Letter toQBCRA member growers
Dear members,
The QBCRA wishes to clarify certain information communicated in recent months, so that all producers covered by the Regulation respecting the development, implementation and financial support of a deposit-refund system for certain containers have a common understanding of article *98 regarding internalization and the possibility of making visible the contribution that will be invoiced as of March 1, 2025.
The regulatory concept is clear: internalization of the amount is compulsory if it is partially or fully included in the product's selling price (as opposed to the possibility for the producer to assume this contribution himself and not increase his product price).
This internalized amount can only be made visible at the producer's initiative. It cannot be outsourced like the CRF in some other provinces, and no price breakdown can be made.
In October 2024,QBCRA the following mechanism for invoicing from producer to retailer, assuming that a product is worth 99 cents and that a contribution of 1 cent is applicable:
On January 27, 2025, the department informed theQBCRA , in its opinion, the following change was required in the example provided: This makes it clear that the product costs $1 and includes a 1-cent contribution.
Here are two other billing models that comply with the Ministry's requirements:
*Example #1 - The contribution is internalized in the price without being made visible (display):
*Example #2 - The contribution is internalized in the price and made visible (display):
Please note that the example below does not comply with the regulations, as it involves outsourcing the contribution:
If changes to your billing system are required to comply with this obligation and cannot be completed by March 1, 2025, please notify us at [email protected].
We would also like to remind you that the costs associated with the management of containers previously declared for selective collection will no longer apply as of March 1, 2025, and this for containers that will be covered by the regulation during the second phase of modernization.
Finally,QBCRA that there are no changes to report regarding the retailer billing retailer end consumer. If the producer makes the (internalized) contribution visible, the retailer , although not required to do so, make this contribution visible. If the producer does not make the contribution visible, the retailer make it visible to the end consumer.
Best regards,
TheQBCRA team
*98. The amount set per container pursuant to the first paragraph of Article 95 may only be attributed to that container and, if it is partially or entirely included in the sale price of the product, it must be internalized in that sale price as soon as the product is marketed, placed on the market, or otherwise distributed. This internalized amount may only be made visible at the initiative of the producer who markets, places on the market or otherwise distributes the product, and this information must then be made visible by the producer as soon as the product is marketed, placed on the market or otherwise distributed. In such a case, the information must be accompanied by a statement that this amount is used to ensure the recovery and recycling of the redeemable container redeemable the web address where more information on this subject can be obtained.