Reminder of registration for PPP program in New Brunswick

Member Update / Impact:

Amendments to the Designated Materials Regulation were approved in 2021, which mandate the creation of an extended producer responsibility program (EPR) for packaging and paper products (PPP) in New Brunswick.  The program will begin in 2023.  An arm’s length government agency named Recycle New Brunswick will oversee the PPP program on behalf of the government.  As a reminder, brand owners (eg: manufacturers, distributors, franchisors, sellers of PPP) must register with Recycle NB by February 11, 2022.

Registration is free and details are as follows:

• https://recyclenb.com/register for online registration OR
• https://recyclenb.com/downloads to download a form.

Background:

You do not have to register if you are a brand owner who:

• Generates less than $2 million in gross annual revenue in New Brunswick
• Manufactures, distributes, sells or offers for sale less than one tonne of packaging and paper annually in New Brunswick or
• Is a charitable organization registered under the Income Tax Act (Canada)

For those who must register, please note the following: 

It is likely that a Producer Responsibility Organization (PRO) will act as an agent on behalf of brand owners and implement a plan to ensure the proper stewardship of PPP.  The deadline for a PRO to submit a stewardship plan is October 14, 2022.  The stewardship plan must be approved by Recycle NB.  As brand owners need to register before February 11, 2022, Recycle NB noted that brand owners will not be obligated to fill out the section of the registration form related to their PRO.

Recent Advocacy:

In 2021, RCC led meetings for its members with New Brunswick’s Minister of Environment, the CEO of Recycle NB and senior Departmental staff.  During these meetings, RCC pressed its points of concern with the regulation.  Specifically, RCC raised concerns over the interpretation of regulatory definitions like ‘brand owner’ while pushing for clarity regarding the expectations involved with implementing a stewardship plan.  Despite RCC’s efforts, the PPP regulation is such that most of the clarification and detail sought by RCC will have to be resolved through the stewardship plan (submitted by the Producer Responsibility Organization). 

Next Steps:

RCC has been communicating with the potential (PROs) to ensure they understand the concerns raised by RCC.  RCC expects that its concerns will be reflected in the proposed stewardship plan when it is submitted by the successful PRO.