Reporting Requirements: Federal Plastics Registry Phase 1

On April 20, 2024, the Government of Canada published 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”). The Notice established the Federal Plastics Registry (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 significant penalties. The Notice is likely to have broad implications for  businesses involved in the lifecycle of plastics and plastic products.

These reporting obligations summarized in a previous blog post here,  will be phased in over three years, with Phase 1 covering calendar year 2024.  Phase 1 applies to a producer of plastic products, the definition of producer is quite broad and includes those who import, manufacture, and place plastic packaging or plastic products on the market in Canada such as brand owners, importers, manufacturers, retailers, marketplace facilitators or sellers. In Phase 1 these producers of plastic packaging, electronic and electrical equipment and single-use or disposable plastic products that are destined for residential waste streams are required to submit their first annual report no later than September 29th, 2025.

Companies that manufacture, import or place plastic products on the market — particularly those with significant operations and substantial supply chains whose products will end up in residential waste — should evaluate their reporting obligations early to ensure they can meet the reporting deadline or, if needed, file an extension request with the Minister.

McCarthy Tétrault’s National Environmental Group and Retail & Consumer Markets Group is providing guidance to clients across various industries and sectors on how to comply with reporting obligations under CEPA. Please contact our team for assistance in determining your company’s specific reporting obligations, including extension requests, meeting reporting requirements, and confidentiality claims.