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Important changes will be made to the Deposit System starting from November 1, 2023. To properly prepare for this transition to a modernized system, beverage producers and importers will need to adhere to certain transitional measures.
On June 22, 2022, the Government of Quebec passed regulations giving producers the responsibility to develop, implement, finance and manage the modernized deposit system, based on the Extended Producer Responsibility (EPR) approach.
The QBCRA is the management organization designated by RECYC-QUÉBEC to represent producers and manage the deposit system for beverage containers on their behalf. Under these regulations, producers were required to become members of the QBCRA by February 28, 2023.
To become a QBCRA member, producers must register with the portal (link below).
Persons targeted by the settlement, called “producers,” include:
• Any person who is an owner/user of a name or brand, domiciled or having an establishment in Quebec, who markets a targeted product in a targeted container on the Quebec market.
• Any first supplier of a targeted product on the Quebec market, such as an importer, distributor, wholesaler, retailer, etc., when acquiring a targeted product from outside Quebec or when the owner/user of a name or brand does not have a domicile or establishment in Quebec.
• For a targeted product without a name or brand, the obligations fall on the first supplier in Quebec.
• If a product is acquired outside Quebec by a person domiciled in Quebec for own use, the obligations fall on the person from whom the product was acquired, including the person who operates an e-commerce site.
The responsibility for developing, implementing, financing and managing the deposit system rests primarily with individual producers, who are also responsible for most of the obligations prescribed by the regulations.
However, each producer will have to fulfill its obligations in cooperation with other producers within a single deposit system.
Comply with the terms and conditions determined by the QBCRA for all steps related to the deposit system and its internal regulations. The information that each producer transmits to the QBCRA must include:
Its complete contact details;
The types of products it markets, the brands and its status with respect to those products (brand owner, first supplier, etc.);
The quantity of returnable containers placed on the market, by type of container and weight.
Barcode: Every returnable container must be marked with a barcode that, when read, identifies the type, weight, volume and description of the product marketed, offered for sale or otherwise distributed in that container, as well as the amount of the deposit to which it is associated. An update of this information must be transmitted to the QBCRA, according to the modalities prescribed by the QBCRA, whenever any modification is made.
Products covered by the deposit system are defined as:
Any liquid intended for human consumption that is sold in a sealed container and that, at the time of purchase, is ready to drink.
We are referring to the so-called "ready-to-drink" beverages such as juices, soft drinks, fruit drinks, flat and sparkling waters, flavoured or not, beer, wine, cider, spirits, dairy or plant milk, etc., with the exception of concentrates, broth, soup, cream, infant formula, syrup or yogurt drinks, and any such product containing more than 50% milk permeate.
Meal replacements are not considered beverages.
• Containers of volume ≥ 100 millilitres and ≤ 2 litres, used to market targeted products;
• Single-fill containers (SFC);
• Multi-fill containers (MFC);
• Containers used to market a "ready-to-drink" beverage, according to the following types :
1. SFC in metal;
2. SFC in plastic;
3. SFC made of glass or other breakable material;
4. SFC made of fibre, including multi-layer containers;
5. SFC biosourced;
6. MFC made of glass or other breakable material;
7. MFC made of any material other than glass or other breakable material;
+ Any container composed of a combination of these materials, classified on the basis of its principal component by weight.
• Bags, i.e. flexible plastic "pouch" type containers (milk bags, self-storage bags);
• Bag-in-box packaging, i.e. containers of the "wine cask" type;
• Unsealed containers used to serve beverages added at the point of sale, such as coffee cups or soft drink containers.