Canada Publishes Phase 1 Guidance for the Reporting of Plastics

Introduction 

On December 31, 2024, the Government of Canada published a guide for reporting to the Federal Plastics Registry (Registry). As discussed in our previous bulletin, the Government of Canada established the Registry in 2024 pursuant to a Notice. This Notice 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.

These reporting obligations will be phased in over three years, referred to in the guide as phases 1, 2 and 3.

In Phase 1, producers of plastic packaging, electronic and electrical equipment and single-use or disposable plastic products are required to submit their first annual report on September 29, 2025, which will cover activities during the 2024 calendar year. In subsequent years, additional categories of producers, service providers and plastic waste generators are required to report.

The newly published guide (Guidance Document) focuses on Phase 1 reporting requirements, offering guidance on who must report, which materials are covered by the Notice, what information needs to be reported for each material category and how to calculate material volumes for the purposes of reporting.

Key Information in the Guidance Document 

More specifically, the Guidance Document:

• Assists companies with determining whether they need to report by explaining key definitions, including “producer,” “marketplace seller,” “marketplace facilitator,” “placed on the market,” and “residential waste stream,” and by offering examples of how these concepts apply to concrete scenarios.
• Provides clarification on reporting exemptions and includes practical examples.
• Clarifies the resin types, resin sources, plastic packaging and plastic products covered by the Notice.
• Expands on the information that obligated persons must report, including details on resins, plastic packaging and plastic products. For products made entirely of plastic or those with plastic as a component of multi-material items, the Guidance Document clarifies that only information about the plastic components must be reported.
• Provides guidance on reporting obligations to avoid duplication. For example, when a product (e.g., a car stereo) is a component of another larger product (e.g., a vehicle) that has its own reporting category, the component product should be included in the data reported by the producer of the larger product. This may result in the data first being reported in a later reporting period than if the component was sold on its own.
• Clarifies that entities submitting data to the Registry must identify the calculation methods used to determine the quantities being reported. While the Notice does not mandate specific calculation methods, the Guidance Document clarifies that entities are allowed to choose their preferred approach.
• Provides guidance on handling confidential business information and submitting claims of confidentiality.
• Includes examples in the Appendices to assist in determining reporting obligations and provides sample calculations for packaging, single-use and disposable products, and electronic and electrical equipment.

Conclusion 

While the Guidance Document only addresses Phase 1 reporting obligations, the Government of Canada has indicated that a subsequent version of the document will provide additional guidance for the future phases to be reported on in 2026 (2025 data) and 2027 (2026 data). The Guidance Document encourages persons who did not meet the reporting criteria or who are exempt from reporting in a given year to review their status on an annual basis to determine whether they are required to report.

With the first reporting deadline fast approaching, companies involved in the lifecycle of plastics would be well advised to assess their reporting obligations and, if necessary, compile the required information before the reporting deadline on September 29, 2025. The Guidance Document is available upon request from Environment and Climate Change Canada and can serve as a helpful resource in this process, particularly in relation to Phase 1 of reporting.

If you need assistance with navigating this new reporting regime, the Environmental group at Blakes can help you determine your company’s specific obligations and guide you through the reporting process.

For more information, please contact the authors or any other member of our Environmental group.