1.11 What is a small business policy?

To the extent possible, CSSA is committed to minimizing the administrative burden on small businesses participating in packaging and paper product stewardship programs. Some provinces have regulated or legislated policies specifically recognizing the needs of small businesses. In other provinces, a small business policy has been established by the stewardship organization in consultation with stakeholders and approved by the government. CSSA recognizes that stewardship fees need to be proportional to the amount of packaging and paper product supplied into the residential marketplace by stewards and does not intend to place an undue burden on small contributors. When considering if your organization qualifies for a small business exemption, be sure to consider and include any affiliates. Affiliates of a parent company are required to report under a single account and do not qualify for small business exemptions, unless the quantity of PPP supplied by all related corporations, in aggregate, is less than the small business limit in the particular province.The following table outlines the small business (or de minimis) policies in BC, SK, MB and ON.


BC SK MB ON
Regulatory or legislative policy In May 2014, the BC Government amended the Recycling Regulation to exempt some categories of small businesses from the obligations of the BC Recycling Regulation The MMSW Program Plan was revised in December 2014 to exempt some small businesses. The MB Packaging and Printed Paper Stewardship Regulation does not provide exemptions for any class of producer but MMSM has established a Small Business Policy as set out in the Steward Rules. The allowance for a de minimis policy is established in the Waste Diversion Transition Act, 2016 Sect. 33(e) and is further defined in the Blue Box Program Plan (Section 9.4.1) as required by the Minister’s Request Letter.
Registration Requirements Businesses that supply less than 1,000 kg of PPP or have revenues in B.C of less than $1M are exempt from the Regulation and do not need to register with Recycle BC. Businesses that supply less than 1,000 kg of waste packaging and paper (WPP) to SK consumers or with revenues of SK less than $2M are exempt from registration and reporting requirements with MMSW. All stewards are required to register with MMSM regardless of their size. Stewards with revenues in ON of less than $2M/year do not need to register with Stewardship Ontario. 
Revenue-based threshold

Businesses with revenue in BC of less than $1M are exempt from the Regulation . Charitable organizations registered under the Income Tax Act (Canada) are also exempt from the Regulation.

A permanent exemption has been granted to businesses (including newspapers) that generate less than $2 million in gross annual revenue in SK.

MMSW Transition Period: Eligible organizations can   choose to pay a fixed fee in 2015 and 2016 as part of the MMSW Transition Period and are not required to  complete a Membership Agreement and file a detailed report.

Eligible organizations include:

  • Companies with revenue between $2 – 5 million
  • Newspaper pubishers with gross revenue in Saskatchewan of over $2 million.

Contact National Steward Services at 1 888 980 9549  to learn if you are eligible for the Transition Period.

Stewards are exempt from filing a Steward’s Report and paying the fees otherwise due, if during the data year, the steward, its affiliates, and franchisees had combined gross revenues from the sale of all products and services in Manitoba of less than $750,000. A steward is exempt from collecting and reporting data to SO if the steward (including affiliates/ subsidiaries) has less than $2 million gross revenue from the combined sale of all of their products and services in Ontario in a calendar year.
Weight-based threshold Businesses that supply less than one tonne (1,000 kg) of PPP are exempt from the Regulation and reporting to Recycle BC. A permanent exemption has been granted to businesses that generate less than 1,000 kg of WPP in SK annually. N/A Stewards with gross sales over $2 million but total reported packaging and printed paper quantities are less than 15,000 kg (15 tonnes) must report their materials to Stewardship Ontario but are exempt from paying fees.
Single Point of Retail Sale Stewards that are a single point of retail sale are exempt from the Regulation and registering with Recycle BC.

To qualify, the steward must only operate one retail location and not supply products on-line, or as part of a chain or franchise.

Stewards that are a single point of retail sale are exempt from the Regulation and registering with MMSW To qualify, the steward must only operate one retail location and not supply products on-line, or as part of a chain or franchise. N/A N/A
Low volume steward fees Businesses that distribute between 1,000 and 4,999 tonnes of PPP qualify as Low Volume Stewards and are eligible for a flat fee payment. There are two categories of Low Volume stewards: organizations that distribute between 1,000 and 2,499 kg of material and those that distribute between 2,500 – 4,999 kg. Visit here to find out more about eligibility. Low Volume stewards are defined as businesses that distribute between 1,000 and 5,000 kg of WPP to SK consumers Please visit the MMSW site for more on eligibility. Please visit the MMSW site for more information on flat fees for low volume stewards.  There are no flat fees for low volume stewards. There are no flat fees for low volume stewards.
Flat Fee Categories

  • Stewards that distribute between 5,000 to 9,999 kg and,
  • Stewards that distribute between 10,000- 15,000 kg of materials.
  • Flat fees associated with these categories will be provided in the Fall of each year.
N/A  N/A N/A
Franchisors & Franchisee Obligation Franchisors with headquarters located both inside and outside of the province, with franchisees operating in BC, are responsible for reporting and paying fees on the amount of PPP all its franchisees supply to BC consumers. Franchisors with headquarters located both inside and outside of the province, with franchisees operating in SK, are responsible for reporting and paying fees on the amount of WPP all its fanchisees supply to SK consumers. Franchisors with headquarters located both inside and outside of the province, with franchisees operating in MB, are responsible for reporting and paying fees on the amount of packaging and printed paper all its fanchisees supply to MB consumers. Franchisors with headquarters located both inside and outside of the province, with franchisees operating in ON, are responsible for reporting and paying fees on the amount of packaging and printed paper all its fanchisees supply to ON consumers.