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Packaging and paper faqs

Packaging and Paper Products
Recycle NB is the arm’s length agency responsible for overseeing waste management programs for materials specified in the Designated Materials Regulation under the Clean Environment Act. These include tires, paint, oil/glycol, electronics, and, more recently, packaging and paper products. The organization was established through legislation in 2008 as a multi-material stewardship board. Recycle NB’s responsibilities include overseeing Producer Responsibility Organizations (PROs) to ensure regulatory compliance, as well as reviewing and approving industry stewardship plans, program measures and targets.
The Designated Materials Regulation requires all brand owners to register with Recycle NB. Use the flowchart below to determine if you are a brand owner. There is no registration fee.

The definition of a brand owner is found in Section 2 of the Designated Materials Regulation. It is summarized in the flowchart above. If you determine that you are a brand owner and, therefore, obligated under the Regulation, please ensure you are registered with Recycle NB as required.
Brand owners are required to register within 120 days of the Legislation. Beyond February 11, 2022, no brand owner shall sell, offer for sale or distribute PPP to a person within the province unless the brand owner is registered with the Board of Recycle NB.
To register as a brand owner, you can do so online or download a registration form and either email or mail it to our office.

Email:  info@recyclenb.com

Mail: Recycle NB
PO Box 308 Station A
Fredericton, New Brunswick
E3B 4Y9

There is no fee to register as a brand owner.

If you are a brand owner, you must register with Recycle NB. A brand owner with respect to packaging and paper products sold, offered for sale or otherwise distributed in or into the province, is a person who:
(i) is a manufacturer of packaging and paper products,
(ii) is a distributor of packaging and paper products,
(iii) is an owner or licensee of a registered or unregistered trademark under which packaging and paper products are sold, offered for sale or distributed, or
(iv) if a packaging or paper product is imported into the Province, is the first person to sell the packaging and paper product.

The regulation does not apply to a person in the following circumstances:
(a) the brand owner generates less than two million dollars in gross annual revenue in the Province;
(b) the brand owner manufactures, distributes, sells or offers for sale less than one tonne of packaging and paper annually in the Province; or
(c) the brand owner is a charitable organization registered under the Income Tax Act (Canada).

A brand owner or its designated agent (Producer Responsibility Organization) must submit a stewardship plan for approval by the Board of Recycle NB. Any proposed stewardship plans must be received by October 14, 2022.
A stewardship plan for packaging and paper products must contain a plan for the collection, transportation, storage, reuse and recycling of packaging and paper waste within the Province, including the packaging and paper waste of other Brand owners. Section 50.58 of Regulation 2021-76 contains full details of what is required in a stewardship plan.
As soon as possible after a brand owner or agent submits a stewardship plan, the Recycle NB Board will either approve the plan for a period not to exceed five years or reject the plan in writing. The rejection letter will outline the reasons for the rejection so adjustments can be made and the plan resubmitted if desired.
The Board of Recycle NB may refuse to register or suspend the registration of a brand owner who does not submit a stewardship plan for packaging and paper products. Failure to comply and maintain a valid registration may require further enforcement action as covered under the Designated Materials Regulation and the Clean Environment Act.
A stewardship plan expires on the date set by the Board of Recycle NB but no plan shall exceed five years. Ninety days before the expiry of a Board-approved stewardship plan, the brand owner or agent shall submit a new plan for review and approval.
A brand owner must provide the Board of Recycle NB with an annual report by April 30 of each year, detailing the effectiveness of the packaging and paper products stewardship plan for the previous calendar year. Section 50.64(1) of Regulation 2021-76 sets out the content requirements for the report.
A brand owner must give retailers information on its plan, return depots, and the benefits of participating in the packaging and paper products program. A brand owner must submit its educational and consumer material to Recycle NB, at least one month in advance of its release.
According to the Regulation, “packaging” means any material that is used for the containment, protection, handling, delivery or presentation of a product that is provided to a consumer, any marketing material and any packaging-like products. “Packaging-like product” means a container or covering that is sold as a product, is used by a consumer for their own packaging needs and would be ordinarily disposed of after a single use or short-term use (a period of less than five years). “Paper” means paper that is provided to a consumer that is printed, or intended to be printed, and includes telephone directories. More details about what products are included are available here.

To speak with Recycle NB staff about regulatory requirements, registering with RNB, and for general inquiries, contact:

Recycle NB
E-mail: info@recyclenb.com
Telephone: 506-454-8473, 1-888-322-8473 (Toll-Free)
Fax : 506-454-8471

Mail: Recycle NB
PO Box 308 Station A
Fredericton, New Brunswick
E3B 4Y9

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