Bill C-15: What It Could Mean for Canada’s Circular Economy
Why should the circular economy sector be paying attention to a federal budget bill?
The RCA is highlighting three provisions in Bill C-15, the Budget 2025 Implementation Act, that could have implications for waste diversion, resource recovery, reuse and circular business models.
Bill C-15 received Royal Assent in March 2026. While it is not a circular economy bill, several of its measures point to a broader shift in how government is thinking about resources, materials and economic value.
Why does this matter?
Circular economy considerations are increasingly intersecting with issues such as economic competitiveness, critical minerals, clean technology, domestic supply chains, energy security and resource efficiency.
For RCA members, that means the conversation is expanding beyond “What do we do with waste?” to a much bigger question: How do we retain the value of products and materials within the economy?
Here are three provisions we’ll be watching.
1. Making It Easier to Keep Usable Goods in Circulation
Part 5, Division 26 — Clauses 457–459: Customs Tariff
Bill C-15 creates a pathway for eligible surplus or obsolete goods to be donated to a registered charity while still qualifying for a refund of customs duties, rather than being destroyed.
The specific goods and conditions will be established through regulation, and the provision will come into force by Order in Council.
Why does this matter?
This is an interesting policy signal: government is recognizing that policy should not inadvertently make destruction more attractive than keeping products in use.
While this provision focuses on charitable donation, it raises an important question for the broader circular economy:
Could similar approaches encourage other higher-value pathways such as reuse, repair, refurbishment, remanufacturing and recycling?
For businesses managing surplus, obsolete or returned products, changes like this could influence the economics of different end-of-life pathways.
For the RCA, it reinforces the importance of policies that support the highest-value use of products and materials wherever practical.
2. Recognizing Critical-Mineral Recycling as Part of the Clean Economy
Part 1, Division 1 — Clause 56: Clean Technology Manufacturing Investment Tax Credit
Bill C-15 expands the 30% Clean Technology Manufacturing Investment Tax Credit to additional critical minerals, including antimony, indium, gallium, germanium and scandium, along with other changes to eligible mining and processing activities.
Why does this matter?
Critical minerals don’t only come from mines. They can also be recovered from products, manufacturing processes and other secondary sources.
That strengthens the case for seeing recycling and resource recovery as part of Canada’s industrial infrastructure and domestic supply chain—not simply waste management.
For Alberta, this connects directly to opportunities around industrial circularity, economic diversification, resource efficiency and supply-chain resilience.
In fact, this is exactly the conversation we’ll be exploring at the RCA’s Explore Circularity Day one-day conference in March 2027: Industrial Circularity- we’ll share more details soon.
3. Recognizing Waste Biomass as a Clean Technology Opportunity
Part 1, Division 1 — Clause 52: Clean Technology Investment Tax Credit
Bill C-15 expands the Clean Technology Investment Tax Credit to include qualifying equipment that generates electricity, heat or both from waste biomass.
Biomass is organic material from plants or animals that can be used for energy or converted into other useful products. Examples can include forestry and agricultural residues, manure, organic waste and certain organic by-products.
The change applies to qualifying property acquired and available for use on or after November 21, 2023.
Why does this matter?
The bigger story is the recognition that residual materials can be resources.
For Alberta, this could be particularly relevant to agricultural, forestry and other organic residual streams.
Instead of simply asking:
“How do we manage this waste?”
the circular economy asks:
“What is the highest-value use for this material?”
That shift in thinking is at the heart of circularity—and it demonstrates why circular economy opportunities extend well beyond the traditional recycling sector.
The Bigger Picture
Bill C-15 doesn’t create a federal circular economy strategy. But it does offer a useful snapshot of how circularity is increasingly showing up in broader economic policy.
Customs. Clean technology. Critical minerals. Energy. Resource recovery. Supply chains. Industrial competitiveness.
These policies may not carry a “circular economy” label, but they can have a significant impact on how products and materials move through our economy—and where their value is retained.
The RCA takeaway
Circular economy policy isn’t just about recycling policy anymore.
If Canada wants greater economic resilience, resource security and domestic supply-chain capacity, we need policies that make it easier—not harder—to keep products in use, recover materials and build markets for secondary resources.
The RCA will continue to watch these developments and bring members into the conversation.
Read Bill C-15 — Royal Assent version: Parliament of Canada — Bill C-15
Legislative Summary: Library of Parliament — Bill C-15
Have you seen a policy opportunity—or barrier—to circularity?
The RCA wants to hear from members.
Are you seeing federal or provincial policies that are making it easier—or harder—to reuse, repair, recycle, recover or retain the value of materials?
Share your perspective with us. Member experiences help inform the RCA’s policy and advocacy work and identify where policy changes could better support Alberta’s circular economy.