Extended Producer Responsibility (EPR) Reform in Québec
- Marie Horodecki Aymes
- 3 days ago
- 5 min read
Updated: 5 hours ago
Where Do the Costs Come From?
On February 23, 2026, the CTAQ and eight agri-food associations spoke out publicly. The tone was grave. The figures were heavier still.
"Costs are far exceeding what most companies are able to absorb," declared Sylvie Cloutier, noting that many businesses had simply not anticipated these invoices in their budgets.
The increases cited range from 75 percent to 350 percent. The headline number, 810 million dollars, has circulated widely. Yet that figure combines two distinct realities: 483 million under the 2026 Producer Financial Participation within the new extended producer responsibility regime, and roughly 327 million linked to the 2025 tariff, the final exercise under the former compensation model. The two funding years overlap because of the transition between systems.
The 810 million reflects a transitional spike. Even so, the annual bill under the new model alone is already more than double what it was four years ago.
It would be tempting to dismiss this as corporate resistance. That would be a mistake. The pressure is real. The data are public. And the mechanics deserve examination without caricature.
In the short term, the rapid increase in contributions creates a very real liquidity constraint for companies, regardless of any medium-term optimization, and an overly abrupt adjustment risks triggering sectoral disruption that goes beyond the system’s environmental performance alone.
A Gap That Can No Longer Be Ignored
In 2022, the Regulatory Impact Analysis estimated additional operational costs from modernizing selective collection at roughly 72 million dollars by 2030. In return, it projected benefits of around 28 million, driven by contract optimization and higher value for sorted bales. The net additional cost for both systems combined, deposit return and selective collection, was presented as 119.6 million by 2030. These projections concerned the delta compared to the existing regime, not the total cost of the new system.
Reality has followed a different trajectory.
According to data published by Eco Entreprises Quebec, net system costs for curbside recycling system rose from 211 million in 2022, under the 2023 tariff, to 285 million in 2023, then 387 million in 2024, reaching 483 million in 2026 under the new PFP. The 2026 figure includes 444 million in net costs and 39 million in management fees and funds.
The additional cost relative to the 2022 baseline is therefore about 272 million dollars. That is nearly four times the delta projected for 2030, and it has arrived four years ahead of schedule.
This is not a marginal discrepancy. It is structural. The 2022 analysis underestimated the real cost of implementation, not by a small margin but by a factor significant enough to alter companies' budget trajectories. This follows directly from public data.
A Shift in Logic, Not Just in Amount
The jump from 211 million to 483 million cannot be read as mere continuity.
Under the former regime, only materials deemed recyclable were truly integrated into the operational logic of the blue bin. Other packaging, though formally regulated, was largely diverted to disposal. The system functioned with an implicit filter. The reform altered that architecture. The "everything in the bin" principle now allows all non-deposit containers, packaging and printed materials into selective collection. The message to citizens is simplified. Complexity shifts to infrastructure.
This is a design choice, not a behavioral failure. And it mechanically increases sorting, rejection and treatment costs for lower-value streams. The increase reflects two simultaneous phenomena: the exposure of costs previously partially masked, and the operational integration of materials that the previous system did not fully absorb.
A Late Catch-Up
The reform must also be situated in the longer arc of Quebec's waste policy.
For more than thirty years, Quebec gradually modernized its system without fully investing in the infrastructure required for comprehensive packaging management. The model relied on heterogeneous sorting centers, often under-capitalized, and on fragile end markets. The reform makes this accumulated deficit visible. It compels investment in equipment capable of handling more complex streams at a time when the cleanest materials are gradually leaving selective collection for deposit return.
This is accelerated catch-up, not accidental drift.
Five Structural Drivers
The rise in costs is rooted in the reform's design. Five factors stand out.
Material expansion. The "everything in the bin" approach raises the average cost per managed ton by incorporating streams that were previously excluded or only loosely managed.
Deposit diversion. Aluminum, beverage PET and, eventually, glass are exiting selective collection. These streams are clean, homogeneous and highly marketable. Their removal mechanically degrades the average value of the residual mix. Deposit return performs well and is not the problem, but it changes the economic balance of what remains.
Sorting center obsolescence. Variable yields, insufficient output quality, high unit costs. The reform did not create this situation. It has made it more expensive to maintain.
Modernization investments. Optical sorting technologies, automation, traceability systems, information platforms. These are necessary and amortized over years, but their financial impact is immediate.
Contemporary material complexity. Multilayer packaging, technical plastics, functional barriers, e-commerce formats. More complex to sort, less readily marketable.
These factors were identifiable before full implementation. Macroeconomic variables amplify the pressure. They do not fully explain it.
Cyclical Amplifiers
North American recycled material markets are tight. Domestic capacity remains limited. Quality requirements are rising. Collection and sorting account for roughly 88 percent of system costs. Wages, energy, transport and maintenance follow the broader inflationary curve. Trade policies and tariffs add uncertainty.
Oil prices act as a particular amplifier. When virgin resin becomes cheaper, recycled plastic loses competitiveness. Resale revenues decline. Net system costs rise.
These variables shape the trajectory. They are not its primary cause.
A Marked Redistribution
The 2026 data reveal significant redistribution across material categories.
Plastics' share of the PFP rises from 37.1 percent in 2025 to 39.9 percent in 2026 and is projected to reach 44.8 percent in 2027. Steel sees a relative increase of 72 percent over two years. Unit rates climb sharply for HDPE, aluminum, steel and polypropylene. The impact is uneven: thirty-two percent of producers see their contribution decrease, twenty-nine percent record a moderate increase, and twenty-six percent face increases above 20 percent. Sectors heavily reliant on plastics are particularly exposed.
The elimination of the Publisac flyer and the 30 percent decline in printed materials reduce declared volumes and increase pressure on unit rates for remaining categories.
What Companies Can Still Control
Ecodesign will not reduce the system's global costs. Structural determinants will continue to weigh on the trajectory. For an individual company, however, it remains the most direct lever.
The eco-modulation framework provides bonuses of up to 50 percent, maluses for certain resins and credits for recycled content. It acts on the material mix and reduces exposure to the most penalized categories. In a context of systemic increase, inaction means absorbing the full pressure. Action can mitigate its relative effect.
Deposit return offers a simple gesture to citizens and produces high-quality streams. Reuse, when conceived as a complete system with standardization and adequate logistics, has demonstrated effectiveness both here and abroad. It reduces flows at the source rather than managing them at end of life. These approaches underscore a fundamental point: environmental performance depends as much on system architecture as on product design.
What the EPR Framework Must Confront
The reform pursues legitimate environmental objectives. But its trajectory warrants scrutiny.
The initial underestimation of costs has undermined companies' budget predictability. Ambitious targets are forcing rapid transformation of a system that was not dimensioned to absorb these requirements overnight. The issue is not whether to return to the previous model. It is how to adjust the trajectory, ensure coherent support mechanisms and maintain a dialogue grounded in real data.
Companies cannot ignore the system's internal logic. Government cannot ignore industrial absorption capacity. Designated producer responsibility organizations have to reconcile regulatory compliance with operational reality.
This reform is the product of deliberate structural choices, amplified by adverse economic conditions and accelerated by a long-delayed catch-up.
The bill is now visible. The question is no longer where the costs come from. It is who adjusts, how fast, and on what terms.
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