🧭 What’s in scope now (Phase 1)

✅ Phase 1 categories (current must-do)

Phase 1 requires reporting by producers of plastics placed on the market in three categories:

• 📦 Plastic packaging (filled and unfilled)
• 🔌 Electronic and Electrical Equipment (EEE)
• 🧴 Single-use or disposable products

🏠 Residential waste stream focus

For Phase 1, reporting is required only for products that typically accumulate in households (the residential waste stream). Items destined for industrial, commercial and institutional (ICI) streams (and construction/demolition/renovation streams) are not included in Phase 1.

🧪 Resin manufacturers/importers are not a Phase 1 requirement

The Phase 1 guidance explicitly notes that Phase 1 does not require reporting by those who import, manufacture, or place resins on the market.

🧑‍💼 Who must report (the “producer” rule)

A producer is determined through a hierarchy:

1- the brand owner / intellectual property holder resident in Canada

2- if the brand owner is not in Canada: the first resident importer or manufacturer in Canada

3- if there is no resident importer/manufacturer: the first resident supplier to the consumer

Marketplace rules also matter: a marketplace facilitator can become obligated when there is no resident brand owner/importer/manufacturer for goods sold through the marketplace.

🧮 Exemption: the 1000 kg de minimis threshold

To reduce burden on small entities, Phase 1 provides a de minimis exemption:

• If you manufacture, import, or place on the market < 1000 kg of plastic products or packaging per calendar year, you are exempt.

How to apply it correctly (this is where companies go wrong):

• The 1000 kg is the plastic within the item, not the total item weight.
• It is based on the combined plastic weight across packaging + products that are in-scope for that year.
• It must be calculated on national totals across all provinces/operations.
• You must calculate it annually and keep records supporting the calculation.

📦 What you must report (data fields you need ready)

The reporting platform states you must be able to report the weight plus classification fields such as resin source, resin type, category and subcategory.

1) Weight in kg (plastic portion only)

If plastic is only part of a multi-material product, you report only the plastic component, not total product weight.

2) Resin type must use NAPCS codes (not the consumer #1–#7 symbol)

ECCC’s Phase 1 guidance explains resin group reporting is based on NAPCS Canada 2022 and states reporting must use the NAPCS code for the applicable resin group.

3) Resin source (virgin vs recycled categories)

The guide defines resin sources and notes how to handle unknown sources (including defaulting rules).

4) Packaging: filled + unfilled, and it’s not “double counting”

Phase 1 requires reporting on both unfilled and filled packaging that is imported/manufactured and placed on the market; the guide clarifies these are separate data points, not duplication.

Also, packaging must be reported regardless of what it contains (even if the product itself is not yet in scope).

5) Multi-resin items must be split by resin

If a product/packaging contains multiple resin types (e.g., multilayer structures), producers must report each resin type accordingly.

6) “Reasonably accessible” supply-chain data is expected

If you are subject to the notice, you must provide information you possess or are reasonably expected to access, and you are encouraged to obtain needed information from your supply chain.

🗓️ Deadlines, submission, and recordkeeping

Reporting deadline

The reporting deadline is September 29 of the year following the data year (e.g., 2024 data due September 29, 2025).

Record retention

Organizations obligated to report must keep copies of all records for three years after the reporting deadline, including detailed records of data and calculations.

Portal basics (what you need to register)

To register, the platform indicates you’ll need your CRA Business Number, address, and contact information; the portal also supports multiple users and requires an authorized person to certify submissions.

🧩 Step-by-step compliance plan (what a company should do)

✅ Step 1 — Confirm obligation (producer + scope)

• Apply the producer hierarchy and document it per brand/SKU family.
• Confirm items fall within Phase 1 categories and the residential waste stream.

✅ Step 2 — Run the 1000 kg test (and keep proof)

• Calculate annual national totals (plastic-only, in-scope only), then retain the supporting workpapers.

✅ Step 3 — Build a reporting-ready plastics inventory

For each packaging/product family, capture:

• category/subcategory (Phase 1)
• resin type (NAPCS) + resin source
• plastic weight per unit (kg)
• annual quantities (manufactured/imported/placed on market)
• rules for splitting by resin for multi-resin items

✅ Step 4 — Choose and document your calculation method

You must identify calculation methods used; the guide lists examples such as:

• specific component identification
• average bill of materials (ABOM)
• fixed-factor calculation

✅ Step 5 — Close data gaps with suppliers (early)

• Request resin composition and weights; prioritize high-volume packaging formats and multi-layer structures.
• Treat “reasonably accessible” as a practical expectation: start supplier outreach early to avoid deadline risk.

✅ Step 6 — Set up portal workflow, certification, and delegation (optional)

You can authorize another party to report and certify on your behalf, including a PRO, but the producer remains ultimately responsible for accuracy.

✅ Step 7 — Quality checks before submission

Run checks that catch the most common errors:

• packaging included even when the product isn’t in scope yet
• unfilled vs filled packaging tracked as separate data points
• NAPCS resin codes used (not consumer resin symbols)
• plastic-only weights (not total product weight)

✅ Step 8 — Submit by Sept 29 and retain records for 3 years

• Submit before the deadline, then store the full evidence pack and calculations for the required retention period.

🛡️ Confidential business information (CBI)

The portal allows confidentiality claims for parts of a report, with rationale required; CEPA governs how confidentiality requests are assessed.

🧰 What this compliance service typically delivers

• Producer determination + Phase 1 applicability assessment
• SKU/packaging mapping to Phase 1 categories + residential stream decisions
• Resin type (NAPCS) + resin source data model and validation
• Calculation method selection, documentation, and audit-ready workpapers
• Supplier data request workflow aligned to “reasonably accessible” expectations
• Portal submission support, certification readiness, and 3-year record retention pack

⭐ Why ComplyMarket is the best solution for Canada Plastics Reporting

ComplyMarket’s Material Compliance Management and Reporting Platform is built to operationalize Canada Plastics Reporting (FPR) as a repeatable, audit-ready business process—especially for companies managing many SKUs, multi-layer packaging, and supplier-driven resin data.

How ComplyMarket helps you stay compliant:

• Single source of truth for packaging & materials: Centralize packaging layers, component weights, resin type/source, and version history so “plastic-only kg” is always available and defensible.
• Standardized classification at scale: Consistent mapping to categories/subcategories and resin identifiers reduces misclassification and rework across teams and regions.
• Automated calculations + reporting outputs: Generate manufactured/imported/placed-on-market totals and structured datasets ready for submission, while preserving calculation logic and evidence.
• Supplier collaboration & evidence control: Built-in supplier requests, reminders, data validation, and document storage to meet “reasonably accessible” expectations.
• Workflow + approvals + traceability: Role-based review, certification readiness, and complete audit trails—critical when delegating work while retaining producer accountability.

For organizations that want faster reporting cycles, fewer submission errors, and a scalable compliance operating system that can adapt as Canadian plastics requirements evolve, ComplyMarket is the strongest end-to-end solution.