Canada has postponed the planned expansion of its Federal Plastics Registry. This does not mean that federal plastics reporting has been suspended.

Companies already covered by Phase 1 must continue to report relevant plastic quantities for the 2025 calendar year by 29 September 2026. A further Phase 1 report covering 2026 data will be due in 2027.

The postponement mainly affects requirements that would have extended the Registry to additional product categories, plastic resins, commercial waste generators, service providers and end-of-life information.

For businesses selling packaging, electrical equipment or disposable plastic products in Canada, the immediate question is therefore not whether the Federal Plastics Registry still applies. It is whether the company qualifies as the responsible Canadian producer and whether its products remain within the narrower Phase 1 scope.

What was postponed in March 2026?

The original Federal Plastics Registry framework introduced reporting in several stages.

Phase 1 began with data relating to plastic packaging, electrical and electronic equipment and single-use or disposable products associated with the residential waste stream.

Later phases were intended to add further areas of the plastics economy. These included plastic resins, additional product categories, waste generated at industrial, commercial and institutional premises, quantities collected at end of life and information about recycling, reuse, disposal and other waste-treatment routes.

On 14 March 2026, Environment and Climate Change Canada amended the reporting notice and postponed the due dates for Phases 2 and 3.

The postponement means that resin manufacturers, waste generators and service providers are not required to submit the previously anticipated Phase 2 and Phase 3 information for the 2025 and 2026 calendar years under the current notice.

It also delays the expansion to product categories such as apparel and textiles, tires, transportation products, agriculture and horticulture products, construction products and fishing and aquaculture equipment.

The existing Phase 1 obligations remain in force.

Which report is due on 29 September 2026?

The report due on 29 September 2026 covers activities during the 2025 calendar year.

Relevant producers must report on plastic that they manufactured in Canada, imported into Canada or placed on the Canadian market in the Phase 1 categories.

A further report covering the 2026 calendar year is due by 29 September 2027.

The annual deadline falls on 29 September of the year following the reporting year. The postponement of later phases did not change that timetable for Phase 1.

Reporting is mandatory under section 46 of the Canadian Environmental Protection Act, 1999. Companies that meet the criteria must file even where they have already reported packaging or product quantities to one or more provincial Extended Producer Responsibility systems.

Which product categories remain covered?

Phase 1 continues to cover three principal categories:

• plastic packaging, whether filled or unfilled;
• electrical and electronic equipment containing plastic;
• single-use or disposable plastic products.

For the 2025 reporting year, the relevant packaging and products must generally be associated with the residential waste stream.

Plastic products intended exclusively for industrial, commercial and institutional waste streams are not currently included under the remaining Phase 1 requirements. The same applies to construction, demolition and renovation waste.

This distinction depends on where the product is expected to become waste rather than simply on whether the customer is a business.

A product sold through a B2B transaction may still be associated with the residential stream if it is ultimately supplied to households. Conversely, equipment intended exclusively for use and disposal within an industrial facility may fall outside the current reporting scope.

Businesses should therefore avoid treating B2B and residential as interchangeable classifications.

Packaging remains reportable even when the product is not

The packaging category is particularly broad.

Phase 1 covers relevant filled and unfilled plastic packaging regardless of the type of product contained inside it. Packaging can therefore be reportable even where the packaged product belongs to a category whose inclusion has been postponed.

For example, the plastic bag surrounding a textile product can remain within Phase 1 even though the plastic content of the textile itself is not currently reportable.

The same principle can apply to plastic packaging around furniture, cosmetics, food, machinery or other goods that do not independently fall within one of the current product categories.

The Registry distinguishes between filled and unfilled packaging.

Unfilled packaging includes empty packaging manufactured, imported or supplied for subsequent filling. Filled packaging is packaging containing goods when it is placed on the market.

A company that manufactures plastic packaging, fills it and then sells the packaged product may need to report both activities. It reports the manufacture of the unfilled packaging and the subsequent placement of the filled packaging on the market.

These figures describe different movements of plastic through the economy. They should not be merged merely because they relate to the same physical packaging.

Electrical and electronic equipment requires product-level plastic data

The reporting obligation for electrical and electronic equipment is not limited to its external packaging.

A producer may also need to report the plastic incorporated into the equipment itself. This can include plastic housings, internal components, cables and other relevant plastic parts.

Electrical products frequently contain several different resins. The report must reflect the applicable resin types rather than classify the entire product under one generic plastic category.

A manufacturer or importer may therefore need information that is not normally available in sales or provincial EPR records.

A conventional WEEE or electronics EPR declaration may record the total weight of an appliance. The Federal Plastics Registry instead requires information about the weight and source of the plastic within that appliance.

This difference can create a significant data gap for importers and private-label businesses that receive finished-product weights but not detailed bills of materials from their suppliers.

Which disposable products are included?

Phase 1 also covers designated single-use and disposable plastic products.

The category includes specified products intended to be used once or for a limited period before being discarded. Examples in the federal guidance include food-service items and certain personal hygiene and care products.

The legal categories and subcategories in the reporting notice determine the scope. A product is not necessarily reportable merely because it is marketed as disposable, and it is not automatically excluded because it can technically be reused.

Companies must examine the relevant product classification, the plastic components and the expected waste stream.

Where a disposable product is sold in plastic packaging, the product and its packaging may require separate entries under different categories.

Who is the responsible producer?

The Federal Plastics Registry uses a producer hierarchy centred on Canadian residence.

The first level is generally the brand owner or intellectual property holder resident in Canada.

Where no brand owner is resident in Canada, responsibility generally moves to the first Canadian resident that manufactures or imports the product.

Where there is no resident manufacturer or importer, the first resident person supplying the product to the consumer may become responsible.

This structure means that the company physically handling the goods is not always the reporter. A contract manufacturer, distributor or retailer may be outside the reporting position where a Canadian brand owner sits higher in the hierarchy.

The assessment must be completed for the specific products and brands concerned. Different companies within the same supply chain may be responsible for different product lines.

Private-label products

Private-label arrangements place particular importance on the brand-owner rule.

A Canadian retailer selling products under its own brand will generally be the producer for those products, even where another Canadian or foreign company physically manufactured or imported them.

The contract manufacturer or importer may still hold much of the information needed for the report. This can include the resin type, plastic weight, source of the material and product composition.

Commercial agreements should therefore distinguish between legal reporting responsibility and responsibility for supplying the underlying data.

A private-label brand owner cannot assume that its supplier will file the federal report. Equally, a supplier should not automatically include private-label products in its own report without first establishing which entity qualifies as producer.

Marketplace facilitators

Online marketplaces are also included in the producer hierarchy.

A marketplace facilitator may become the responsible producer where products are supplied through its marketplace and there is no Canadian resident brand owner, manufacturer or other importer responsible for those goods.

The marketplace does not automatically become the reporter for every third-party seller.

Where a Canadian brand owner sells through the platform, the Canadian brand owner generally remains responsible. Where another Canadian company imports the products before they are distributed through the marketplace, that importer may remain responsible.

The marketplace facilitator becomes particularly relevant as the fallback actor where it is effectively the first resident person placing foreign products on the Canadian consumer market.

Marketplace sellers and operators should therefore determine responsibility by supply chain rather than rely only on the identity displayed to the consumer at checkout.

Do foreign companies have to report?

A company without Canadian residence and without a Canadian address is not generally required to file directly with the Federal Plastics Registry.

The reporting obligation instead falls on the relevant Canadian resident producer, such as the Canadian brand owner, first importer, manufacturer, retailer or marketplace facilitator.

Foreign businesses nevertheless play an important role.

The Canadian reporter may need detailed information about the identity, source and quantity of each plastic resin contained in the product and its packaging. This information frequently sits with the foreign manufacturer or packaging supplier.

Environment and Climate Change Canada has provided a supplier letter specifically to help Canadian businesses request information from foreign suppliers.

An overseas company may therefore have no direct filing obligation but still face contractual data requests from Canadian customers. A failure to provide adequate composition information can prevent the Canadian partner from completing an accurate report and may affect future supply arrangements.

The 1,000 kg exemption

A de minimis exemption applies where a person manufactures, imports or places on the market less than 1,000 kg of relevant plastic packaging and products during the calendar year.

The threshold is calculated using the weight of the plastic, not the total weight of the packaged goods or finished products.

It is also calculated nationally.

A company cannot apply the threshold separately in each province or territory. Relevant quantities from all Canadian operations must be combined.

The threshold also combines the applicable reporting activities and categories. For example, a business importing 600 kg of plastic in products and 500 kg of plastic packaging exceeds the threshold and must report the full relevant quantities.

Exactly 1,000 kg is not below the threshold. A company reaching that amount is therefore not covered by the less-than-1,000-kg exemption.

Only packaging and products included in the categories applicable to the reporting year are used for the calculation. Plastic in postponed product categories does not count toward the Phase 1 threshold merely because it is made from plastic.

The assessment must be repeated annually. A company exempt for 2024 may become reportable for 2025 if its sales, imports or product mix change.

What information must be reported?

The Federal Plastics Registry requires more detail than a single annual tonnage.

For each applicable product or packaging category, producers may need to provide information concerning:

• the product category and subcategory;
• the relevant waste stream;
• each plastic resin type;
• the source of the resin;
• the quantity manufactured in Canada;
• the quantity imported into Canada;
• the quantity placed on the market in Canada;
• the quantities placed on the market in each province and territory;
• the method used to calculate the reported weights.

Resin source information distinguishes between material such as virgin fossil-based resin, bio-based resin, post-consumer recycled resin and post-industrial recycled resin.

Multimaterial products require reporting only on their plastic content. However, all relevant plastic components must be considered.

A thin plastic layer in laminated packaging cannot be ignored merely because paper, aluminium or another material makes up most of the structure. Where several resins are present, each resin must be reported separately.

How can quantities be calculated?

The reporting notice does not prescribe one compulsory calculation method for every product.

The federal guidance recognises methods based on component identification, bills of materials, average product composition and fixed factors. Companies must identify the method they used and retain sufficient evidence to support the resulting figures.

The appropriate method depends on the quality of the available product data.

A component-level bill of materials may offer greater precision but may not be available for every imported product. Average weights can be used across sufficiently similar products, but the grouping must remain technically credible. Fixed factors may be practical for large product ranges but can create less accurate results.

Companies should avoid combining methods without documented rules. Changes in methodology between reporting years should also be recorded so that apparent changes in plastic volumes can be explained.

Sales data alone will rarely be sufficient. It generally needs to be connected to packaging specifications, product composition data and provincial distribution information.

Reporting can be delegated, but responsibility remains

A producer may designate a producer responsibility organisation or another party to prepare and submit information on its behalf.

The designation does not transfer the underlying legal responsibility.

The obligated producer remains responsible for ensuring that the report is submitted and that the information is accurate and complete.

This is important where a company uses several provincial PROs. No single organisation may hold a complete national dataset covering all provinces, product categories and plastic components.

A federal report may therefore require consolidation across multiple EPR systems, internal business units, import records and supplier data sources.

The reporting company should retain control over the assumptions, calculation methods and final national totals even where an external service provider operates the reporting platform.

Federal reporting does not replace provincial EPR

The Federal Plastics Registry and provincial Extended Producer Responsibility systems serve different purposes.

Provincial EPR programs determine responsibility for financing and managing products and packaging at the end of life. They are used to calculate producer fees, measure collection and recycling performance and administer local waste-management obligations.

The Federal Plastics Registry is a national information-gathering system under the Canadian Environmental Protection Act.

Submitting an FPR report does not complete a company’s provincial packaging, electronics or other EPR obligations. Likewise, filing provincial declarations does not automatically satisfy the federal reporting requirement.

Differences may arise in:

• producer definitions;
• product scope;
• material classifications;
• reporting thresholds;
• calculation methods;
• residential and commercial waste-stream distinctions;
• provincial allocation requirements.

The same product data may support both processes, but companies should not submit one dataset unchanged without confirming that the applicable definitions are aligned.

Record retention and enforcement

Companies required to report must retain their supporting records for three years after the relevant reporting deadline.

The records should make it possible to reconstruct the reported figures. Relevant documentation can include bills of materials, supplier declarations, import records, sales data, packaging specifications, calculation files and provincial allocation methods.

Reporting late, failing to report or knowingly providing false or misleading information can result in enforcement under the Canadian Environmental Protection Act.

The available penalties depend on the offence, the type of person involved and the prosecution route. The federal guidance identifies potential fines reaching CAD 500,000 for a large corporation convicted on indictment, with higher exposure for subsequent offences.

The compliance risk is therefore not limited to companies that completely ignore the Registry. Unsupported estimates and incomplete resin data can also create problems where they result in inaccurate submissions.

What does the postponement mean for future reporting?

The postponement should not be interpreted as a permanent cancellation of the wider Federal Plastics Registry.

Environment and Climate Change Canada has stated that a new notice is intended to continue information gathering for the 2027, 2028 and 2029 calendar years.

The eventual structure of that notice will determine when additional product categories, resin reporting and end-of-life data return to the reporting timetable.

Businesses in sectors such as textiles, transport, construction, agriculture, fishing and tires have gained additional preparation time. They should not assume that these sectors have been removed from the federal policy permanently.

The same applies to recyclers, waste-management providers and businesses generating plastic waste at industrial, commercial and institutional premises.

The delay provides an opportunity for the government to revise the requirements and for businesses to improve data availability before the broader system is reintroduced.

The Registry remains an active compliance obligation

Canada’s Phase 2 and Phase 3 postponement narrowed the immediate Federal Plastics Registry requirements. It did not remove them.

Canadian producers of relevant residential plastic packaging, electrical and electronic equipment and single-use or disposable products must continue to report Phase 1 information.

For the 2025 calendar year, the deadline is 29 September 2026.

The main compliance challenge is not simply calculating a total packaging weight. Companies must identify the correct producer, separate plastic from other product materials, distinguish resin types and sources, allocate quantities by province and retain evidence supporting the calculation.

International manufacturers may also be drawn into the process through requests from Canadian importers, retailers and brand owners for detailed product-composition data.

Viron Compliance supports international producers and Canadian market participants in assessing packaging, electronics and other EPR responsibilities across national and provincial systems. We help companies distinguish federal plastics reporting from provincial producer registrations, reporting and ongoing compliance obligations.