The Canadian Beverage Association (CBA) is proud to be the trusted and leading voice for Canada’s sustainable, responsible, and competitive non-alcoholic beverage sector. Collectively, the association represents more than 60 brands of non-alcoholic beverages including carbonated soft drinks, juices, bottled waters, sports drinks, functional beverages, and ready-to-drink coffees and teas. Most beverages sold by members across the country are made and shipped within Canada. The non-alcoholic beverage industry sector directly and indirectly employs over 56,000 Canadians and contributes over $5 billion to the Canadian economy. The sector is committed to maintaining and growing their contributions to the Canadian economy and the communities in which they operate.
As the federal government focuses on affordability and economic growth, there is a clear opportunity to address rising system costs, recycling costs, regulatory burdens, and trade uncertainty. Across Canada, inconsistent recycling regulations and rapid implementation and expansion of Extended Producer Responsibility (EPR) programs is creating avoidable cost pressures for producers, retailers, and consumers. These pressures are especially acute for small and medium-sized businesses, which is a barrier to competition. Furthermore, these costs are ultimately felt most acutely by households with lower incomes, for whom food and beverage affordability is already a pressing concern.
The lack of a consistent supply of high-quality food-grade recycled materials is hindering the transition to a more circular economy for beverage containers. By adopting a One Canadian Economy approach to recycling, Canada can increase the availability of recycled content for beverage packaging while enabling growth opportunities. As leaders in the circular economy, CBA member companies support a unified approach through a national beverage container recycling framework that will increase harmonization across provincial programs and reduce the regulatory burden leading to reduced cost and improved efficiency. The CBA has been actively working toward the goal of a national beverage container recycling framework through producer-led beverage container recycling programs in British Columbia, Alberta, Quebec and several Atlantic provinces.
The CBA recommends that the Government of Canada prioritize:
- Initiation of a federal study on beverage container collection and recycling that reduces duplication, eliminates red tape, improves efficiency, increases program effectiveness.
- Action to reduce internal trade barriers in recycling and materials markets to help contain system costs.
- Continued support for integrated North American supply chains and essential municipal infrastructure that protect competitiveness, affordability, and manufacturing continuity.
Recommendation 1: Federal Study on a Harmonized National Beverage Container Recycling and Recycled Content Framework
The CBA supports the government’s goal of building an effective, harmonized circular economy in Canada while improving affordability for consumers. As provincial recycling systems evolve and recent legal decisions clarify the federal government’s role in regulating plastic manufactured items under the Canadian Environmental Protection Act (CEPA), the federal government has a timely opportunity to show national leadership on beverage container recycling. A coordinated national approach can reduce duplication, increase efficiency, improve recycling outcomes, and help reduce unnecessary compliance costs from flowing through to food and beverage prices.
For this reason, Environment and Climate Change Canada (ECCC) should:
- Initiate a formal study to explore the implementation of a coordinated, national framework for beverage container collection and recycling.
- Study the requirements needed for a national market-calibrated recycled content framework for plastics used in beverage containers.
The studies should focus on the following core pillars:
- Study the opportunity to build a cost-effective recycling network across Canada:
The study should assess the opportunity for standards and guidelines for beverage container recycling that would enhance affordability and performance across jurisdictions without disrupting successful provincial models. Sound data from a trusted and transparent source will give all participants valuable insight for policy and operational decisions. Key Performance Indicator development should consider the assessment of current container volumes, recovery rates, recycled content use, material availability, infrastructure gaps, aluminum and PET markets, food-grade recycled PET access, public participation, and cost scenarios.
- Market-Calibrated Recycled Content Standards:
The CBA recommends developing a data informed phased-in approach for mandatory post-consumer recycled content in plastic beverage containers. It is vital that these standards are structurally linked to the North-American availability of high-quality, food-grade recycled PET (rPET), allowing producers to scale up incorporation with the expansion of supply chain capacity and end markets. A national recycled content framework must recognize the integrated nature of North American recycling, manufacturing, and packaging supply chains.
Recycled content mandates must be evidence-based, with targets and policy being driven by market realities through assessments of processing capacity, performance of collection systems, pricing conditions, and technological capabilities. Mandates should be accompanied by government investments and incentives to promote the increased use of recycled content and strengthen collection rates and processing capacity, while mitigating supply chain disruptions or unintended market impacts. Federal harmonization of a recycled content framework would support consistency and competitiveness, while mitigating the challenges and burden of patchwork provincial/territorial requirements, which inevitably lead to increased barriers, costs, and inefficiencies.
- Collaborative Industry Support:
The Government of Canada should establish a dedicated consultation process, beginning with an introductory meeting with the CBA and key industry leaders, such as the Beverage Container Recycling Network of Canada (BCRNC). Fleshing out this approach in partnership with the producers and organizations that manage these systems daily will ensure the resulting policy is both operationally viable and economically sustainable.
Federal leadership is needed to support:
- Funding and initiation of a study to explore a national beverage recycling framework in Canada.
- Development of feasible recycled content standards.
- Collaborate with industry partners and other key stakeholders like BCRNC to ensure policies align with market realities.
Recommendation 2: Reduce Internal Trade Barriers in Recycling Systems
Canada can be a global leader in the circular economy if it takes a One Canadian Economy approach to recycling systems and reporting frameworks.
Fragmented recycling systems and inconsistent reporting standards have undermined Canada’s progress on affordability and sustainability goals. The current patchwork of provincial/territorial systems has proven costly and inconsistent in delivering improved outcomes. A package that is recyclable or compliant in one jurisdiction may be subject to different definitions, reporting requirements, fee structures, and/or recycling infrastructure in another, increasing administrative and operational costs across national supply chains. Producers are facing overlapping and uncoordinated requirements, including:
- Multiple provincial Deposit Return Systems (DRS) and EPR systems with inconsistent rules, definitions, and reporting requirements.
- Federal initiatives such as the Federal Plastics Registry.
- Ongoing food regulatory compliance obligations.
While EPR policies are intended to shift recycling costs away from municipal taxpayers, fragmented implementation can increase costs to producers, retailers, and ultimately into the price of everyday food and beverage products. Because lower-income households spend a larger share of their income on groceries and essential goods, these layered compliance costs can have a disproportionate affordability impact unless systems are harmonized, efficient, and designed with cost containment in mind.
These pressures are especially acute for small and medium-sized businesses, which often have fewer resources to absorb rising EPR fees, manage complex reporting obligations, or redesign packaging to meet differing requirements across jurisdictions. A harmonized national approach would help reduce these disproportionate impacts by lowering duplication, improving predictability, and supporting more cost-effective compliance.
For this reason, the federal government should:
- Convene provinces/territories to align system design, definitions, and reporting requirements.
- Reduce duplication between federal and provincial reporting and repeal and replace the Federal Plastics Registry with a system that works with data collection resources from all EPR and provincially managed recycling systems.
- Support the development of a national market for recycled materials.
- Assess the cumulative affordability impact of EPR and recycling compliance costs on food and beverage prices, with particular attention to lower-income households and northern, rural, and remote communities.
Taking a One Canadian Economy approach to recycling would improve efficiency, lower costs for producers and consumers, reduce the risk that fragmented EPR costs are passed through to grocery bills, and position Canada as a genuine leader in the circular economy.
Recommendation 3: Support Integrated North American Supply Chains and Essential Infrastructure
The beverage sector depends on a highly integrated North American supply chain for:
- Packaging (Aluminum cans, PET bottles, rPET supply chain).
- Ingredients and intermediate inputs.
- Finished goods (both to and from Canadian producers).
- Critical Intellectual Property (IP).
Recent U.S. trade actions, including new Canadian retaliatory tariffs and the shift to annual CUSMA review cycles, have increased uncertainty for cross-border beverage manufacturing. These pressures compound domestic regulatory and recycling cost pressures, making supply chain stability an important affordability issue for producers and consumers alike. As Canada continues trilateral discussions following the 2026 CUSMA review, the government should:
- Ensure continued access to tariff-free inputs where no domestic alternatives exist.
- Provide businesses with certainty through timely, predictable remission frameworks where tariffs apply.
- Establish structured industry engagement mechanisms ahead of trade negotiations.
- Prioritize investments in essential drinking water, wastewater, and stormwater infrastructure that support food and beverage manufacturing continuity, system reliability, and long-term economic growth.
In addition, the sector’s competitiveness also relies on dependable municipal infrastructure, including drinking water, wastewater, and stormwater systems. These systems should be treated as essential economic infrastructure because they help protect production capacity, improve system reliability, maintain manufacturing continuity, and support new investment. Federal infrastructure programs, including the Build Communities Strong Fund, should account for industrial continuity, system redundancy, food security, and the ability to attract and retain manufacturing investment when assessing projects. Recent service disruptions in major Canadian cities underscore the economic risks associated with aging or capacity-constrained infrastructure.
Supply chain stability and reliable municipal infrastructure are essential to maintaining affordability, competitiveness, and manufacturing continuity. Maintaining tariff-free trade, regulatory alignment under CUSMA, and resilient municipal services is essential to:
- Competitiveness and manufacturing efficiency.
- Meeting recycled content objectives.
- Avoiding non-tariff barriers that increase costs and disrupt cross-border production.
Conclusion
Canada’s non-alcoholic beverage sector is a significant employer and economic contributor, and most beverages sold by CBA members are made and shipped within Canada. However, rising system costs, fragmented recycling and EPR requirements, limited access to high-quality food-grade recycled materials, trade uncertainty, and aging or capacity-constrained municipal infrastructure are creating avoidable cost pressures for producers, retailers, and consumers. These pressures are especially challenging for small and medium-sized businesses with limited capacity to absorb new costs, manage duplicative reporting obligations, respond to infrastructure disruptions, or redesign packaging across inconsistent provincial and territorial systems.
Targeted federal leadership can help address these challenges by initiating a study on a harmonized national beverage container recycling and recycled content framework, reducing internal trade barriers and duplication in recycling systems, and supporting integrated North American supply chains alongside essential municipal infrastructure. Together, these actions would help protect competitiveness, affordability, system reliability, manufacturing continuity, food security, and the ability to attract and retain manufacturing investment.
The CBA welcomes the opportunity to work with the federal government, provinces, territories, municipalities, and industry partners to advance practical, market-informed solutions that improve recycling outcomes, strengthen essential infrastructure, reduce avoidable costs, and support both economic and environmental performance.