Understanding Your Responsibilities as a Producer in the Return-It Program

Under British Columbia’s Extended Producer Responsibility (EPR) policy framework, the BC Recycling Regulation requires producers that supply beverage container products into the BC marketplace to take responsibility for the life cycle of their containers, including end-of-life collection and recycling.

As per the BC Recycling Regulation, a producer is defined as someone who sells, offers for sale or distributes ready-to-drink beverages in sealed containers in British Columbia. A producer may also include a manufacturer’s agent or a person who imports into British Columbia, for sale within the province.

If you have appointed Encorp as your agency to fulfill your obligations under the BC Recycling Regulations, you still retain important responsibilities as a producer. Your two primary responsibilities are: registering beverage containers and reporting sales / remitting fees.

Registering Beverage Containers with Encorp

Registering your beverage containers ensures they are recognized as part of the Return-It program and can be accepted at depots for deposit refunds. All beverage containers sold in British Columbia must be registered with Encorp before they are supplied to the marketplace.

The only exception is when you have a remitting agreement with a retailer or distributor that has agreed to register containers and report sales on your behalf. In this case, a Remittance Relationship Agreement must be signed by all parties, including Encorp, and be on file with Encorp before it is considered valid.

A remitting agreement applies only to the products sold to that specific retailer or distributor. If the same product is sold to other retailers, distributors, brokers, wholesalers or customers that are not covered by a remitting agreement, you remain responsible for registering those containers and reporting those sales to Encorp.

Reporting Sales and Remitting Fees

Accurate and timely sales reporting is an essential part of the Return-It program. Monthly beverage sales reports, together with the associated deposits and container recycling fees (CRFs), are due by the 7th day of the month following the month of sales.

Sales data is used to calculate recovery rates that are reported annually under the BC Recycling Regulation.

Late sales reporting or fee remittance may result in interest charges, stricter deposit remittance requirements, or deregistration from the Return-It program. Chronic reporting delays or significant accounts in arrears may also delay registration of new beverage containers until the overdue account is brought into good standing.

As a producer, you are responsible for reporting:

• Direct sales: Any products sold directly to retailers, hospitality businesses or consumers in BC.

• Sales through non-remitting distributors: Any inventory sold to wholesalers, distributors, brokers or other intermediaries that are not covered by a signed Remittance Relationship Agreement, on file with Encorp.

• Samples, promotions and donations: Any promotional products, samples or donated products distributed in BC.

If you are unsure about your responsibilities as a producer, please contact the Brand Registry team at brandregistry@returnit.ca.

For any accounting inquiries, including questions related to sales reporting, deposits, or CRFs, please contact Bev Corrigan at bcorrigan@returnit.ca.