EPR in Alberta

Producers must submit their Supply Reports detailing the volume of designated materials supplied within the reporting period. This data is essential for tracking and managing recycling efforts across Alberta.

The inaugural supply reporting for Alberta began on June 1, 2024. Producers who have operated in the province since or before 2022 must submit supply data for the calendar years 2022 and 2023.

Below is a graph illustrating the percentage of producers who have met their reporting obligations for the 2024 reporting (2023 supply) calendar year.

Below is a graph illustrating the percentage of producers who have met their reporting obligations for the 2025 reporting (2024 supply) calendar year.

Below is a graph illustrating the percentage of producers who have met their reporting obligations for the 2026 reporting (2025 supply) calendar year as of July 31, 2026.

Percentages may fluctuate due to a time lag between a producer registering in the system and submitting their supply reporting.

To support and regulate Alberta’s EPR recycling initiatives, we have a detailed list of registered PPP and HSP producers. Registration is vital for ensuring all obligated producers are actively involved in EPR and contributing to a sustainable future.

Being registered as a Producer does not mean that: 

• An entity is, in fact, a producer; 
• The producer has reported accurately; or 
• The producer’s registration is not suspended. 

ARMA’s Compliance and Registration Team continues to work with potential producers to bring them into compliance. If you are aware of a producer not on the list, please email epr@albertarecycling.ca. 

ARMA may cancel or suspend the registration of a producer in accordance with the Extended Producer Responsibility Regulation, ARMA’s Bylaws, and/or ARMA’s Policies and Procedures.

Following the Government of Alberta’s amendment to the Extended Producer Responsibility Regulation (AR 194/2022) (EPR Regulation) through Order in Council 69/2025, ARMA has updated the following documents to reflect the exclusion of certain packaging-like products and provide clearer guidance to all EPR stakeholders: 

• PPP Bylaws 
• PPP Material Type Guide 
   

Flexible Plastic Packaging-Like Products (PLPs) Update Summary 

• Under the latest regulatory update, a narrow range of flexible plastic packaging-like products (PLPs) has been exempted. 
   
• Flexible plastic PLP means any packaging-like product made wholly of flexible plastic or that portion of a packaging-like product made of flexible plastic, where such packaging-like product has all of the following characteristics: 
  • ordinarily used for the containment, protection, or handling of food such as cling wrap, sandwich bags, and freezer bags; 
  • ordinarily disposed of after a single use, whether or not it could be reused; and 
  • not used as packaging when supplied to the end user. 
     
• This definition for flexible plastic PLPs has been added to Section 1 of the PPP Bylaws, and reference to it has been accordingly incorporated throughout. 
   
• The following updates have been made to the PPP Material Type Guide effective April 1, 2025: 
  • Exclusion of flexible plastic PLP 
  • Inclusion of recycling bags (blue bags) 

Update: Exemption for Flexible Plastic Packaging-like Products (PLPs) under the EPR Regulation 

The purpose of this notice is to inform you of a recent amendment made by the Government of Alberta to the Extended Producer Responsibility Regulation AR 194/2022 (the “EPR Regulation”) through Order in Council 69/2025. 

Under this amendment, a narrow range of flexible plastic products will no longer be subject to requirements under the EPR Regulation. 

Details of the Exemption 

The exemption applies to flexible plastic packaging-like products (PLPs) that are typically used for the containment, protection, or handling of food, such as cling wrap, sandwich bags, and freezer bags. These products will be exempt from EPR obligations if they meet the following criteria: 

• The product is ordinarily used for the containment, protection, handling, delivery, presentation, or transportation of a thing or things.
• The product is ordinarily disposed of after a single use, whether or not it could be reused. 
• The product is not used as packaging when it is supplied to the end user. 
•  

Impact on Other Flexible Plastics PLPs 

Other flexible plastic PLPs supplied for household use will remain under the EPR Regulation and will continue to be subject to the requirements. 

Effective Date of Exemption 
This exemption takes effect as of the issuance of the amendment, which is March 26, 2025. 

Fees and Obligations Prior to Exemption 

Producers of the exempted flexible plastic products will remain responsible for covering any fees incurred under the EPR Regulation, including oversight fees, from the establishment of the regulation until the exemption date. 

ARMA will be conducting an in-depth review of existing bylaws, policies and procedures for updates necessary to accommodate the regulatory update and will be communicating any revisions. Please check our website regularly for updates. 

Update: Verification Requirements for 2025 Supply Reporting 

Alberta Recycling Management Authority (ARMA) is pausing the verification requirement for 2025 supply reporting. This change is intended to reduce the administrative burden on producers while maintaining accountability and transparency in the system. 

What This Means for Producers 

No Verification Required in 2025: 

Previously, producers were required to submit verification for both their 2023 and 2024 supply data as part of the 2025 Supply Report. This verification requirement has now been paused. 

• Producers are not required to submit verification for either 2023 or 2024 supply data in 2025. 
• Instead, producers will complete and upload an attestation form, confirming the accuracy of their supply data, similar to the process used in the 2024 reporting cycle. 

2023 Supply Data – No Longer Requires Verification: 

Verification of 2023 supply data will not be required. 

• However, if a producer has already started the verification process for their 2023 supply data, they may choose to complete and submit it as part of their 2025 Supply Report. 
• If a verified 2023 report is submitted, the producer will not be required to verify 2025 data in 2026. Only 2024 supply data will need to be verified. 
• Similarly, if a producer submits verified data for both 2023 and 2024, they will not be required to verify 2025 supply data when reporting in 2026.  
• ARMA would like to recognize and thank the many producers who have already completed or begun verification for their supply reports. Your efforts and proactive approach help build a stronger, more transparent system for all participants. 

Updated Timeline for Verification: 

The first year in which verification will be required is now the 2026 Supply Report. Producers will need to verify their 2024 and 2025 supply data during the 2026 reporting cycle. 

Why This Change? 

This pause reflects ARMA’s commitment to striking a balance between regulatory integrity and reducing administrative burden. It also acknowledges ongoing economic pressures and feedback from key producer groups. 

Producer Expectations  

While this deferral reduces administrative burden, producers are still expected to provide accurate supply data. 

• Incorrect supply reporting may impact Oversight and Program Fees, leading to inequities among producers. 
• Compliance actions may be taken against producers who submit inaccurate data. 

This bulletin provides clarification regarding the responsibilities of an HSP PRO as the operator of the common collection system. 

Obligation of Compliance:

Producers must comply with the EPR Regulation, Hazardous and Special Products (HSP) Bylaws, and Verification Procedure. This includes providing a Common Collection System (CCS) at no charge to registered communities while ensuring the proper processing and disposition of collected designated materials. 
 

Producer Responsibilities:

Producer responsibilities fall into two key areas: CCS activities and post-collection activities. 

1. CCS Activities (varies by registered Community and may include one or more of the following): 

• Collection of designated materials. 
• Establishing an appropriate collection service per HSP Collection Service Standards. 
• Sortation, temporary storage, and transportation. 

2. Post-Collection Activities (may include one or more of the following): 

• Transportation, if required, to processing facilities. 
• Processing materials per regulatory requirements. 
• Data reporting to the Authority. 

Producers Are NOT Responsible For: 

• Legacy Household Hazardous Waste (HHW): Producers and PROs are not responsible for HHW stockpiled before April 1, 2025. Communities must manage pre-existing HHW outside the EPR system. 
• Non-Designated Materials: Items not listed under the EPR Regulation are not the responsibility of Producers. 

Thank you for registering with Alberta Recycling Management Authority (ARMA) as a Producer of designated materials in Alberta. 

Section 15(1)(c) under Part 1 of the EPR Regulation and section 10.1 of the PPP Bylaws provide for some exemptions for producers with an annual gross revenue in Alberta below $1,500,000.00 (the “Revenue Threshold”).  

Producers whose annual gross revenue is below $1,500,000.00 are exempt from the following obligations: 

• Oversight fees; 
• Annual supply reporting; and 
• Participation in the common collection system. 

Your organization remains subject to record-keeping requirements under the EPR Regulation and the Bylaws, including maintaining financial records and making them available for audit or inspection by ARMA. At any point, ARMA may require you to provide such financial records for audit or inspection. Such records shall include fiscal information based on the most recent corporate financial statements that demonstrate your organization’s annual gross revenue in Alberta. 

Revenue Exemption Re-Evaluation

To maintain compliance, producers are periodically required to provide updated gross revenue amounts for the purpose of re-evaluation and to confirm that your organization’s gross annual revenue in Alberta remains below the Revenue Threshold.  

If at any point your organization's gross annual revenue in Alberta exceeds the Revenue Threshold, it will no longer be exempt from the requirements of Part 1 of the EPR Regulation. You will then be required to register with ARMA and report your annual designated material supply. 

Action Required 

A system-generated notification email will be sent to the Primary User (or Account Administrator) of your organization’s ARMA Connect account this week. Log into your ARMA Connect account to complete the re-evaluation of your registration.  

• Have your annual gross revenue in Alberta for the calendar year 2024 ready for input. 
• Refer to the PPP Producer Registration Procedure to review the registration steps. 

Deadline: March 14, 2025 

Support & Assistance

Communications are sent via email to keep Producers informed on EPR in Alberta. Ensure you maintain up-to-date contact information on your ARMA Connect portal account to receive the latest bulletins and notices.

Update to Designated Material Collection  

Status Quo for April 1, 2025: Phase I Communities will maintain their current materials collection as per their pre-EPR services for PPP. This approach ensures service continuity and minimizes disruptions. 

Phased Transition by 2027: Per the EPR Regulation, designated materials will be incorporated gradually, with Producers/PROs expanding collection based on operational readiness. The 2027 targets serve as the final compliance benchmark. 

Community and Resident Education: The phased approach provides time to develop clear communication and education materials, ensuring residents are well-informed as new materials are added to recycling programs. 

Community Processing Contracts and Capabilities: The phased approach allows current recycling contracts to be maintained and adjusted over time, and provides time to enhance recycling programs and capabilities to include all designated materials.  
 

What Do Communities Need to Do? 

Maintain Current Services: Continue collecting the same designated materials in your PPP recycling programs as of April 1, 2025. 

Collaborate with PROs: Work closely with your designated PRO to support the gradual expansion of services and materials. 
 

Community Feedback  

We encourage communities to keep ARMA informed about their preparation for the EPR launch. If you encounter any challenges, please let us know. We are committed to working with you to resolve any issues and close gaps in service or compliance. 

Clarity on EPR Regulation Intent of PPP Depots 

1. PPP Depots should be treated as an extension of curbside services, where applicable. 
    
2. The status quo for depots, whether staffed or un-staffed, must be maintained for Phase I. This means that: 

• Residents can expect service continuity and should not experience any decrease in recycling service levels during the transition. 
• Depots, whether standalone or part of an integrated curbside system, should remain operational and accessible to residents during the transition.  
• The number and location of depots and their hours of operation must remain consistent during the transition. 
• Depots may inadvertently collect non-designated materials. These materials are not the responsibility of the Producers. 
• Communities will need to work with Circular Materials to accommodate the operational changes required to manage current PPP collections, and phase in new PPP designated materials.

Depot Timelines Provided by Circular Materials* 

January 31, 2025: 

• Deadline for final community/commission approval of terms. 

February 28, 2025: 

• Deadline for community/commission execution of agreement. 

* The expectation is that these timelines will be met, with Phase I depot services commencing on April 1, 2025. 

Community Feedback
We encourage communities to keep ARMA informed about their preparation for the EPR launch. If you encounter any challenges, please let us know. We are committed to working with you to resolve any issues and close gaps in service or compliance.