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Canada's Federal Plastics Registry (the "Registry") is entering Phase 2, bringing increased reporting obligations for plastics producers. The original deadline to report for Phase 2 was September 29, 2026, while the deadline for Phase 3 was set for September 2027. Environment and Climate Change Canada ("ECCC") has announced that they are delaying the reporting deadlines for both Phase 2 and Phase 3.
What is the Federal Plastics Registry?
The Notice with respect to reporting of plastic resins and certain plastic products for the Federal Plastics Registry for 2024, 2025 and 2026 (the "Notice") was published, in the Canadian Gazette on April 20, 2024. The Notice established the Registry which requires companies to report annually on the quantity and types of plastic manufactured, imported and placed on the Canadian market. It also requires generators of packaging and plastic waste at industrial, commercial and institutional premises, as well as service providers who collect and manage those wastes, to report to the Registry. Reporting is mandatory, and companies that fail to meet their reporting requirements could face penalties. For additional information on the totality of the regime please see our previous blog post.
Postponement of Phase 2 and 3
ECCC has explained that the decision to postpone Phases 2 and 3 follows feedback from industry stakeholders regarding the complexity of the expanded reporting obligations. According to ECCC, organizations expressed concerns about the level of detail required, the pace of implementation, and the need for additional time to put adequate data‑tracking systems in place. In response, and in the interests of "efficiency, responsiveness, and building a system that works better for everyone," ECCC has confirmed that all reporting requirements associated with Phases 2 and 3 will be delayed.
The delay is intended to:
- give ECCC an opportunity to streamline and optimize the reporting framework before it comes into force;
- use the additional time to refine the reporting requirements, reduce administrative burden where possible, and improve clarity for obligated parties; and
- allow producers, waste generators, and service providers more time to collect and prepare the high‑quality, consistent data that the Registry aims to standardize across Canada.
To implement these changes, ECCC plans to publish a new Notice in the Canada Gazette in Summer 2026 that will establish reporting requirements for the 2027, 2028, and 2029 calendar years. Prior to that, a Notice of Intent is expected in Winter 2026, which will provide stakeholders with advance information about the planned delay to Phases 2 and 3 and the government's intended approach.
Importantly, although Phases 2 and 3 are postponed, organizations must continue to comply with their Phase 1 obligations for the 2024, 2025, and 2026 calendar years. As outlined in the Notice, Phase 1 applies to producers of packaging, electronics and electrical equipment, and single‑use and disposable plastics destined for the residential waste stream. These reporting requirements remain in effect and unchanged.
Next Steps
McCarthy Tétrault's Environmental Law Group is advising clients across all industries and sectors on how to respond to reporting obligations under CEPA.
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