Canada has established a goal of zero plastic waste by 2030, and has established a variety of regulatory and informational programs to pursue that goal. As part of these effort, Environment and Climate Change Canada (ECCC) has established the Federal Plastics Registry (FPR), along with accompanying regulations requiring reporting by targeted producers of plastic packaging, electronic and electrical equipment, and single-use or disposable products. These entities’ reporting requirements expand annually in three “phases,” beginning with Phase 1 reports starting with selected 2024 data due by September 29, 2025. (I wrote about ECCC’s proposal to establish the FPR, HERE). The remainder of this note summarizes Phase 1 requirements and identifies Phase 2-4 targets.
What is the Federal Plastics Registry?
ECCC established the FPR to receive annual reports from companies (including resin manufacturers, service providers and producers of plastic products) on:
- quantities and types of plastic they manufacture, import, and place on the market
- quantities of plastic collected for diversion, reused, repaired, remanufactured, refurbished, recycled, processed into chemicals, composted, incinerated, and landfilled
- Amount of packaging and other plastic waste generated on industrial, commercial and institutional (ICI) premises.
Who must report?
ECCC published a Notice in the Canada Gazette in April 2024 (“Notice with respect to reporting of plastic resins and certain plastic products for the Federal Plastics Registry for 2024, 2025 and 2026”) defining reporting requirements. The following “persons” will eventually be required to report to the FPR beginning on deadlines set in the reporting phases described below (defined in Schedule 3 of the Notice):
- manufactures, imports, and places plastic resins (listed in Schedule 1, Parts 1 and 2) in market in Canada. Part 1 lists 23 classes of resins (identified by North American Product Classification System (NAPCS) Canada 2022 Version 1.0), including various polyethylene, PVC-based, petroleum- and bio-based, etc. Part 2 lists 4 types of resin sources: virgin fossil-based resin; virgin bio-based resin; post-consumer recycled resin; and post-industrial recycled resin.
- is a producer of plastic products (listed in Schedule 1, Parts 3 or 4). Part 3 lists 8 types of plastic packaging, filled and unfilled, rigid and flexible, used for beverage container, food contact material, packaging for hazardous materials, and other packaging. Part 4 lists categories and subcategories of plastic products: electronic and electrical Equipment (EEE; 14 subcategories); tires (9 subcategories); transportation (9 subcategories); construction (9 subcategories); agriculture and horticulture (15 subcategories); fishing and aquaculture (19 subcategories); apparel and textiles (8 subcategories); and single use or disposable products (5 subcategories).
- is a generator of packaging and plastic product waste at their industrial, commercial or institutional facility;
- is a seemrvice provider for the management of plastics or plastic products (listed in Schedule 1, Parts 3 or 4) including the following activities: collecting or hauling; arranging for direct reuse; refurbishing; repairing; remanufacturing; mechanical recycling; chemical recycling; processing into chemicals, including fuels; composting; incineration with energy recovery; incineration for industrial processes; incineration without energy recovery; landfilling.
- Manufactures, imports or places on the market less than 1,000 kg of plastic products or packaging per calendar year,
- Generates less than 1,000 kg of packaging and plastic product waste at their industrial, commercial or institutional facility per calendar year.
- Manages less than 1-000 kg of plastic via the activities listed in (4) per calendar year.
What must be reported in Phase 1 (by 29 September 2025) through 3?
ECCC has established three annual “phases” during 2025-2027, requiring additional information each year. Requirements apply
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Phase 1 (2024 data due by 9/29/25)
Phase 1 requires reporting by a person that imports, manufactures, and places plastic on the market in Canada in the following product categories destined for the residential waste stream:
- Plastic packaging, filled and unfilled
- Electronic and Electrical Equipment (EEE)
- Single-use or Disposable Products
These persons are required to:
- material report - for resins used in the manufacturing of the plastic packaging or product:
(a) the total quantity, in kilograms, of plastic packaging and products, by resin, resin source, category and subcategory, that are destined for the residential waste stream and that are manufactured in Canada, imported into Canada, and placed on the market in Canada in each province and territory, and
(b) the method used to determine the quantities above.
- administrative report - the following administrative information:
(a) name, email address, phone number, street address and, if different, mailing address of reporting person;
(b) federal business number assigned by the Canada Revenue Agency (CRA);
(c) name, email address, and telephone number of an individual who is an authorized person to contact about this program, or has authority to bind the person and takes legal responsibility for data submitted
(d) primary, secondary, and tertiary six-digit North American Industry Classification System (NAICS) Canada codes, if applicable;
(e) provinces and territories where the person subject places plastic products or resins on the market;
(f) any provincial and territorial EPR programs in which the person participates;
(g) any provincial and territorial stewardship programs in which the person participates; and
(h) any producer responsibility programs (PROs) the person engages and the provinces and territories in which those PROs operate on behalf of the person.
- Statement of Certification or electronic certification certifying that all information submitted pursuant to this notice is true, accurate and complete
- use FPR online reporting tool
The subject person may prepare and submit its report, or may use a PRO or other third party (in which case the third party must also submit specified information about itself).
In December 2024 ECCC published its “Guide for Reporting to the Federal Plastics Registry - Phase 1.” ECCC does not require persons to follow recommendations in the Guide, but instead intends the information in the 60-page Guide to facilitate initial reporting, by provide additional explanation and examples of calculation methods.
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Phase 2 (2025 data due by 9/29/26)
Phase 2 will add the following reporting, of 2025 data due by September 29, 2026:
- plastic waste generated at industrial, commercial and institutional (ICI) facilities in the three categories that reported in phase 1
- plastic collected at end of life, that and sent for diversion and disposal, for packaging and single-use plastics (but not EEE)
- imports, manufactures, and places plastic on the market in Canada by other categories listed in item number 2 above.
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Phase 3 (2026 data due by 9/29/27)
Phase 3 will add additional reporting on plastics collected and sent for diversion and disposal for EEE and tires. Reporting requirements for Phase 4 will be covered in a future information gathering notice.
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Phase 4 (to be determined)
ECCC describes initial Phase 4 reporting, which is intended to add reporting of plastic collected at end of life, that and sent for diversion and disposal, for the transportation, construction, and fishing and aquaculture categories, as to be commenced “beyond 2027.”
What happens now?
Non-exempt persons doing business in Canada and assigned to Phase 1 should be preparing to report required 2024 data by September 29, 2025. Persons that will be required to report in Phase 2 should be collecting data now in 2025 for reporting in 2026. Other Canadian entities should probably be reviewing their operations and data collection systems in anticipation of future reporting. Non-Canadian entities that export plastics to Canada should be taking steps to ensure that their customers and affiliates in Canada have access to appropriate data. Other non-Canadian entities with activities involving plastics should anticipate the possibility that other governmental jurisdictions (including US states, although probably not the US federal government during President Trump’s tenure) may impose similar requirements.
Self-assessment checklist
Do the organization’s activities in Canada include doing any of the following with plastic resins or items:
- Manufacture
- Import into Canada
- Place into Canadian market(s)
Do any of these activities involve plastics products that leave wastes after end users (the organization or its customers) finish with them?
If so, has the organization evaluated the volumes of such plastic materials and wastes, their materials flows after initial use, and methods available for management of any wastes?
Has the organization assumed any post-use responsibilities for such wastes?
Is the organization presently required to report any of this information, and if so to which governmental jurisdiction or organization?
Has the organization determined which of its activities in Canada will be subject to reporting to the Canadian Federal Plastics Registry, and in which phase(s)?
Where can I go for more information?
- ECCC –
- “Federal Plastics Registry” webportal
- “Canada’s Zero Plastic Waste Agenda” webportal
About the Author
Jon Elliott is President of Touchstone Environmental and has been a major contributor to STP’s product range for over 30 years.
Mr. Elliott has a diverse educational background. In addition to his Juris Doctor (University of California, Boalt Hall School of Law, 1981), he holds a Master of Public Policy (Goldman School of Public Policy [GSPP], UC Berkeley, 1980), and a Bachelor of Science in Mechanical Engineering (Princeton University, 1977).
Mr. Elliott is active in professional and community organizations. In addition, he is a past chairman of the Board of Directors of the GSPP Alumni Association, and past member of the Executive Committee of the State Bar of California's Environmental Law Section (including past chair of its Legislative Committee).
You may contact Mr. Elliott directly at: tei@ix.netcom.com