Canada Plastic Reporting – Complying with Product Requirements

🧾 Introduction

The Canada Plastic Reporting initiative establishes a national system for tracking plastics across their lifecycle.

Created under subsection 46(1) of the Canadian Environmental Protection Act (CEPA 1999),

The Federal Plastic Registry collects data to:

• Prevent plastic pollution.
• Keep plastics circulating in the economy.
• Support Canada’s Zero Plastic Waste Agenda.

A formal notice was published in the Canada Gazette on 20 April 2024, covering data years 2024 to 2026.

Reporting is mandatory for all entities subject to the notice, with penalties under CEPA section 272 for not reporting, late reporting, or submitting false information.

⚙️ Key Terms

• Producer – The Canadian brand owner or intellectual‑property holder.

If not resident in Canada, the first Canadian importer or manufacturer becomes the producer.

Marketplace facilitators listing and distributing products online are also considered producers.

• Marketplace Seller – A business selling through a third‑party platform.
• Marketplace Facilitator – The platform that sells, ships, and must report on behalf of sellers.
• Placed on the Market – Introducing plastic products into Canada, whether for sale or free of charge (including samples).
• Residential Waste Stream – Waste originating from households; all Phase 1 reporting covers plastics assumed to enter this stream.

🗓️ Deadlines and Phase 1 Scope

Reporting for 2024 data is due 29 September 2025.

Later submissions will cover 2025 and 2026 data annually.

Included in Phase 1

• Plastic packaging (filled or unfilled)
• Electronic and electrical equipment (EEE)
• Single‑use or disposable plastic products

Not Included in Phase 1

• Plastics from industrial, commercial, or institutional (ICI) streams
• Construction, demolition, or renovation waste
• Plastic resins (reporting begins 2026)
• Other product categories scheduled for later phases

👥 Who Must Report

Entities must report if they manufacture, import, or place on the Canadian market plastic products for the residential waste stream in any of the Phase 1 categories above.

De Minimis Threshold

Businesses handling less than 1,000 kg per year of in‑scope plastics are exempt but must retain records proving the calculation.

Plastic weight calculations must be recalculated each year and aggregated nationwide.

🧭 How to Determine If You Must Report

To assess obligations under Phase 1:

1- Check if your products are in scope – packaging, EEE, or single‑use items for household use.

2-  Confirm if you exceed 1,000 kg of plastic per year (manufactured or imported). Below the threshold → not obligated.

3- Identify activities – If you:
          • Manufacture or import plastic products or packaging in Canada, or
          • Import filled packaging,
          you are typically required to report.

4- Brand ownership – If you act on behalf of a Canadian brand owner, that brand owner reports; otherwise, you do.

5- Retailers and marketplace operators – Retailers placing in‑scope plastics on the market or marketplace facilitators distributing them online are also obligated.

🧾 Examples of Phase 1 Reporting

🍬 Example 1 – Wrappers and Packaging Used by a Retail Store

• Imported plastic bags for bulk candy: Reportable as single‑use food service ware. The retailer must report because it both imports and uses these bags.
• Wrappers on individually wrapped imported candy: Reportable as filled flexible packaging; the retailer imports a finished product.
• Wrappers made in‑store: Also reportable as filled flexible packaging since the retailer manufactures and uses the wrapping.
• Unfilled domestically purchased wrappers: Not reportable by the retailer – the manufacturer of the empty wraps reports.

🏪 Example 2 – “ABC Candy Store”

ABC Candy Store imports plastic bags for candies and sells packaged goods.

• Category: Single‑use (disposable) and packaging.
• Resin: Low‑density polyethylene (LDPE 2811221).
• Resin source: Virgin fossil‑based.
• Quantities: Imported bags – 1,000 kg (ON 600 kg, QC 400 kg); Imported wrappers – 400 kg; Manufactured in‑store wrappers – 250 kg.

💻 Example 3 – “LMN Electronics” (Manufacturer in Canada)

• Plastics in electronic devices: Report under EEE as information‑technology equipment (ABS resin).
• Unfilled specialty packaging made onsite: Report as unfilled rigid packaging (PS with post‑industrial recycled resin).
• Filled specialty packaging sold in Canada: Report under filled rigid packaging (PS recycled resin).

📜 Reporting Requirements

🌐 Submission

Reports must be filed through the Federal Plastic Registry Portal, available via the Regulatory Services Platform.

Official guidance will be issued before the first deadline.

📦 Data to Report

1- Resin type (e.g., LDPE, HDPE, PP)

2- Resin source (virgin fossil‑based, post‑industrial, post‑consumer, bio‑based)

3- Product category (packaging, EEE, single‑use)

4- Quantities manufactured, imported, and placed on the market per province or territory.

🧮 Calculation Methods

Submitters must declare how they determine weights:

• Specific Component Identification, using actual component weights.
• Average Bill of Materials Method, using average composition data.
• Fixed Factor Calculation, based on standard conversion ratios.

🧱 Avoiding Duplicate Reports

Each plastic item should be reported once in the most specific category:

• Example: a food clamshell → report under single‑use food‑service ware, not packaging.
• Separate entries for filled and unfilled packaging ensure complete lifecycle tracking.

🧩 Categories Covered in Phase 1

1- Plastic Packaging (filled and unfilled; primary, secondary, tertiary).

2- Electronic and Electrical Equipment (covered under EEE listing).

3- Single‑Use or Disposable Plastic Products.

🤝 How ComplyMarket Supports Your Reporting

Preparing for the Federal Plastic Registry requires precise data, correct resin classification, and accurate submission methods.

ComplyMarket helps organizations to:

• Identify obligations under CEPA and the Plastic Registry,
• Classify resins using official NAPCS codes,
• Implement data collection and weight‑calculation methods, and
• Align with Canada’s Zero Plastic Waste Agenda.

With specialized compliance support, businesses can report plastics accurately, avoid penalties, and demonstrate environmental accountability.