As the calendar turns over to April, thousands of companies across Canada are entering that period of true taxation frustration.  No, not CRA time, but CSSA time.  Having closed out year end and the required audits, many finance departments within obligated companies (also known as stewards or producers) are turning their attention to the next deliverable on their list – preparing the annual printed paper and packaging (often called Blue Box) stewardship reports that are due for up to 4 provincial programs by May 31st, 2018

Viewed by many companies as an “indirect tax”, the Blue Box stewardship reports will help determine what companies will be obligated to pay in 2019.  However, unlike some traditional corporate financial reporting, Blue Box annual reporting is rarely simple and straightforward for companies to complete each year.  New products and vendors, changes to packaging, mergers and acquisitions, and the always-popular internal staff changes are all factors that can make this annual ritual challenging for stewards.  CSSA has implemented some significant changes to the timeliness of the reports.  They will now assess penalties and interest charges for reports that are not filed by the reporting deadline.  These penalties are new for RecycleBC (MMBC), Saskatchewan (MMSK) and Ontario (SO).

Missing deadlines now has a financial impact!

The Growing Landscape of Environmental Stewardship

Stewardship programs are here to stay in Canada.  In addition to the 5 provincial programs for Blue Box materials, there are stewardship programs in most provinces for used tires, used oil, waste electronics of various types, left over paints and household hazardous waste to name a few.  Some large retailers who operate across Canada may be reporting to over 50 provincial stewardship organizations.  These reporting requirements can be monthly, quarterly or annually and the time and resources many companies spend on reporting compliance each year is a growing, hidden cost of stewardship in Canada.

As we talk to more and more companies, it is clear that stewardship reporting fatigue is setting in and is becoming a real issue for the stewards and the programs themselves.  In our work, we continue to see countless examples of over-reporting, under-reporting, and no reporting across many of the programs.  Incorrect reporting can expose stewards to unnecessary costs and/or the legal risks. If you are a company struggling with these reporting challenges, know that you are not alone.

Ongoing Changes in Ontario

The new Waste Free Ontario Act will see the elimination of the monopoly programs for tires, waste electronics, household hazardous waste, and Blue Box materials over the coming years.  Will the future allow companies the opportunity to streamline and rationalize reporting requirements?  It is too soon in the process to tell.  Sadly, even if reporting efficiencies were to be achieved in Ontario there are many other programs across the country that will continue to need detailed reporting. Consequently, until then, Stewards must work within the confines of the current protracted requirements related to stewardship reporting in Canada.