Electronic Devices: What Is The Liability Extended Producer Responsibility?

Consumers are increasingly aware of the importance of properly disposing of their electronic products. According to a regulatory framework, manufacturers, retailers, distributors and other suppliers of these products are required to do the same. They play a leading role in the responsible treatment of these residual materials across Canada. According to the various agreements across the country, these companies must contribute financially to the collection and recovery system.

Multiple Categories And Rates

The electronic products affected by Extended Producer Responsibility (EPR) programs are varied and include everything from computers and computer accessories to televisions and audio and video equipment. With regulations varying by provincial jurisdiction, there are currently more than 150 different tariffs with which companies must familiarize themselves.

All Canadian provinces are members of the Electronics Product Recycling Association (EPRA). This non-profit, industry-led organization coordinates regulated recycling programs to ensure that end-of-life electronics are handled safely, securely, and environmentally sound. Nine provinces have adopted the ARPE-coordinated "Recycle My Electronics" programs, while Alberta, the Northwest Territories and the Yukon have established their own structures.

Evolving Programs

Approaches continue to evolve in each province and territory to include more and more products at the heart of environmental management efforts.

Ontario, for example, stopped charging an ecofee at the time of purchase in 2019 and 2020 after large surpluses accumulated in its program. A new program in which producers can incorporate the fee into the selling price or charge it separately was subsequently implemented in early 2021.

As of April 1st, 2021, Prince Edward Island has enhanced its program by adding several categories of electronic devices to its environmental framework, such as clocks, space heaters, irons and many others. Similarly, Newfoundland has expanded its program as of November 1, 2021, to include mini-desktop computers, e-readers and portable video games, among others.

The rules for eco-fees continue to change regularly. Producers must therefore remain vigilant to ensure that they pay the required fees for each product.

Managing Your Environmental Costs Is Profitable

Understanding the fee structure and careful management can help avoid overclaiming and save significant money. Staying up-to-date on the programs' intricacies, which vary by jurisdiction, requires a thorough knowledge of the regulations in effect. This is why it is a good idea to consult experts who will be able to optimize each file thanks to their expertise and their in-depth knowledge of the various programs and regulations.

A Costly Error: Paying 24 Times Too Much!

To help companies comply with regulations and ensure the accuracy of their reports, Evnia performs a rigorous analysis of their reports to identify potential errors. This can be very beneficial. Here's a good example: while auditing the data of one of our clients, we discovered an overpayment of more than $200,000, which was caused by a simple data entry error. Instead of considering each product as a single unit, the client's Excel file applied a multiplier of 24 to the calculation.


Whether you are a producer or one of the players in the distribution network, managing ecofees requires constant attention. Beyond silly calculation errors such as the one mentioned above, keeping track of the numerous regulations and deadlines is an issue that should not be overlooked. This area is becoming increasingly specialized, and using specialized external advisors is an excellent solution to avoid unnecessary costs or penalties. Think twice about going at it alone!