Update on EPR Amendment Response

The Recycling Council of Alberta is committed to keeping our members informed on regulatory updates and changes as they occur. On March 26th, 2025, by Order in Council, the Extended Producer Responsibility (EPR) Regulation was amended to exempt certain flexible, packaging-like, materials from the EPR list of regulated materials. 

On March 28th, the RCA brought this news to your attention via a NewsFlash with a commitment to respond.  

Since March 28th, the RCA has sought clarity on the exemption from Alberta Environment and Protected Areas (AEPA), Alberta Recycling Management Authority (ARMA) and Circular Materials (CM), and a brief in-person  meeting with Minister Schulz.  

Here’s what we’ve learned so far:  

From AEPA Administration:  

The Government of Alberta is exempting a narrow range of flexible plastic packaging-like products (PLPs) from requirements under the Extended Producer Responsibility Regulation.   

The exemption is intended to be specific to products made from flexible plastic that are ordinarily used for the containment, protection or handling of food, such as cling wrap, sandwich bags or freezer bags, specifically, where:  

  • 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.   

Other flexible plastics PLPs supplied for household use remain in the EPR Regulation.  

The RCA wrote and sent a letter to the Minister outlining our three main concerns about the Order in Council.  

  1. The goals of EPR are to hold producers accountable to develop better products to innovate and find efficiencies. This regulatory change lets producers off the hook and allows for the status quo of materials to continue to, in many cases, to be sent to landfill. Furthermore, our municipal members are left holding the bag to communicate about, manage, recycle or dispose of materials that were, and should be, part of a provincial EPR program.  
  2. The GoA and partners have been working diligently to stand up EPR. This last-minute update undermines the hard work of many who are implementing the specific details of the regulation to roll out the programs in their communities.   
  3. The RCA is disappointed with the lack of communication and engagement on these updates, as they were being considered as well as after the decision was made. The RCA has an expectation that key program implementation partners keep each other, and stakeholders informed. We’re all in this together – let’s work together.  

Next Steps  

The RCA is a member of a provincial EPR Working Group convened through the Alberta Municipalities Association which meets regularly. The next meeting is April 28th.  Municipalities are encouraged to send reactions and thoughts on the Order in Council, EPR regulation, or EPR implementation in general to the RCA info@recycle.ab.ca to support the conversation and any potential further response.  

Other resources: 

A bulletin with further clarity was released and shared in our April Connector Newsletter.