Bill 225 amends the Resource Recovery and Circular Economy Act, 2016 to expand the government's regulation-making power so Cabinet can establish a beverage container deposit program and set rules for blue box collection depots. The statutory change is aimed at folding deposit-return mechanics into the province’s broader resource recovery framework.
The Bill gives the regulations authority to require specific kinds of retailers to accept returned containers and to govern payment and refund mechanics. It adds new enabling subsections to section 107.1 of the Act to support those regulatory instruments.
At a Glance
What It Does
The Bill authorizes regulations that will create a deposit-return program for beverage containers and allow the government to designate and govern collection depots for blue box materials. The regulations — not the Act text itself — will set which containers are covered and the operational details of deposits and refunds.
Who It Affects
Large grocery-format retailers and the network operated by Brewers Retail Inc. will be first-order targets for collection obligations; producers, municipal blue-box systems, and recycling processors will also be affected indirectly when the deposit scheme interacts with existing recovery streams.
Why It Matters
This inserts a statutory pathway for a provincial deposit-return system into Ontario’s existing extended recovery regime and shifts collection responsibility onto retail networks rather than relying solely on curbside/municipal systems. That can materially change logistics, cost allocation, and recycling rates.
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What This Bill Actually Does
The Bill modifies the Resource Recovery and Circular Economy Act to let Cabinet make regulations that both create a beverage-container deposit program and require designated places to act as collection depots for blue-box material. Instead of spelling out every operational detail in the statute, the legislature delegates core design choices — which container types count, how the deposit is collected and refunded, and how depots operate — to the regulatory process.
The text establishes minimum deposit levels in the regulation framework: a baseline of 10 cents for containers of one litre or less and 25 cents for containers larger than one litre for any container defined in regulation as a blue-box material. It also supplies a statutory definition of “grocery store” used to target the retail locations that will be required to participate: stores over 4,000 square feet with significant grocery inventory (either at least 10,000 square feet devoted to food products or at least half of store floor space), offering a broad variety of canned, dry, frozen, fresh, meat, dairy, non-alcoholic beverage, baked goods and snack categories, and not branded primarily as a pharmacy.Operationally, the Bill requires stores that fall within that grocery definition and stores run by Brewers Retail Inc. to act as collection depots and to ensure returning consumers receive the applicable deposit refund.
The statute also places a duty on Brewers Retail Inc. and grocery store owners to make sure their outlets comply with the depot and refund rules — the regulations will define the practical steps but the Act makes noncompliance an enforceable offense. The statute sets a single commencement clause: the law takes effect one year after Royal Assent, placing a clear and relatively short clock on regulatory drafting and operational rollout.Because the authority is regulatory, many consequential design choices will appear outside the Act: how refunds are delivered (cash, vouchers, automated terminals), whether third-party refund processors are permitted, exemptions for certain container types, operational hours and space requirements for depots, and the interplay with existing municipal blue-box collection and producer responsibility programs.
Those details will determine how quickly retailers can adapt and how much of the system cost is borne by producers, retailers or consumers.
The Five Things You Need to Know
The Bill authorizes regulations that set a beverage container deposit program and the rules for collection depots but leaves the operational design to Cabinet-made regulations.
The statute directs regulations to set minimum deposit amounts of at least 10¢ for containers ≤1 L and at least 25¢ for containers >1 L for containers defined as blue-box material.
The Bill defines “grocery store” by size and product mix (over 4,000 sq ft retail; either ≥10,000 sq ft of food or ≥50% of floor space devoted to food, and a specified range of food categories) to identify which retailers must serve as depots.
Every grocery store and every store operated by Brewers Retail Inc. must act as a collection depot and ensure returning consumers receive the deposit refund; grocery store owners and Brewers Retail Inc. are legally required to ensure their stores comply.
The Act comes into force one year after Royal Assent, creating a one-year window for regulators and industry to implement systems and procedures.
Section-by-Section Breakdown
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Adds a statutory definition of “grocery store”
Section 1 inserts a specific, multi-part definition of “grocery store” into the principal Act. The definition uses both physical size (more than 4,000 square feet) and product-mix thresholds (either at least 10,000 square feet of food products or at least half of store floor space devoted to food), plus a list of required food categories and a carve-out for stores primarily identified as pharmacies. Practically, the definition draws a line to target larger-format supermarkets and exclude small grocers and most pharmacies; that line will determine which retail footprints face the operational obligations created later in the Bill.
Technical amendment linking enforcement authority
This short change adds a reference in subsection 98(2) to the new compliance subsection (107.1(5.3)). It’s a housekeeping step that brings the new compliance requirement within the Act’s enforcement architecture and ensures offences under the new regime can be addressed using existing enforcement tools in section 98. Expect subsequent regulations to specify penalties and enforcement procedures in more detail.
Delegates authority to create a deposit program and govern depots
The Bill expands the list of regulation-making powers in section 107.1 to include establishing and governing a beverage container deposit program and to require and regulate collection depots for blue-box material. By embedding the deposit program authority in the same section that governs blue box collection, the legislature intends the deposit regime to operate alongside — and be coordinated with — existing resource recovery rules. The concrete design (which containers; how credits/returns are handled; producer obligations) will be specified in regulation rather than fixed in statute.
Minimum deposits, depot duties, and owner compliance duty
Subsection (5.1) sets statutory minimum deposit thresholds (10¢ for ≤1 L, 25¢ for >1 L) for containers defined by regulation as blue-box material. Subsection (5.2) imposes an operational duty: every grocery store and every store run by Brewers Retail Inc. must act as a collection depot and ensure refunds are issued. Subsection (5.3) makes it an obligation on Brewers Retail Inc. and grocery store owners to ensure their stores comply with the depot duties. The statutory language frames these as duties enforceable under the Act, but the practical details — devices, staffing, hours, refund mechanisms, exemptions — are left to the regulations.
Commencement — one-year delay
The Bill sets commencement for one year after Royal Assent. That single provision creates a defined implementation window for regulators to draft rules and for impacted parties to update operations. From a compliance perspective, it places pressure on both government and industry to settle operational standards (refund mechanisms, signage, training) within a relatively brief period.
Short title
Provides the Act’s short title: Resource Recovery and Circular Economy Amendment Act (Beverage Container Deposit Program), 2024. This is a formal drafting element and signals the legislature’s intent to treat the deposit program as part of Ontario’s broader circular economy policy architecture.
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Explore this topic in Codify Search →Who Benefits and Who Bears the Cost
Every bill creates winners and losers. Here's who stands to gain and who bears the cost.
Who Benefits
- Consumers seeking refunds—They gain the ability to recover a per-container deposit at in-person depots, creating a direct financial incentive to return containers rather than discard them.
- Recycling and material processors—A deposit system typically raises return rates and improves material quality, which benefits processors by reducing contamination and increasing predictable feedstock volumes.
- Municipal waste systems—Municipalities may see lower volumes of beverage containers in blue-box streams, potentially reducing curbside collection costs and contamination burdens.
- Environmental NGOs and policy advocates—An enforced deposit-return mechanism provides a measurable policy lever to increase recycling rates and reduce litter, advancing circular economy objectives.
Who Bears the Cost
- Grocery store owners meeting the statutory definition—They must allocate floor space, staff time, and handling systems to accept returns and issue refunds, increasing operating costs and logistic complexity.
- Brewers Retail Inc.—As an owner-operator network explicitly named, it will need to rework store operations and back-office systems to comply and to ensure all outlets meet refund obligations.
- Provincial regulators and enforcement agencies—They will carry the administrative cost of drafting regulations, monitoring compliance, and enforcing offences unless offset by fees or producer contributions.
- Producers and brand owners—Depending on regulatory design, beverage producers may face new financial responsibilities (storage, handling, reimbursement schemes) or higher EPR fees to fund the deposit infrastructure.
Key Issues
The Core Tension
The central dilemma is between convenience-driven collection (mandating retail depots to maximize return rates) and the operational cost shifted onto retailers and operators. A store-based depot network improves consumer access and material quality, but without clear, enforceable cost-allocation rules in the statute, the Bill leaves regulators to choose who ultimately pays — a decision that will determine whether the program boosts recovery efficiently or simply burdens retail operations and raises consumer prices.
The Bill sets a statutory framework and minimum deposit levels but delegates nearly all operational detail to regulation. That delegation speeds legislative action but creates uncertainty: until regulations are published, retailers cannot finalize equipment purchases, staffing plans, or account systems, and producers cannot calculate their ultimate financial exposure.
The one-year commencement window compresses the timeline for rule-making and industry adaptation, increasing the risk of rushed or administratively heavy regulations.
Requiring grocery-format retailers and the Brewers Retail network to act as depots addresses convenience and geographic coverage, but it imposes concrete costs (space, labour, cash handling or terminal deployment) that the Bill does not allocate. The statute’s silence on who pays for the in-store infrastructure leaves open contentious design choices in regulation: should producers reimburse stores, should the government subsidize retrofits, or will retailers absorb costs and adjust margins?
Each choice reallocates costs among business, consumers and producers and will shape retailer support or opposition. Finally, the Bill integrates the deposit system into the existing blue-box/regulatory architecture, but it does not resolve overlaps: which containers travel through municipal programs versus the deposit system, how credits are reconciled, and how to prevent double-counting or diversion will all depend on complex regulatory coordination.
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