On April 20, 2024, the Government of Canada established a Federal Plastics Registry (the “Registry”), marking a significant move toward achieving its goal of zero plastic waste by 2030. The Registry is being implemented under the Canadian Environmental Protection Act, 1999 pursuant to a Section 46 notice published in the Canada Gazette, Part I (the “Notice”) and aims to track plastic from production by creating a national resource to support and inform Canada's efforts in tackling plastic pollution.
The Registry requires certain prescribed companies to report annually to the Minister of the Environment on the quantity and types of plastic they manufacture, import and place on the market, including the quantity of plastic collected for diversion, reused, repaired, remanufactured, refurbished, recycled, processed into chemicals, composted, incinerated and landfilled. Reporting entities will also be required to report on the methods used to determine the amounts of plastic reported. Reporting requirements will be introduced in phases each year (from 2024 to 2027, and beyond 2027) to allow time for obligated entities to meet reporting requirements. Phase 1 requires reporting on plastic placed on the market in three categories for 2024, while Phases 2 and 3 will expand the categories for reporting. Phase 4 reporting requirements will be covered in a future notice.
WHO IS REQUIRED TO REPORT?
An entity is required to report annually if it:
- manufactures, imports and places certain plastic resins listed in Schedule 1 of the Notice on the market in Canada;
- produces prescribed plastic products listed in Schedule 1 of the Notice;
- generates packaging and plastic product waste at an industrial, commercial or institutional facility; or
- is a service provider for the management of certain plastics or plastic products listed in Schedule 1 of the Notice (for example, incinerating, recycling or landfilling).
However, an entity is exempt from reporting if it:
- 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; or
- manages less than 1,000 kg of plastic via management services or activities per calendar year.
WHAT IS REQUIRED TO BE FILED?
Reporting entities will be required to complete an annual report outlining certain prescribed information on the Registry's online portal by September 29 of the following year. The report must also be certified by an authorized representative of the reporting entity, certifying that all information submitted pursuant to the report is true, accurate and complete.
NEXT STEPS
The Notice mandates reporting for calendar years 2024 to 2026, and the first report with respect to the 2024 calendar year is due on September 29, 2025. Reporting entities were provided with access to the online portal in the fourth quarter of 2024.
Looking forward, businesses involved in producing, importing, distributing or managing plastic products should begin defining reporting roles across the supply chain and establishing systems to accurately collect and submit data.
This article appeared in ESG and Sustainability: Key Trends in Canada
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