FAQ Members

Extended Producer Responsibility, or EPR, is an environmental policy approach in which a producer’s responsibility for a product extends to the post-consumer stage of its life cycle.​ Post-Consumer stage refers to waste that individuals would typically discard. EPR regulations in Canada are provincially regulated under ministries of the Environment.

EPR is provincially regulated in the following provinces:

1. British Columbia (Medications only)
   • Environmental Management Act – Recycling Regulation 449/2004​
2. Prince Edward Island ​​(Medications and Medical Sharps)
   • Environmental Protection Act ​- Materials Stewardship and Recycling Regulations EC349/14​
3. Manitoba ​(Medications and Medical Sharps)
   • The Waste Reduction and Prevention Act ​- Household Hazardous Material and Prescribed Material Stewardship Regulation MR 16 2010​
4. New Brunswick ​​(Medications and Medical Sharps)
   • Clean Environment Act – Designated Materials Regulation 2024-37
5. Ontario ​​(Medications and Medical Sharps)
   • Environmental Protection Act ​- Collection of Pharmaceuticals and Sharps – Responsibilities of Producers Regulation 298/12 ​
6. Quebec​ ​(Medications and Medical Sharps)
   • Environment Quality Act- Regulation amending the Regulation respecting the Recovery and Reclamation of products by Enterprises (Q-2, r 40.1)

• Prescription Drugs
• OTC (Over-the-Counter)
• NHP (Natural Health Products)

• Infusion Set/Infusion pods
• Lancets
• Needles
• Pen tips
• Syringes
• Prefilled cartridges
• Pen injectors and autoinjectors
• Continuous Glucose Monitoring (CGM) Devices
• Other

In all provinces, an obligated party, is the Brand Owner of the product brand or the trademark. In Quebec, obligated party or an “Obligated Enterprise” (Entreprise visée) is a Brand Owner with​

• a domicile or an establishment in Quebec, or ​
• a Quebec-based representative through which products are put on the market

If a Brand Owner does not fulfill the above conditions in Quebec – the First Supplier with a domicile or an establishment in Quebec or a Quebec-based representative is obligated

The Health Products Stewardship Association (HPSA) is a not-for-profit organization open to all brand-owners of health products in Canada. HPSA is currently the only Producer Responsibility Organization (PRO) managing Pharmaceuticals and Medical Sharps stewardship programs under EPR regulations in Canada.

In 1997, British Columbia passed the first regulation mandating medication brand-owners to provide environmentally responsible disposal methods for consumers. To ensure proper management of post, industry associations collaborated, leading to the formation of the Post-Consumer Pharmaceutical Stewardship Association in 1999, now known as HPSA. Founding industry associations include:

• Nonprescription Drug Association of Canada (NDAC), now Food, Health, and Consumer Products (FHCP)
• Pharmaceutical Manufacturers Association of Canada (PMAC), now Innovative Medicines Canada (IMC)
• Canadian Drug Manufacturers Association (CDMA), now Canadian Generic Pharmaceutical Association (CGPA)

HPSA has approved stewardship plans and is running the programs in all regulated provinces: British Columbia, Manitoba, Quebec, Ontario, Prince Edward Island and New Brunswick. In total 6 regulated provinces with 11 programs

HPSA is 100% funded by members, brand owners of obligated products under the EPR.

To ensure that the EPR regulatory requirements are met, HPSA’s mandate on behalf of its members includes:

• Develop, submit and renew stewardship program plans for medications and medical sharps, as required.
• Submit annual reports covering program performance.
• Manage collection network, supplies and service providers.
• Develop and implement communication campaigns to educate the public about proper collection and disposal.

Please reach out to us at member@healthsteward.ca to review your obligations and sign the membership agreement.

Program fees are based on member program share. Please reach out to us at member@healthsteward.ca to discuss the programs and the fees.

Stewardship programs developed and managed by HPSA only cover obligations pertaining to the collection of unwanted medications and used medical sharps (the content). You are required to participate in the Packaging and Printed Paper (“Blue Box”) programs managed by other PROs.