Registration requirements for Alberta Hazardous and Special Products (HSP)
Dear Product Care members,
As previously communicated, the Government of Alberta passed Extended Producer Responsibility regulations for Hazardous and Special Products (HSP) in November 2022.
The regulations define HSP in Alberta as:
- Corrosive products *
- Corrosive product containers*
- Flammable products*
- Flammable products containers*
- Pesticide containers*
- Toxic products*
- Toxic products containers*
*Supplied in quantities under 10Kg for solids, 10L for liquids and 680g for gaseous products.
Note: Paint is not included in the HSP regulations and remains under the ARMA paint program. Batteries will be managed by another PRO.
The Alberta EPR regulation created an Authority (oversight body) to administer the regulation. The Authority for HSP is the Alberta Recycling Management Authority (ARMA). The regulation gave ARMA the power to create by-laws that will governs the program, including but not limited to:
- Producers and PRO registration requirements
- Reporting requirements
- Fees paid to ARMA (fees TBD)
- Requirements of collection systems and consumer awareness
- Product scope clarification
- Records and data that must be collected and kept
- Inspections, verification and audits requirements
We have finally received an update from the Government of Alberta and the Alberta Recycling Management Authority (ARMA) on the by-laws of the HSP Program and can now share this information with Producers.
The by-laws require Producers to register with ARMA by Dec 31, 2023.
The program is required to be operational by April 1, 2025.
Product Care will be hosting three identical webinars, which will cover.
- Producer obligations
- Registration requirements
- Data requirements
- Next Steps
We encourage producers to register for one of these webinars through the following links:
Note: The webinars will present identical information. Producers only need to attend one.
Session #1: Wednesday, 27th September, 1:00 PM – 2:00 PM PT:
Session #2: Wednesday, 4th October 11:00 AM – 12:00 PM PT:
Session #3: Wednesday, 11th October, 11:00 AM – 12:00 PM PT:
What information do Producers need to register?
The registration for Producers will include submitting or confirming the following information to Product Care.
- Name, contact information, and address of the producer.
- Name and contact information of the person responsible for registering the producer (Primary contact).
- The brand name(s), if applicable, of each designated material (see key terms) that producers supplied to consumers in Alberta in the previous calendar year (2022). (See below)
- Whether the producer is a brand holder, an importer, or a retailer. (See below)
- Whether the producer is a franchisor with franchisees in Alberta.
- The weight (Kg or L) of designated material supplied to consumers in Alberta in the previous calendar year (2022).
How will producers provide this information to Product Care?
Product Care intends to have Producers register through our ehfreporting.com and submit the required data in line with how they currently submit their EHF data. Once ARMA has defined their reporting requirements, we will educate producers on how to submit this information.
Who is obligated as a “Producer”? / Brand Holder/ Importer / Retailer
The regulations (s. 14) define a Producer, for HSP, in a hierarchy, as:
- a) The brand holder of the product if the brand holder is a resident of Canada
- b) If there is no brand holder resident in Canada, the importer of the product is resident in Alberta
- c) If there is no person described in (a) or (b), the retailer who supplied the product to the consumer
How do I classify my products? / What is included in the Alberta HSP Program?
The definitions for what is included in the HSP regulations in Alberta broadly align with the definitions of HHW under the Manitoba HHW program.
The table below compares how products would be reported under the MB HHW and Alberta HSP programs. It is designed to allow producers who already categorize their products for the MB HHW Program to be able to quickly classify their products for the Alberta HSP program. For example, if a product is categorized as “Flammable Liquids/Solvents 0.75L or less” under the MB HHW Program, it will need to be classified as a flammable product under the Alberta HSP Program.
|Manitoba HHW Reporting Category||AB HSP Product Categories|
|Flammable Liquids/Solvents 0.75L or less||Flammable Products|
(Total Kg or L)
|Flammable Product Containers|
(Total Kg or L)
|Flammable Liquids/Solvents 751ml to 1L|
|Flammable Liquids/Solvents 1.01L to 2L|
|Flammable Liquids/Solvents 2.01L to 4L|
|Flammable Liquids/Solvents – Aerosols 75ml or less|
|Flammable Liquids/Solvents – Aerosols 76ml – 200ml|
|Flammable Liquids/Solvents – Aerosols 201ml or more|
|Physically Hazardous Products|
|Corrosives 0.75L or less||Corrosive Products||Corrosive Products Containers|
|Corrosives 751ml to 1L|
|Corrosives 1.01L to 2L|
|Corrosives 2.01L to 4L|
|Corrosives – Aerosols 75ml or less|
|Corrosives – Aerosols 76ml – 200ml|
|Corrosives – Aerosols 201ml or more|
|Toxics 0.75L or less||Toxic Products||Toxic Product Containers|
|Toxics 751ml to 1L|
|Toxics 1.01L to 2L|
|Toxics 2.01L to 4L|
|Toxics – Aerosols 75ml or less|
|Toxics – Aerosols 76ml – 200ml|
|Toxics – Aerosols 201ml or more|
|Pesticides 0.75L or less||Pesticide Products||Pesticide Products Containers|
|Pesticides 751ml to 1L|
|Pesticides 1.01L to 2L|
|Pesticides 2.01L to 4L|
|Pesticides – Aerosols 75ml or less|
|Pesticides – Aerosols 76ml – 200ml|
|Pesticides – Aerosols 201ml or more|
How do I quantify the weight of products I supply in or into Alberta?
Like the Ontario HSP program, the Alberta HSP program will require producers to report on each product category’s total weight (L or KG) rather than the units supplied. In their current form, the By-laws will require producers to report the total weight of designated product and the total weight of the containers separately.
Producers will need to
- Identify the weight (L or Kg) of each designated product (contained within the packaging).
- Identify the weight (kg) of the packaging of each designated product.
- Attend one of the webinar sessions to learn about the registration process and how to gather your data for registration.(see webinar information above)
- Producers must register by December 31, 2023.
- PROs must submit a collections and management plan to ARMA by October 1, 2024.
- The EPR System for HSP must be operational by April 1, 2025.
For further information or should you have any questions, please contact Richard Hodges at email@example.com