above require third-party verification to ensure accuracy and compliance. Producers who have enlisted the services of a producer responsibility organization (PRO) may opt to have a delegated PRO report on one or more components on their behalf.

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FAQ: ProCESSING FACILITY

What is a processing facility?

A processing facility processes material that was supplied to a consumer and collected by PRO.

What is required for PPP processing facilities to register with ARMA?

Processing facilities need to provide the following information when registering with ARMA:

Business information (e.g.: business name, contact information, etc.).
Processing site location(s) and contact information.
PPP materials accepted for processing at each location.
Types of processing.
Any producers or PROs the processor has contracted with.

Will a PRO be able to register after November 17th?

Therefore, it is permissible for PROs to register after November 17th, as long as they adhere to the 30-day registration period post-agreement with a producer.

Can a PRO report on behalf of service providers?

No, a PRO cannot report on behalf of service providers (processing facilities).

My organization already has an ARMA Connect account. Is it possible to have multiple people on the same account?

Is there a reporting obligation for volumes stored?

There is an obligation in the draft bylaws that the storage (or inventory) is reported annually as part of the annual reporting by the material processing facilities.

Not all processing facilities have scales to weigh the recyclable materials. Is there an option for municipalities that don't have weights on materials collected?

The reporting policy will outline ways to model or estimate the volumes of recyclable material collected when tonnage information is unavailable. The initial information required is meant to assist producers in developing the common collection system. Alternate information, such as the size of bins and frequency of collection, may be appropriate substitutions.

What happens when processing facilities can't report incoming comingled streams by materials type.

If the incoming materials are commingled, such as those collected from curbside collection, then the material would need to be tracked into the facility as mixed. The PRO or producer would still be obligated to meet the material management requirements on what materials have been separated and recycled. There is no metric for the incoming material; it is simply a metric of how much material has been managed by the processing facility.

Do communities with depots that only receive materials need to register as processing facilities? In other words, are they considered processing facilities under the regulation?

If a processing facility is outside of Alberta, do we still want them to register as a processing facility or would they automatically be considered an "exporter"?

Ideally, processing facilities located outside Alberta will register with ARMA, as this registration grants ARMA the authority to conduct audits on these facilities.

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