The Canadian Extended Producer Responsibility (EPR) landscape is shifting fast. New provincial requirements and the Federal Plastics Registry are multiplying reporting obligations, and with them, the risks of getting it wrong.

Regulatory compliance is no longer just a box to check. It is becoming a marker of credibility, trust, and competitiveness. Producers who act early to strengthen their reporting processes can mitigate risk, protect their brand, and demonstrate leadership in sustainability.

EPR at a glance

In Canada, the “polluter pays” principle is nothing new. Provincial EPR regulations make “producers,” including brand owners, importers, retailers, and franchisors, responsible for the products they place on the market for consumers.

Obligations vary by province and program, and generally include:  

Packaging and paper programs are now widespread, building on more mature programs like tires, electronics, and hazardous products. As regulatory scrutiny intensifies, credible reporting has become essential: inaccurate or late submissions can trigger costly penalties and fee surcharges. Customer scrutiny is also intensifying as consumers continue to make purchasing decisions based on sustainability. In some provinces, producers must now provide verified, reliable reporting—highlighting the growing importance of accuracy and accountability.

Demystifying packaging verification rules

As regulatory focus intensifies, producers are now being asked to deliver credible, verified reporting to support fair cost allocation, stronger accountability, and public trust in EPR systems. Independent verification, already in place for some programs, is being introduced for packaging data in Alberta and Ontario. In Alberta, producers must submit two verification reports by June 30, 2026, covering 2024 and 2025 data, while Ontario’s Blue Box Program mandates the first verification report by May 31, 2027, covering 2026 data.

These reports must be prepared by accredited professionals who are independent from the producer’s reporting process. Verification procedures are set in regulations and still evolving. Alberta has released procedures that are subject to change, while Ontario has yet to publish its own.

The onus is on producers to obtain additional guidance on the provincial standards they must meet. Producers should ensure their verifier is up to date and capable of navigating these requirements. Deloitte’s EPR Assurance team brings deep experience in this space, helping producers meet verification obligations with confidence and credibility.

Producers’ top compliance challenges

We’ve worked with clients on their EPR strategies across various industries, including technology, automotive, retail, consumer products, and financial services. Here are the most common challenges organizations face with EPR compliance:

• Ambiguity about scope: Suppliers struggle to classify complex packaging materials (multi-material laminates, labels, adhesives). Inconsistent classification drives large variances in reported weights.
• Cross-province complexity: Each province defines obligations and material categories differently, complicating cross-border compliance for producers selling across Canada. Disparate timelines and portal systems require proactive compliance calendars.
• Fragmented and unreliable data: Many producers lack integrated systems to track packaging weights and formats by stock keeping unit (SKU). Inconsistent data across SKUs makes manual data reconciliation slow, error-prone, and costly.
• Unclear process and resource constraints: EPR cuts across finance, supply chain, and product teams. Without clear ownership and good governance, deadlines are at risk. Weak internal tracking can lead to over-reporting (and overpaying) or under-reporting (risking non-compliance). Small to-medium size businesses often lack the capacity or technical know-how to effectively manage EPR compliance across jurisdictions.
• Low supplier engagement: Suppliers may not prioritize packaging weight requests or may lack the required technical data. These delays may cascade into late reporting.

Three actions to stay compliant and competitive in EPR

Done well, compliance builds trust, drives efficiencies, and positions producers ahead of competitors who struggle to adapt. Here are three strategic actions that leading producers are taking.  

Stay compliant and competitive with Deloitte

EPR compliance isn’t optional—and it’s only getting more complex. Waiting until deadlines loom can mean inaccurate reporting, rushed fixes, higher costs, and regulatory penalties. Producers who act proactively with a data-driven approach can control costs, reduce risk, and stay ahead of both regulatory and market expectations.

Deloitte’s EPR assurance specialists help producers navigate this evolving landscape—from understanding the regulations to data readiness and independent verification. For organizations reporting packaging data in Canada and internationally, Deloitte leverages a global network of EPR specialists with deep knowledge of regulations across jurisdictions, helping you maintain compliance while protecting your brand reputation.

Turn compliance into a competitive advantage.

Connect with our leaders today to build credibility and confidence in your EPR reporting.