Curbside Recycling is in transition from the Compensation Plan (CP) to an Extended Producer Responsibility (EPR) system.

• The CP is based on an Annual Schedule of Contributions, which is a retroactive payment to compensate municipalities for costs incurred in the year preceding the year of declaration
• EPR involves funding for the year following the declaration (prospective), to enable the PRO to pay “real-time” invoices for the system service providers

For 2025 and 2026, the funding of the two systems will overlap, with producers having to pay at the same time for costs incurred in the past (CP) and for the current year’s costs (EPR).

To help producers avoid the burden of paying for two full years in one, the Quebec government has provided for a staggered payment schedule for the last year of the CP, until 2026. The 2025 Schedule of Contributions will be the last Schedule of Contributions.

ÉEQ forecasts that the costs producers will have to pay are as follows:

• In 2024: $308 million
• In 2025: $598 million
• In 2026: $596 million

Why ?

• Increased collection and transport costs;
• Increased investment to upgrade sorting centres (MRFs);
• 100% Producer funding (including awareness programs, etc.)

The financial transition between the Compensation Plan (CP) and Extended Producer Responsibility (EPR) runs from 2024 to 2026.

This decision comes from the Quebec government, not our organization. Since we need to transition from one system to another, there is an overlap in the funding of the two systems between 2024 and 2026.

Since 2005 under the Compensation Plan (CP), and with the principle of Extended Producer Responsibility (EPR) in place since 2022, businesses marketing packaged products, containers, and printed paper are collectively responsible under the Regulation for ensuring the financing of the curbside recycling system, which includes the transition from the CP to EPR.

We know that producers are concerned about this financial transition. Although certain factors, such as inflation and the economic situation, are beyond our control, ÉEQ has several levers to mitigate the increase in curbside recycling costs and, ultimately, stabilize them:

• Bundling contracts with municipalities to achieve economies of scale
• Staggering and moderating the investment needed to upgrade the curbside recycling system
• Optimize the marketing of materials by pooling sorted volumes
• Identify new obligated producers to mitigate the impact of increased costs per producer by sharing these costs with a larger pool of producers

At this time, ÉEQ has estimates for the overall costs of curbside recycling and is not in a position to provide a precise estimate of the impact of this transition for each producer, as the amount varies according to the type of material marketed by each producer. However, it is still possible to make some very high-level projections by comparing your annual contribution with ÉEQ’s estimate of the change in costs per year to be borne by producers, which is as follows:

• 2024 : $308 M
• 2025 : $667 M
• 2026 : $622 M

This would double your costs between 2024 and 2025. However, it is very important to bear in mind that a quick pro rata can give an idea of how much you will have to pay, but is by no means a representative estimate of the final invoice.

Based on current projections, producers can expect to see a stabilization of curbside recycling in the early 2030s, once the roll-out of all our new responsibilities has been completed.

Several new responsibilities and charges for ÉEQ, including the gradual extension of service to the IC&I, will be deployed between 2025 and 2030.

Cost increases are to be expected until 2030, as regulatory responsibilities are added, after which we should see some stabilization and then maturity of the system.

To achieve economies of scale, we must first have a solid system for curbside recycling: investments must be made to enable sorting centres to achieve the desired levels of performance.

Despite this, a period of stabilization is expected in the early 2030s and it is expected that reductions in costs per ton will start to materialize from 2034 onwards.

Producers will receive 3 types of invoices during this period, namely:

• Three invoices for the contribution provided for the 2025 Schedule of Contribution, under the Compensation Plan (CP)
• A special PFP as per the ÉEQ policies, under EPR, only applicable for the 2023 and 2024 reports
• A series of 4 annual PFP quarterly invoices: as per the ÉEQ policies, under EPR, from the 1st quarter of 2025

The 2024 Special PFP invoices are issued once the 2024 report is submitted.

Invoices for the 2025 annual PFP will be issued in the autumn of 2024. These will be payable in 4 instalments from the beginning of 2025. Applicable rates will be based on reported quantities submitted in your 2024 report.

The contribution under the Schedule of Contribution will cease to exist with the end of the Compensation Plan (CP). The final payment for the 2025 Schedule of Contribution will be made in 2026.

The Annual PFP will be the only invoicing remaining once the transition is complete. It will be payable in 4 instalments (only 1 for producers eligible for a flat fee) each quarter.

• Thus, in 2026, producers will report their data for the 2025 calendar year and, in autumn 2026, once the rates have been set, they will receive their annual PFP invoicing (divided in 4 quarterly instalments, payable in 2027). The amounts paid will be used to fund the curbside recycling system in 2027

Containers, packaging and printed matter sold as products

In an effort to broaden materials subject to a fee, materials covered by the net costs paid to municipalities, short-life containers and packaging sold as products and printed matter sold as products (CP&PM products) must be reported.

CP&PM products may be grouped into different classes. The classes are not limited: they are only provided to facilitate the identification of the CP&PM products included in the broadening. Click here for examples.

Some containers, packaging and printed matter (CP&PM) are excluded from the payable contribution. You may still have to leave a trace of these CP&PM in your report. Refer to the attached table for more information.

Materials excluded from the reporting process

Companies may deduct from their report certain materials generated by their products. However, these deductions must be clearly detailed in the online reporting system, in the « Deductions » section. Companies must be able to provide supporting documents upon request.

Consult the allowable deductions related to your activity sector 

• Retailers
• Distributors
• Manufacturers
• Service companies
• Restaurants

Every year, your company must report the containers, packaging and printed matter put on Quebec’s market, by specifying, for each material subject to a fee, the actual weight and quantity.

If the total weight is inferior to 15 MT, you may follow the simplified process for low-volume producers, without having to report the materials separately.

If your company generated over 15 MT in the year, you must report the total number of kilograms for each designated material, detail the calculation method (see the « Methodology » section) and list the brands for which your company is responsible.

Go to the « Methodology » section of this guide for further details related to your activity sector.

Best practices for efficient reporting

First report

1. Determine which of your company’s activities generate designated materials that are ultimately intended for Québec consumers:
   • for example, print advertising material, containers and packaging of products sold, shopping bags and delivery packaging
     • Be sure to consider all your sales in Québec, including those shipped outside the province and then reintroduced by a retail outlet in Québec.
2. Determine whether the designated materials that are generated are your company’s responsibility:
   • for example, if your company owns the brand and is the first supplierA first supplier is a person who has a domicile or an establishment in Québec and is the first to take title, or possession, or control, in Québec, of a container, a packaging or a printed matter designated by the Schedule. in Québec
     • To determine whether your suppliers must file a report with ÉEQ, which would enable you to exclude the products sold under their brands from your own report, consult Québec’s registraire des entreprises to verify whether your suppliers have a place of business in Québec. If they do, then they are subject to the Compensation plan under the Environment Quality Act and you don’t have to report for their products.
3. Regarding products for which your company is responsible, collect the information required to establish the weight of designated materials that are generated:
   • for example, the number of units sold or distributed, the weights and the materials of the containers, packaging or printed matter:
     • Ask your suppliers to send you any information you may need: some suppliers can provide annual purchasing reports that include the quantities of each material.
     • Ask your sector association whether it has developed sector-specific tools to support you in the reporting process.
     • Take advantage of all the deductions to which you are entitled to and be sure to have adequate and verifiable supporting documents.
     • Organize the materials you are including in your report by category and subcategory.
     • Document your methodology and data sources.

For a methodology adapted to your activity sector, please choose the profile that suits you best:

Retailer

Distributor

Manufacturer

Service company

Restaurant

For future reporting:

1. Determine whether any changes to your activities may impact the materials you generate, such as:
   • new product lines and brands
   • new lines of business
   • new services (online orders, etc.)
   • new print advertising campaign
2. Determine whether new products (SKU) were considered in the report.
3. Update the weights and materials of containers, packaging and printed matter.

Below is a list of sources from which you may obtain the information you need to fill out your report.

Containers and packaging

• Purchase invoices for supplies

• Sales reports

• Information on packaging components, unitary weights

• Internal specifications on packaging and databases

• Reports from your packaging suppliers

• Third-party databases which include information on the unitary weights that companies with similar products may apply

• When no data on unitary weights is available, you may need to weigh empty packaging

Printed matter

• Purchase invoices for supplies or advertising material
• Information provided by printers to determine the type of paper used and the quantities and weights of printed matter
• Information provided by branches and franchisees to determine the quantities of generated printed matter intended for consumers

Contributing companies that put materials on the market that reach or exceed the thresholds for postconsumer recycled content may benefit from a 20% credit applied to their basic contribution for certain materials. 

Eligibility criteria for the credit

*Post-consumer recycled content

Companies that report containers, packaging and printed matter that are eligible to the credit for post-consumer recycled content have to fill out the appropriate screen in the reporting portal. 

Conditions to obtain the credit

• Data must be entered on the credit screen when preparing your report
• All supporting documentation on each material for which you are requesting a credit must be. sent in no later than the date of the first instalment of your contribution.
  • All supporting documents submitted after that date will be rejected.
•  Supporting documentation must be deemed admissible
• The company’s entire contribution must be paid according to the established payment calendar.

What supporting documentation is required?

Printed matter

• Recognized certification (e.g. FSC recycled fiber content)
• Letter of confirmation from the supplier, along with   quantities and specifications on the type of material used (the supplier must address a copy of the letter directly to ÉEQ)
• ISO 14001 standards with recycled content specifically indicated.

Containers and packaging

• Recognized certification (e.g. FSC recycled fiber content);
• Letter of confirmation from the supplier, along with   quantities and specifications on the type of material used (the supplier must address a copy of the letter directly to ÉEQ);
• ISO 14001 standards with recycled content specifically indicated;
• BNQ standard 8952-911.

How is this credit granted to my company?

Eligible companies will receive a 20% credit based on the quantities of materials for which the credit was granted on a separate invoice issued in the year following the deadline to file a report. Note that the credit is applied to the balance of the next contribution.

If you are unable to obtain information on materials weight, use the calculators approved by ÉEQ. You may also contact your association to find out whether it has developed an ÉEQ-approved calculator.

Important note

To use an ÉEQ-approved calculator, you must first contact ÉEQ’s Company Services. Only companies that are not eligible to an exemption or a flat fee rate for low-volume producers may submit a request.

Fill out the application to use a calculator.

Pay particular attention to the classification of materials to be reported, since inaccuracies can significantly impact the amount of your contribution, as well as the development of the Schedule of Contributions.

ÉEQ has released a guide that will help you classify the containers, packaging and printed matter your company put into Québec’s market, providing you with concrete examples and tips.

Go to the materials guide

To make the classification process easier, use our tool to verify whether a material is exempted or to determine the class to which it belongs.

• You may fill out your report over the course of several sessions.
• Billing contacts may also be added;  they will receive a notification email when a new invoice is available following the filing of a report.
• While other contacts may access the company’s reports and invoices, the primary contact remains responsible for the Company Report.