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24th September 2025

Pilot study on the collection of empty HHW containers in BC

On December 16, 2024, the BC Ministry of Environment and Parks (BC MEP) issued a letter to producers requesting information on how they intend to meet their obligations for empty Schedule 2 containers (solvents/flammables, domestic pesticides, and gasoline containers). Product Care informed members of this development and provided a link to the Ministry’s letter in our notice: Producer obligations for empty household hazardous waste containers in British Columbia.

The Retail Council of Canada (RCC) and the Canadian Consumer Specialty Products Association (CCSPA), on behalf of their members, highlighted to the BC MEP the lack of data to support the development of a program for these empty containers. They requested that time be allowed to conduct a pilot study to gather the necessary information to make an informed decision, and have asked Product Care to carry out this pilot on industry’s behalf. Product Care developed and shared a project outline with RCC, CCSPA, and the BC MEP, and the Ministry has since provided acceptance of the proposed project scope.

The pilot project will run in three phases.

  1. Planning and research – September to December 2025
  2. Implementation – January to December 2026
  3. Analysis and reporting – January to April 2027

NOTE: The pilot is being conducted solely at the request of industry to support producers in meeting regulatory obligations. It does not represent an industry mandate for Product Care, or a commitment by Product Care to manage these containers under the currently approved Paint and HHW stewardship program, nor under the revised program plan currently under review. Decisions about the management of empty containers rest solely with industry upon the conclusion of the pilot study. The purpose of this pilot is to provide the information needed to help inform that decision.

If you have any questions regarding the pilot project, please don’t hesitate to contact us at bcpaintrecycle@productcare.org.

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