Pharmaceutical PRODUCTS and medical sharps - FAQS

Pharmaceutical Products and Medical Sharps
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, packaging and paper products, and pharmaceutical products and medical sharps. 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 21, 2023, no brand owner shall sell, offer for sale or distribute pharmaceutical products and medical sharps 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 pharmaceutical products and medical sharps sold, offered for sale or otherwise distributed in or into the province, is a person who:

(i) is a manufacturer of pharmaceutical products or medical sharps,
(ii) is a distributor of pharmaceutical products or medical sharps,
(iii) is an owner or licensee of a registered or unregistered trademark under which pharmaceutical products or medical sharps are sold, offered for sale or distributed, or
(iv) if a pharmaceutical product or medical sharp is imported into the Province, is the first person to sell the pharmaceutical product or medical sharp.

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 April 22, 2023.
A stewardship plan for pharmaceutical products and medical sharps must contain a plan for the collection, transportation, storage, reuse and recycling of waste pharmaceutical products and medical sharps within the Province, including the waste pharmaceutical products and medical sharps of other brand owners. Section 50.76 of Regulation 2022-73 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 pharmaceutical products and medical sharps. 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 pharmaceutical products and medical sharps stewardship plan for the previous calendar year. Section 50.82(1) of Regulation 2022-73 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 pharmaceutical  products and medical sharps 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:

“Pharmaceutical product” means a drug as defined in section 2 of the Food and Drugs Act (Canada) and a natural health product as defined in subsection 1(1) of the Natural Health Products Regulations made under that Act, but does not include:

(a) a food as defined in section 2 of the Food and Drugs Act (Canada),
(b) a cosmetic as defined in section 2 of the Food and Drugs Act (Canada),
(c) a drug that is a radiopharmaceutical as defined in Part C of the Food and Drug Regulations made under the Food and Drugs Act (Canada).
(d) a drug for veterinary use except a drug for veterinary use in a consumer’s companion animal,
(e) a topical substance that does not contain an antibiotic, antifungal or analgesic, or
(f) a drug that is represented as being solely for use as a disinfectant on hard non-porous surfaces.


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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