Federal Plastics Registry in Canada: Overview
The Government of Canada is implementing a comprehensive, first of its kind Federal Plastics Registry. This will require companies (including resin manufacturers, service providers and producers of plastic products) to report annually on the quantity and types of plastic they manufacture, import, and place on the market. Producers of plastic products and service providers will also be required to report on the quantity of plastic collected for diversion, reused, repaired, remanufactured, refurbished, recycled, processed into chemicals, composted, incinerated, and landfilled. This document provides a high-level overview of requirements. The online reporting portal will be available to stakeholders in the first half of 2025, before reports are due in September 2025.
Note: Canadian companies with an international supply chain may need to seek information from foreign suppliers to meet their reporting obligations. As such, the Plastics Registry requirements are of interest to both domestic and international plastics companies.
What is the Plastics Registry?
The Registry is a federal tool to compel plastic producers and other companies across the plastics value chain to report annually to Environment and Climate Change Canada (ECCC) to help monitor and track plastic from the time it is produced up to its end of life.
What is the purpose of the Plastics Registry?
The Plastics Registry addresses the need to develop and maintain Canada-wide data on how plastic moves through the economy.
The Registry will provide Canadians with reliable data that will identify opportunities for further action to reduce plastic waste and pollution, as well as help monitor progress over time.
Who is required to report into the Plastics Registry?
Producers: Need to report on upstream data, like plastics placed on the market and downstream data like plastics collected for diversion. A producer is defined as:
- A brand owner or intellectual property holder who resides in Canada.
- If the brand owner is not a resident of Canada, then the first resident person to manufacture or import a plastic product in Canada is defined as the producer.
- If there is no person as described in the above bullet points, the producer is the Canadian retailer who supplied the product to the consumer.
- If the producer is a retailer and that retailer is a marketplace seller, the marketplace facilitator that contracts with the marketplace seller would be the producer.
Generators of Plastic Waste: Entities which send plastic waste and plastic- containing packaging waste for disposal or diversion from their industrial, commercial, or institutional facilities.
- Inclusion of these entities captures those that generate plastic waste even if they are not a producer obligated to report upstream data to the Federal Plastics Registry.
- Need to report on the quantity and type of plastic waste generated at their facility and sent for diversion or disposal activities.
Service Providers: A person who is a service provider for the management of plastics or plastic products including, without limitation, via 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.
- Need to report on quantities and types of plastics for each of the previous activities.
What information will be collected in the Plastics Registry?
The information collected will go beyond plastic packaging and other plastic categories currently captured through domestic extended producer responsibility (EPR) programs.
Producers of plastics will have to report the quantities of plastic they import into, manufacture in and place on the market in Canada on an annual basis as per the following criteria:
Waste streams: • Residential • Industrial, Commercial and Institutional (ICI)
Product categories and subcategories: • Packaging • Single-use or disposable plastic • Electronic and electrical equipment (including appliances) • Tires • Transportation • Construction • Agriculture and horticulture • Fishing and aquaculture • Textiles and apparel
Resin sources: • Virgin fossil-based conventional resin • Virgin bio-based conventional resin • Post-consumer/industrial recycled resin
Resin type: 23 resin types according to the North American Product Classification System
When is reporting due?
Reporting requirements for the Federal Plastics Registry will be introduced in phases to allow time for those obligated to report to meet the requirements.
- Phase 1 reporting to the Federal Plastics Registry is due September 29, 2025, requiring reporting on plastic placed on the market in three categories for the 2024 calendar year.
- Category of Plastics to be Reported: Packaging, single use and disposable plastics and electronics and electrical equipment destined for the residential waste stream only.Reporting Requirements: Total quantity, in kilograms, of plastic packaging and products that are: (a) manufactured in Canada, if any, (b) imported into Canada, if any, and (c) placed on the market in Canada and in each province and territory.
- Information to be Reported: • Resin type • Resin source • Category of plastic products • Subcategory of plastic products • Quantity of each resin in packaging or plastic products in kilograms • Calculation method.
- Phase 2 reporting is due September 29, 2026, requiring reporting on plastic placed on the market for the 2025 calendar year. This phase adds reporting requirements for resin manufacturers and importers, for the three categories that reported during Phase 1, as well as reporting on plastic placed on the market for remaining categories. Phase 2 will also see the introduction of reporting on plastic waste generated at ICI facilities and the introduction of reporting for plastic collected and sent for diversion and disposal for some categories.
- Phase 3 reporting is due September 29, 2027, requiring reporting on plastic placed on the market for the 2026 calendar year. This phase adds additional reporting on plastics collected and sent for diversion and disposal for more categories.
- Phase 4 reporting is due September 29, 2028, requiring reporting on plastic placed on the market for the 2027 calendar year. Requirements will be covered in a future information gathering notice.
Under what authority is the Federal Government seeking this information?
The Government of Canada issued a Section 46 Notice. This is a mandatory information gathering survey issued under subsection 46(1) of the Canadian Environmental Protection Act, 1999 (CEPA).
The Section 46 Notice for the Federal Plastics Registry was published in Canada Gazette, Part I on April 20, 2024.
A Section 46 Notice is different than a regulation under CEPA:
- It is only valid for three years and must be republished.
- It is not dependent on Schedule 1 of CEPA listing.
Where can I learn more about the requirements?
Complete details are available on the Government of Canada website at: Federal Plastics Registry – Canada.ca and Canada Gazette, Part 1, Volume 158, Number 16: GOVERNMENT NOTICES.
A guidance document has been prepared to provide assistance in responding to the requirements. The Guide for Reporting to the Federal Plastics Registry – Phase 1 is now available upon request. To obtain a copy, please submit a request by email to [email protected].