Refining Ash and Waste Definitions for Pulp and Paper Mills
The Regulation to amend the Regulation respecting pulp and paper mills (O.C. 892-2026) under Québec’s Environment Quality Act (chapter Q-2), updates the province’s framework governing the management of residual materials generated by pulp and paper manufacturing operations. The amendment is under the Government of Québec’s broad statutory authority under sections 53.30 and 70 of the Environment Quality Act, which empower it to regulate both the recovery/reclamation and elimination of residual materials, including setting binding standards for processing, storage, disposal, and facility operation.
Substantively, the amendment revises the definition of “mill residual materials” in section 1 of the Regulation respecting pulp and paper mills. Key changes include the removal of “ash from a combustion facility” and adjustments to the terminology and classification of certain by-products such as “dregs” and “slaking.” The revised definition clarifies that ash from combustion facilities and other non-hazardous manufacturing residues remain included within the regulatory scope, but with updated wording intended to better distinguish between hazardous and non-hazardous materials under section 1 of the Environment Quality Act. This refinement aims to improve regulatory precision in determining which residuals are subject to specific recovery or disposal obligations.
Further amendments are made to sections 93 and 98, narrowing and clarifying permissible disposal pathways for certain residual materials. Notably, references allowing disposal in solid waste sanitary landfill sites compliant with Division IV of the Regulation respecting solid waste are removed in several instances. This signals a tightening of regulatory controls and a shift away from landfill disposal options for certain pulp and paper residuals, particularly those associated with combustion processes, unless they meet specific non-hazardous criteria.
Section 117 is modified to exclude ash from certain general categories while explicitly adding a new provision allowing residual materials consisting entirely of non-hazardous ash from sawmill combustion facilities. A similar change is made to section 129, reinforcing a consistent regulatory approach across multiple sections. These amendments collectively establish a clearer classification regime for ash-based residuals, distinguishing sawmill combustion ash as a distinct category eligible for specified handling conditions when it is non-hazardous.
Overall, the regulatory changes reflect a broader policy objective of improving environmental control over industrial residual materials, improving classification clarity, and restricting less controlled disposal methods such as landfill use. By refining definitions and tightening disposal rules, the amendment strengthens Québec’s residual materials management framework, particularly in the pulp and paper sector, while maintaining flexibility for non-hazardous by-products under controlled conditions.
Quebec (892/2026) June 30, 2026
Disclaimer: Insights are for informational purposes only and does not reflect RRI’s official position or constitute legal opinion.
