Overall Recommendations
- Adopt a unified National Recycling Framework, with the following additional recommendations:
- Recycled Content Targets: Establish realistic and achievable targets for recycled content in beverage containers. The proposed targets should be evidence-based, with clear definitions and baseline data to support them. Align targets with international standards, such as those in the Ocean Plastics Charter.
- Synchronize reporting standards: Eliminate duplication of reporting requirements and data collection across jurisdictions to reduce administrative red tape that increases costs for consumers and stifles economic development.
- Caps and Labels: Apply recycled content targets to beverage bottles only, excluding caps and labels.
- Advocacy for deposit return systems: Most Canadian provinces and territories have adopted some form of deposit return system for beverage containers, and recycling rates are significantly higher where these systems are implemented. Ontario has a system for alcoholic containers, but has not yet adopted a similar system for all other beverage containers.
- Provide business certainty, including refunds on finished goods that have been granted remissions, limiting potential consumer price escalation.
- Exempt food and beverage from any mutual recognition in domestic free trade agreements and strengthen a single federal regulator for food and beverage manufacturing.
Executive Summary
The Canadian Beverage Association (CBA) is the national industry association for the Canadian non-alcoholic beverage sector. Together, the association represents over 60 brands of non-alcoholic refreshment beverages consumed in Canada and the companies that manufacture and distribute them across every region of the country. The beverage industry sector directly and indirectly employs over 56,000 Canadians and contributes over $5 billion to the Canadian economy.
Canada is on the verge of becoming a global leader in sustainability, but the lack of a consistent supply of 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 establish a nationwide market for recycled content, enabling growth opportunities. As leaders in the circular economy, CBA member companies support the harmonization of Extended Producer Responsibility systems and have been actively working toward this goal through producer-led beverage container recycling programs in British Columbia, Alberta, Quebec and several Atlantic provinces. This submission outlines the need for a coordinated, evidence-based National Recycling Framework that would harmonize practices, eliminate duplicative systems, prevent increasing producer and consumer costs, and ensure interprovincial cooperation.
Amidst these sustainability challenges, Canada’s tense relations with the United States remain a significant threat to Canadian producers and their market competitiveness. While the sector received a remission on aluminum beverage packaging and finished goods, beverage producers have had to cover the costs for the retaliatory tariffs. This submission outlines how the remaining sectoral tariffs are contributing to elevated costs among Canadian brands and reducing their market competitiveness.
CBA supports a single federal authority for the regulatory requirements of food and beverages, including labelling, to be managed by Health Canada and enforced by CFIA. However, beverage producers are concerned about the unintended implications of the Free Trade and Labour Mobility in Canada Act, specifically that the mutual recognition of provincial regulations will create a patchwork of regulations, resulting in an increased burden on producers. To this end, this submission supports and recommends that Food and Beverage continue to be exempt from any mutual recognition in domestic Free Trade and Canada strengthen a single federal authority regulating food and beverages.
The CBA is eager to collaborate with the federal government on implementing a National Recycling Framework, targeted remissions on aluminum for beverage products, and reducing regulatory burdens associated with domestic free trade. These changes would improve business certainty, spur further sectoral investment, and improve affordability for all Canadians.
Recommendation 1: Adopt a unified National Recycling Framework
In 1998, the Canadian Council of Ministers of the Environment (CCME) signed the Canada-Wide Accord on Environmental Harmonization, which includes the goal “to develop and implement consistent environmental measures in all jurisdictions, including policies, standards, objectives, legislation and regulations.” In 2009, CCME published the Canada-Wide Action Plan for Extended Producer Responsibility (EPR) to “promote harmonization and consistency of programs across the country.” As of 2025, ten Canadian provinces and territories have EPR, are in active transition, or have introduced legislation to implement EPR. CBA members have proudly supported the implementation of these systems across Canada and have consistently advocated for greater harmonization of material categories, reporting, targets and regulatory frameworks.
CBA members are also taking actions to further improve the packaging they supply by supporting the Golden Design Rules that require the elimination of plastics and additives that disrupt recycling systems or degrade the value of other recyclables. To fulfill their commitments to use recycled content, CBA members require a stable supply of recycled material. That is why a national framework for beverage container recycling programs in Canada is essential to collect, sort, and market enough recycled plastic to meet future demand.
Recommendation 1.1 Recycled Content Targets
While beverage producers support the rationale for minimum recycled content requirements, the CBA remains concerned about a 50% recycled content requirement in plastic products, where applicable, by 2030 as part of the Canada-wide Action Plan on Zero Plastic Waste. Throughout the development of the Action Plan, the federal government has consistently overlooked the current state of the recycled material market and the time required for industry to transition production and implement changes to achieve this target. Recycled content targets have been, and will continue to be, extremely challenging for the beverage sector to achieve, given current market conditions for recycled content.
If the Canadian government is committed to a 50% target, then more time should be provided to industry to achieve it beyond the interim 2030 target. The existing issues with targets have only been exacerbated by the recent turmoil in cross-border supply chains, as the United States and Canada’s recycled material supply is interconnected. Since large producers rely on two unpredictable and complex markets for their recycled material, regulations should include provisions that acknowledge that, in some cases, meeting targets may not be within the producer’s control.
Recommendation 1.2 Synchronize reporting standards
According to the Beverage Container Recycling Network of Canada, there are a wide variety of definitions for “beverage containers” when recycling programs define recovery rates. Some programs are designated by beverage type, while others by container type. Of Canada’s seven provinces with DRS programs, most do not distinguish between PET and HDPE when reporting “plastic” containers collected; two programs only report on translucent HDPE containers, one program categorizes opaque HDPE in with “other plastics,” and three programs report gable top cartons in with “other plastics” rather than a separate category. In provinces with curbside non-deposit programs, there is a similarly lacking level of data transparency regarding the exact number of beverage containers collected for recycling and the number of units sold, with only the estimated total tonnage sold onto the market for all material types.
One of the most significant impacts of a National Recycling Framework would be a more standardized system for tracking and reporting recycling efforts. More consistent reporting standards are crucial for progress monitoring, assessing whether targets are on track, identifying areas for improvement, and eliminating redundancies in reporting requirements between all three levels of government.
Recommendation 1.3 Caps and Labels
PET and recycled PET (rPET) are very valuable materials in the Canadian plastics economy. HDPE (high‐density polyethylene)/ PP (polypropylene), the primary materials used in plastic bottle caps, are also valuable. However, unlike PET, HDPE can only be recycled up to ten times before its quality is compromised, while PP can only be recycled up to twice.1 Introducing recycled content minimum requirement regulations that include bottle caps and closures under scope would pose a health risk to consumers. It would result in degraded quality products due to issues such as scent retention. Furthermore, food-grade HDPE for caps is not available and commercialized. The technology to produce a sufficient supply of rHDPE for industrial use does not currently exist. For these reasons, the beverage industry strongly recommends that bottle caps and closures should be excluded from recycled content targets.
Recommendation 1.4 Advocacy for DRS
Currently, provinces with DRS programs, such as British Columbia and Alberta, achieve high recovery rates for non-alcoholic beverage containers, ranging from 77% to 85%.2 Ontario has the country’s lowest recovery rate at approximately 50%.3
The federal government can play a pivotal role as an advocate for deposit return systems (DRS) by promoting their environmental and economic benefits while respecting provincial jurisdiction over waste management. Rather than imposing a top-down mandate, Ottawa can act as a convener—bringing provinces, territories, and industry stakeholders together through forums like the Canadian Council of Ministers of the Environment to share best practices. This collaborative approach ensures that provinces retain control over program design while Canadians benefit from convenient and effective beverage container recycling.
Recommendation 2: Provide business certainty on retaliatory tariffs, including refunds on finished goods that have been granted remissions, limiting potential consumer price escalation.
Uncertainty around trade negotiations and increased input costs have placed Canadian beverage producers at a significant disadvantage. As many beverage inputs have little to no domestic supply (i.e. aluminum cans and lids, syrups, juices, etc.) beverage producers have been highly exposed to tariffs for over 6 months. While the remissions for aluminum cans and lids announced on April 15th by the Department of Finance and the removal of retaliatory tariffs on finished goods was welcome news, beverage producers have been managing the increased cost on several beverage inputs and finished goods. Since tariffs have been introduced, beverage producers in Canada have done everything they can to absorb these increases, but when input costs rise sharply, costs transfer through supply chain eventually leading to an increase for Canadian’s grocery prices.
Throughout this challenging time, beverage producers have focused their efforts on collaboration with all levels of government to prioritize Canada’s interests while minimizing the impact on consumer prices. Our members are committed to supporting Canadian jobs and near-shoring operations. With highly integrated supply chains, these changes cannot happen overnight, and companies need significant time and capital to find solutions. To this end, the CBA recommends that impacted beverage companies receive refunds on goods that have been subject to countermeasures, limiting potential price escalation for consumers and allowing producers to invest in supply chain resilience.
Recommendation 3: Exempt food and beverage from any mutual recognition in domestic free trade agreements and strengthen a single federal regulator for food and beverage manufacturing.
Science-based regulatory frameworks provide a modernized and consistent foundation that facilitates compliance, strengthens national food safety outcomes, and supports access to international markets with a unified, secure approach.
The government’s proposed regulatory change under the Free Trade and Labour Mobility in Canada Act to recognize Provincial and Territorial rules as appropriate alternatives will have the unintended consequence of introducing a patchwork of regulatory requirements for food and beverage that would hinder the movement and sale of products across the country, increasing the challenges for our industry in the domestic market. CBA believes that any unique Provincial and Territorial requirement(s) for food and beverage products are a barrier to trade. To this end, the CBA recommends that the Federal Government work to eliminate these unnecessary rules and establish Federal regulations as the sole authority for the sale of safe, properly labelled products in Canada. Caution should be applied in recognizing alternative regulatory requirements for food and beverage products. CBA encourages the government to conduct a more comprehensive consultation on this matter.