by Rachel Kagan
From the evolution of Extended Producer Responsibility (EPR) for packaging, to plastics policy in flux, the pending CUSMA review, PFAS, and environmental claims, these are some of the environmental issues the Paper and Paperboard Packaging Environmental Council (PPEC) will be watching in the year ahead.
Extended Producer Responsibility (EPR)
Extended Producer Responsibility (EPR) – a policy approach where producers are financially and operationally responsible for managing the recycling of their packaging – continues to evolve across Canada, while new EPR laws are being introduced across the United States. Together, these developments are increasing costs and complexity across the packaging value chain.
In Canada, the most recent shift is in Ontario, where the Blue Box program transitioned from a municipally operated system with partial producer funding to a full producer responsibility model. As of January 1, 2026, obligated producers are 100% financially and operationally responsible for residential packaging and paper recycling.
As programs transition and expand, challenges, and learning curves are inevitable in a complex recycling system with multiple stakeholders and overlapping regulatory requirements. EPR is not a simple policy to explain or implement. As a result, media coverage and stakeholder communications will not always capture its full complexity, even as EPR reshapes recycling systems and influences packaging decisions across North America. EPR can be expected to remain a widely discussed issue in 2026.
Plastics
Canada’s plastics policy framework remains in flux. While the Single-Use Plastics Prohibition Regulations remain in force, the legal foundation underpinning the federal approach continues to be challenged. The Federal Court of Appeal has not yet issued its decision in Responsible Plastic Use Coalition v. Canada, a case that raises questions about the federal government’s designation of “plastic manufactured items” as toxic under the Canadian Environmental Protection Act (CEPA).
Although the ban remains in effect pending the Appeal, this ongoing legal uncertainty can make it harder for businesses to make decisions about packaging design and material choices.
Globally, negotiations toward a UN Global Plastics Treaty will continue in 2026. Canada, as a founding member of the High Ambition Coalition to End Plastic Pollution, reiterated its commitment to a global agreement when the G7 Environment Ministers met last fall and “reaffirmed their constructive engagement towards an international legally binding instrument on plastic pollution.”
Canada-US-Mexico Agreement (CUSMA)
While trade policy is not environmental policy, it can have potential impacts on recycling systems and packaging decisions. As PPEC previously noted in its blog, Exploring the Environmental Implications of Potential Tariffs, trade measures targeting specific materials or jurisdictions can influence supply chains, sustainability planning, and environmental outcomes in subtle ways.
The Canada–US–Mexico Agreement (CUSMA) is scheduled for its first six-year joint review in July. While the review is not expected to result in direct changes to recycling regulations, changes could potentially affect recycling systems, packaging decisions, and sustainability planning.
Per- and Polyfluoroalkyl Substances (PFAS)
Per- and polyfluoroalkyl substances (PFAS) – a class of chemicals used across various industries, found in products such as firefighting foams, textiles, cosmetics, and some types of food-contact packaging – remain an evolving issue, with regulatory activity accelerating.
Key issues for the paper packaging industry include the need to distinguish between intentionally added PFAS and unintentional, or legacy, PFAS, and how recycled content may be affected. As regulatory approaches continue to develop in Canada and globally, understanding how PFAS move through supply chains and recycling systems, and how they can be managed and mitigated, remains an evolving area of research.
Environmental Claims
PPEC continues to monitor developments related to making environmental claims in Canada, including Budget 2025’s proposal to amend certain greenwashing provisions under the federal Competition Act. Proposed changes include removing the requirement that environmental claims be substantiated using internationally recognized methodologies.
This comes on the heels of a recent leadership change at the Competition Bureau, as Commissioner Matthew Boswell ended his term early. Under his leadership, the Competition Act was amended to strengthen provisions aimed at addressing greenwashing, which is the act of making misleading or false environmental claims.
Taken together, these developments introduce uncertainty about how environmental claims will be interpreted and enforced going forward. As this evolves, businesses should be mindful of a shifting environmental claims legal and regulatory landscape in Canada and review company and product sustainability disclosures to assess risk and ensure appropriate substantiation.
PPEC’s Bottom Line
These issues reflect a common theme: environmental policy affecting packaging and recycling is becoming more complex and the impacts are adding up. In 2026, the industry will be dealing with several policies at the same time, many of which are still evolving.
