Depot Compliance

Depots are assessed for areas of success and compliance with the following:

• Quality Control Compliance Framework
• Refund Compliance Framework
• Operational Compliance Framework
• Uniform Code of Accounts Compliance Framework
• Investigative Processes
• Customer Complaints

Additional inspections will be conducted where necessary:

Annual depot inspections help ensure Alberta’s beverage container recycling system operates fairly, consistently, and in compliance with regulatory requirements. Inspections also provide an opportunity for depot operators to ask questions, discuss operational challenges, and receive guidance from BCMB Compliance Officers.

Annual inspections provide an opportunity for Compliance Officers and depot operators to work together to address questions, review requirements, and resolve compliance issues. This collaborative approach helps maintain the integrity and accountability of Alberta’s beverage container recycling system.

Refund Compliance

All depots participate in BCMB’s Refund Compliance Program, which helps ensure Albertans receive the correct refund for their returned beverage containers.

Under Alberta’s Beverage Container Recycling Regulation, depots must provide a refund of $0.10 for registered beverage containers of 1 litre or less and $0.25 for registered beverage containers over 1 litre.

Customer confidence and the reputation of Alberta’s beverage container recycling system are heavily influenced and enhanced by depots providing accurate refunds.

BCMB requires all depots to strive for refunds that are 100% accurate.

Refund Compliance Standards:

BCMB’s Refund Compliance Program helps ensure customers receive accurate refunds for returned beverage containers.

Compliance

A depot is considered compliant when the refund provided is within 3% of the expected refund value for the order.

Non-Compliance

A depot is considered non-compliant when the refund provided is more than 3% below the expected refund value for the order.

Audit Resulting in Non-Compliance

A depot is considered non-compliant when the refund paid is more than 3% below the expected refund value for an audited order.

When a depot receives a non-compliant audit result, it enters BCMB’s Refund Compliance Framework. The framework is designed to support corrective action while encouraging continued compliance with refund requirements.

Framework Level	Outcome
Level 1	The depot receives a follow-up audit within 180 days.
Level 2	Triggered by a second non-compliant audit result. The depot is assessed a $400 compliance fee and receives another audit within 180 days.   If the third audit results in non-compliance, the depot will remain in Level 2 of the Refund Compliance Framework, will pay a $400 compliance fee and will receive a fourth audit within 180 days.
Level 3	If the fourth audit results in non-compliance, the depot enters Level 3 of the Refund Compliance Framework, will pay a $400 compliance fee and will receive a fifth audit within 60 days.
Further Action	If the fifth audit results in non-compliance, the depot may be referred to the Complaints Director for further action.

Refund Compliance Results [HH1] 

Uniform Code of Accounts (UCA) Compliance

The Uniform Code of Accounts (UCA) is an integral component of Alberta’s  beverage container recycling system. Completion of the UCA is mandatory as the operational and financial data submitted from each depot in Alberta is used to assist the Data Collection Agent (DCA) in recommending handling commissions

UCA Process and Compliance

Each year, depots are emailed with a UCA package from the DCA that includes a series of forms and a UCA Instruction Manual approximately five months before the filing deadline.

 The DCA is a third-party contractor hired to collect, analyze and report on UCA information for the purpose of determining handling commissions.

UCA Submission Deadline

Depots must submit a complete and accurate Uniform Code of Accounts (UCA) to BCMB’s Data Collection Agent (DCA) at least 20 days before the end of the sixth calendar month following the depot’s fiscal year-end.

Example: If a depot’s fiscal year-end is December 31, the UCA must be submitted by June 10.

Depots are encouraged to submit their UCA well before the deadline to allow the DCA sufficient time to review the submission and identify any missing or inaccurate information. it is highly recommended that a depot submits its UCA before the last day of its filing period to provide the DCA with time to verify the submission.

When Is a UCA Considered Submitted?

A UCA is not considered submitted until it has been reviewed and accepted by the DCA as complete and accurate.

To be considered complete, a submission must include:

• A fully completed UCA with accurate and verifiable information
• All required supporting documentation
• All required signatures

Grace Period

The Depot By-law includes a seven-day grace period before BCMB issues a compliance fee for a late or non-compliant submission.

The grace period is not an extension of the filing deadline. Instead, it provides time for the DCA to review the submission and work with the depot to address any errors, omissions, or missing information.

Legislative Requirements

UCA reporting requirements are outlined in Sections 12.42 to 12.49 of BCMB’s Depot By-law.

Quality Control Compliance

Audit Summary Results (ASRs) are the results of audits conducted on shipping containers that are shipped to the Collection System Agent (CSA, also known as the ABCRC) from depots.

ASRs help depots monitor shipping accuracy and idenfity opportunities to improve counting and sorting processes. They also identify any non-beverage containers, refillable beverage containers, or non-deposit beverage containers included in a shipment.

Shipping Accuracy Zones

Each shipment is assigned a zone based on the variance between the number of containers reported by the depot and the number verified by the CSA.

Zone	Variance
Zone 1	-2.5% or better
Zone 2	Worse than -2.5%

A shipment in Zone 1 indicates the reported container count is within the acceptable variance threshold. A shipment in Zone 2 indicates the shipment exceeded the acceptable variance threshold and may require corrective action to improve reporting accuracy.

• Note: All Zone 2 audit results are issued through the Quality Monitoring System (QMS) and sent to the depot’s industry email account. Depots should review their industry email account each operating day to ensure timely receipt of audit results and related communications.

Zone 1 and Zone 2 audit results form the basis of the Quality Control Framework. BCMB reviews audit performance over time to identify depots that may require additional monitoring, support, or corrective action.

Quality Control Framework

The Quality Control Framework is designed to support shipping accuracy and continuous improvement for depots.

A depot will enter Level 1 of the framework when either of the following conditions is met:

• Worse than -1.7% for all containers 1L or less
• Worse than -3.5% for all containers over 1L
• Worse than -2.0% for all containers

Material Stream Variance

• Any material stream variance, in any one audit, exceeds -7% 

The Quality Control Framework is designed to support continuous improvement in shipping accuracy. Depots may receive additional audits and compliance actions if performance does not improve. As performance improves and compliance is restored, depots may exit the framework.

For more information, refer to Section 12 of the Depot By-law.

Challenging an Audit

Depots receive Audit Summary Results through the Quality Monitoring System (QMS). 

If a depot wishes to challenge an audit result:

• The challenge must be submitted through the QMS by responding to the original audit ticket.
• Responding to the original QMS ticket is the only method for challenging an audit.
• QMS notifications are sent to the depot’s industry email account. Depots should monitor this account each operating day.
• A depot must indicate its intent to challenge an audit within one operating day of receiving the ASR.
• For detailed requirements, refer to Article 5 of the ABCRC and ABDA Service Agreement.

What Happens When an Audit is Challenged?

• When an audit is challenged:
• The ABCRC will arrange a date and time for the recount.
• A depot representative may attend the recount at the ABCRC facility.
• If a depot representative is unavailable, the depot may request assistance from the ABDA. In exceptional circumstances, BCMB may attend on the depot’s behalf.
• The shipment will be segregated until the recount is completed.
• The recount will be recorded, and the verified recount result will become the final count.
• If the recount result differs from the original count, the revised count will be applied to the depot’s payment.

Appealing a Compliance Fee

A depot may appeal a compliance fee by submitting a Notice of Appeal to BCMB.

An appeal may be made if the depot believes:

• BCMB did not have the authority to issue the compliance fee.
• BCMB failed to follow its procedures, and that failure had, or may reasonably have had, a material impact on the decision.
• The decision was influenced by bias.
• BCMB failed to consider relevant information or relied on irrelevant information when issuing the compliance fee.

Appeal Deadline

A Notice of Appeal must be submitted within 30 days of the date the compliance fee notice is deemed to have been received.

Submit an Appeal

If you have received a compliance fee and wish to appeal it for one or more of the above reasons, you must submit the Notice of Appeal Form below to BCMB:

• Compliance Fee Appeal Application