Plan For The Ban: UPDATE Environment Canada Clarifies Timing For Delay Of Phases 2 & 3 Of Canada’s Federal Plastics Registry

In January 2026, Environment and Climate Change Canada ("ECCC") announced that all reporting requirements for Phases 2 and 3 of Canada's Federal Plastics Registry will be delayed, but did not issue any formal notices, proposals or amendments or provide timelines for the length of the delay. However, on March 14, 2026, ECCC published a Notice officially delaying Phases 2 and 3 of the Federal Plastics Registry and pushing such reporting requirements to at least the 2027 calendar year.

This bulletin provides a summary of ECCC's Notice as an update to our last bulletin on the initial announcement here, as well as a discussion of the implications for businesses.

Delay Timelines

Producers of packaging, electronics and electrical equipment and single-use and disposable plastics destined for the consumer waste stream were required to report their Phase 1 data for the 2024 calendar year on September 29, 2025.¹ There have been no changes to the Phase 1 requirements, and these producers must continue to report their Phase 1 data for the 2025 and 2026 calendar years (due on September 29, 2026 and 2027, respectively).²

Phase 2 introduces reporting on all Phase 1 plastics regardless of their destined end-of-life waste stream as well as plastic placed on the market in the remaining categories that are not covered in Phase 1 (being plastic resins, agriculture and horticulture, tires, transportation, construction, fishing and aquaculture, and textiles and apparel).³ Phase 2 also requires reporting on plastic collected and sent for diversion and disposal in some categories.⁴ Phase 3 further expands the reporting requirements to include plastics collected and sent for diversion and disposal in additional categories, namely electronic and electrical equipment and tires.⁵

The Notice removes all reference of these additional reporting requirements for the 2025 and 2026 calendar years, meaning no data from the additional categories set out in Phases 2 and 3 needs to be reported for these years.⁶

The Notice does not set out any new reporting deadlines for Phases 2 and 3.⁷ Instead, ECCC will be issuing a new notice for the 2027, 2028, and 2029 calendar years that will presumably include updated reporting timelines for Phases 2 and 3 in the following September after the reporting period.⁸ ECCC will be soliciting feedback on the new notice once issued.⁹

Planning Ahead for Your Business

The delay to Phases 2 and 3 gives some breathing room for companies that are not obligated to report under Phase 1. It also gives ECCC time to refine the regulatory framework. Companies should remain alert to the other plastics reporting requirements across Canada, including provincial EPR programs. Our environmental team at McMillan is available to assist in determining your company's specific obligations under both the applicable provincial extended producer responsibility programs and the Federal Plastics Registry.

We will continue to monitor updates to plastics regulation across Canada and provide updates in our "Plan for the Ban" series. If you have any questions about how these changes will impact your business, please contact the authors of this bulletin.

Footnotes

1. Environment and Climate Change Canada, "Federal Plastics Registry" (modified 13 March 2026); Notice with respect to reporting of plastic resins and certain plastic products for the Federal Plastics Registry for 2024, 2025 and 2026, (Department of the Environment) (2024) C Gaz I, (vol 158 no 16) Original Notice. .

2. Notice amending the Notice with respect to reporting of plastic resins and certain plastic products for the Federal Plastics Registry for 2024, 2025 and 2026, (Department of the Environment) (2026) C Gaz I, (vol 160 no 11) Amended Notice. .

3. Original Notice, supra note 1.

4. Ibid.

5. Ibid.

6. Amended Notice, supra note 2.

7. Ibid.

8. Notice of intent to issue a notice under section 46 of the Canadian Environmental Protection Act, 1999 with respect to reporting of plastic resins and certain plastic products for the Federal Plastics Registry for 2027, 2028 and 2029, (Department of the Environment) (2026) C Gaz I, vol 160 no 11.

9. Ibid.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.