Program information
Program information
Program information:
Hazardous and Special Products (HSP) Program Overview
On November 30, 2022, Alberta’s Extended Producer Responsibility (EPR) Regulation (AR 194/2022) was enacted. This regulation (Alberta Regulation Extended Producer Responsibility Programs) mandates that obligated producers establish systems for managing single-use products, packaging and paper products (PPP), and hazardous and special products (HSP) by April 1, 2025.
Product Care is assisting producers in complying with the Alberta Hazardous and Special Products (HSP) regulations. We have registered as a Producer Responsibility Organization (PRO) with the Alberta Recycling Management Authority (ARMA. Our registration covers the following product categories: corrosives flammables (including gasoline), domestic pesticides, and toxics as defined in the regulation. Product care does not intend to be a PRO for batteries.
Who is obligated as a “Producer”?
The regulations (s. 14) define a Producer, for HSP, in a hierarchy, as:
- The brand holder of the product if the brand holder is resident in Canada.
- If there is no brand holder resident in Canada, the importer of the product resident in Alberta.
- If there is no person described in (a) or (b), the retailer who supplied the product to the consumer.
Who will regulate the HSP program?
The EPR regulation also creates an Authority (oversight body) to administer the regulation. The Alberta Recycling Management Authority (ARMA) has been designated as the Authority for HSP.
The regulation gives ARMA the power to create by-laws and Policies that will govern various parts of the program, including but not limited to:
- Producers and PRO registration processes.
- Any fees paid to ARMA (fees TBD).
- Reporting requirements.
- Requirements of collection systems and consumer awareness.
- Product scope, what is included and excluded.
- Records and data that must be collected and kept.
- Ability to undertake inspections and audits.
For more information on ARMA bylaws and updated ARMA policies see here:
- Alberta HSP By-Laws
- ARMA: info@albertarecycling.ca
- Alberta Environment and Protected Areas: aep.recyclingregulation@gov.ab.ca
Producers can work with a PRO, such as Product Care, by appointing them as an agent on behalf of the Producer or developing their own recycling program to meet their obligations.
Registration with Product Care as a PRO for Alberta HSP Products
Producers must first register with ARMA (see below) for HSP before registering with Product Care as a member of Product Care’s Alberta HSP program.
1. ARMA registration: The registration process for Alberta HSP now includes Producers providing basic contact details and company information and informing ARMA that they wish to delegate their requirements to a PRO. This will all be done through the ARMA connect portal – which is now open! See ARMA’s registration guide here.
The deadline to register with ARMA is March 1, 2024.
2. Product Care registration: Producers will still need to register with Product Care and become members of the Product Care Alberta HSP Program. This will be done through the Product Care reporting portal. Please refer to the Product Care’s AB HSP Producer Registration Guide located here.
The deadline to register with Product Care is March 1, 2024.
Key Dates
- Producers, and therefore PROs, will be required to provide verification of collection and management plans to ARMA by October 1, 2024
- The EPR System for HSP must be operational by April 1, 2025
- Producer registration with ARMA opens in November 2023, ARMA’s registration can be access here: ARMA connect portal.
- Deadline for submission of 2022 and 2023 supply data to ARMA is June 30, 2024. Note that the supply data must be verified.
Next Steps
- As more information becomes available, Product Care will provide further updates to member.