The federal government has now launched the reporting platform for Canada's Federal Plastics Registry. With the first reporting deadline looming on September 29, 2025 for the 2024 calendar year, obligated parties can now access the form of report and begin inputting their reportable data. This bulletin provides an overview of the Federal Plastics Registry and reporting requirements for this first phase of reporting.
What is the Federal Plastics Registry?
On April 20, 2024, the Government of Canada published the final notice for the establishment of the Federal Plastics Registry (the "Notice") under section 46(1) of the Canadian Environmental Protection Act, 1999 ("CEPA"). The Notice authorizes the Minister of Environment and Climate Change Canada ("Environment Canada") to collect data on plastics in Canada for the purpose of conducting research, creating an inventory of data, formulating objectives and codes of practice, issuing guidelines, and assessing and reporting on the state of the environment.
The Federal Plastics Registry requires companies to register and report on plastics supplied in Canada for the 2024, 2025 and 2026 calendar years. The reported information is intended to inform Canada's extended producer responsibility policy, which aims to improve waste reduction and recycling activities by extending a producer's physical and financial responsibility for a product to the post-consumer stage of its lifecycle (e.g., the end of the product's useful life when it becomes waste). This initiative is part of Canada's broader strategy to reduce plastic pollution and promote a circular economy, ensuring that plastic remains within the economy and is kept out of the environment.1
The new requirements mandate companies, including producers of plastic products, resin manufacturers and service providers for the management of plastics, to report annually to Environment Canada on the quantity and types of plastic they manufacture, import and place on the market. Additionally, producers of plastic products and service providers will be required to report on the quantity of plastic collected and diverted, reused, repaired, remanufactured, refurbished, recycled, processed into chemicals, composted, incinerated, and landfilled. Those who generate packaging or plastic product waste will also be required to report on the amount of packaging or plastic waste generated on their industrial, commercial, and institutional premises.
What does Phase 1 entail?
The reporting obligations under the Federal Plastics Registry will be phased in for the 2024, 2025 and 2026 calendar years. To date, Environment Canada has not made any announcements regarding the potential extension of reporting obligations beyond this timeframe. The first report for the 2024 calendar year is due September 29, 2025 and is referred to as "Phase 1" in Environment Canada's Guide for Reporting to the Federal Plastics Registry – phase 1. Phase 1 requires reporting from defined producers for plastic packaging (filled and unfilled), electronic and electrical equipment and single-use and disposable products that are destined for the residential waste stream, being products that typically accumulate in households (as opposed to products likely to end up in a commercial, industrial or institutional waste streams).
It is important to be aware that whether or not a party is determined to be a producer of a plastic product under the Federal Plastics Registry and obligated to report, (i.e., being a brand owner, manufacturer, importer, distributor or supplier), may differ from product to product due to variations in supply chains, brand ownership and a product's entry or manufacture in Canada within a single company. It is therefore necessary to closely consider how the producer definition applies to a company's structure and operations to assess the scope of its reporting obligations. Our bulletin Plan for the Ban: Canada's Federal Plastics Registry – Let's Talk Reporting Obligations provides additional information on how producers and the categories of obligated products are defined, as well as what information needs to be included in a company's report.
With less than four months before the reporting deadline and no extensions available, businesses obligated to report in Phase 1 should begin compiling data for completing their reports. Those companies obligated to report for 2025 should be well underway in gathering data as we are halfway through the 2025 calendar year. Entities who fail to report, fail to report on time, or knowingly report false or misleading information may face penalties under CEPA.
Footnote
1. Environment and Climate Change Canada, Canada's Zero Plastic Waste Agenda (14 June 2023).
The foregoing provides only an overview and does not constitute legal advice. Readers are cautioned against making any decisions based on this material alone. Rather, specific legal advice should be obtained.
© McMillan LLP 2025
