Federal Plastics Registry: Key updates for 2026

Environment and Climate Change Canada (ECCC) has announced a delay to Phases 2 and 3 of reporting under the Federal Plastics Registry (Registry), giving businesses more time to prepare and improve data quality. Phase 1 remains in effect, and late reporting is still accepted, though enforcement actions are being considered. The amended Section 46 notice reflecting these changes will be published in the Canada Gazette in 2026. Businesses should use this time to strengthen internal reporting systems, engage suppliers, and monitor regulatory updates. 

For further information regarding the Registry, see our previous updates: Government of Canada introduces Federal Plastics Registry, Federal Plastics Registry: Targeted plastics and plastic products, Federal Plastics Registry: phased implementation and Federal Plastics Registry: A look back at Phase 1 reporting.

Reminder: Legislative framework

The Registry is an annual reporting requirement introduced under Section 46 of the Canadian Environmental Protection Act (CEPA). Unlike a regulation, a Section 46 notice, also called an information-gathering notice, expires every three years and must be republished. The purpose of the notice creating the Registry (Notice) is to close critical data gaps on plastics production, use, and waste in Canada, supporting policy development and Canada’s circular economy objectives. Failure to report can trigger enforcement action.

Key developments announced

Delay of Phases 2 and 3

ECCC confirmed that Phase 2 and Phase 3 reporting requirements will be delayed to allow businesses more time to prepare and improve data quality, and to allow ECCC to add clarifications to the Notice further to questions raised by stakeholders during the Phase 1 reporting process. An amended Section 46 notice reflecting the delay and clarifications will be published in the Canada Gazette in 2026. Reporting will restart fresh from the new timelines, and no retrospective reporting will be required.

In the meantime, Phase 1 remains in effect, and businesses already in scope must continue reporting for 2026 and beyond. 

Expanded Scope (Phase 2 – When Implemented)

Phase 2 will significantly broaden the Registry’s coverage to include the following:

• Resin producers (for all resins listed in Schedule 1 of the Notice).
• Manufacturers, importers and persons who place products on the market in the following categories (in addition to categories already covered in Phase 1, being packaging, electronic and electrical equipment, and single-use or disposable products destined for the residential waste stream): tires, transportation, construction materials, agriculture and horticulture equipment, fishing and aquaculture equipment, and textiles and apparel, including those destined for the industrial, commercial, and institutional (ICI) waste stream. 
• ICI waste generators (for all packaging and product categories).
• Service providers (for packaging, single-use or disposable products, and agriculture and horticulture equipment).

As a reminder, the definition of “producer” (which is based on Ontario’s Extended Producer Responsibility [EPR] definition) is hierarchical. The producer of a product is the Canadian brand owner; if there is none, it is the first importer or manufacturer; if there is neither of those, it is the retailer supplying the product; and finally, if none of the previous categories apply, it is the online marketplace facilitator for non-resident sellers.

In addition, there is a 1,000 kg de minimis amount when it comes to producers of plastic packaging and products containing plastics, as well as waste generators and service providers. Any person who produces less than 1,000 kg of plastic packaging or products, who generates less than 1,000 kg of plastic waste, or who manages less than 1,000 kg of plastic is not required to report. 

Technical clarifications

ECCC also provided certain technical clarifications regarding reporting to the Registry, as set out below.

1,000 kg De Minimis Reporting Exemption Amount

For waste generators, this amount applies across all facilities, and includes packaging waste and product waste, such as dead stock. Therefore, a waste generator that produces less than 1,000 kg of waste per facility, but produces 1,000 kg or more of waste across all of its facilities is still required to report.

No De Minimis Amount Per Product

For those reporting on products containing plastics, there is no de minimis threshold per product. Any plastic content must be reported.

Waste to be Reported According to Category and Subcategory

All waste must be reported in accordance with the packaging and product categories and subcategories set out in the notice establishing the Registry. If a particular item destined for the waste stream does not fall within any of these defined categories or subcategories, it is not required to be reported. For example, ECCC representatives mentioned that off-cuts or shavings from manufacturing processes would not be reportable. However, K-cups or other single-use plastic coffee pods generated by employees at the facility are in scope and would be reportable. We are hopeful these comments from ECCC will be clarified in the revised Notice or future guidance materials. 

Reusable Packaging Excluded from Reporting

Reusable packaging in closed-loop systems is excluded from reporting. For example, returnable crates or dunnage do not need to be reported. Only single-use packaging is in scope.

Calculation Methods Are Flexible

While ECCC suggests waste audits, inventory records, and data exchange, businesses may use other reasonable methods. Supporting documentation for assumptions and estimates can be uploaded to the online reporting platform.

Compliance and risk management

The online reporting portal remains open, and late Phase 1 reporting is still accepted and encouraged. However, enforcement actions are being considered. Businesses should document reasonable efforts for Phase 2 preparation and monitor regulatory updates. 

ECCC has provided guidance documents, factor calculators, and templates to assist with compliance. Those resources are available on the ECCC website: https://rfp-fpr.ec.gc.ca/en/resources/.

What’s next: Practical steps for businesses

Confirm Scope: Determine if your organization is in scope under Phase 1 and anticipated Phase 2 categories.

Prepare Internal Systems: Establish or update internal reporting processes and engage suppliers to obtain upstream data.

Monitor Regulatory Updates: Watch for the amended Section 46 notice in the Canada Gazette (expected in 2026). We will continue to monitor and provide updates in this regard.

Mitigate Enforcement Risk: Submit any overdue Phase 1 reports immediately and document reasonable efforts for compliance readiness.

Bottom line

The Registry remains a critical compliance obligation with significant expansion ahead. ECCC has indicated that in addition to the notice to be published in 2026, it is likely the Section 46 notice will be republished upon its expiry, requiring reporting beyond 2027. While Phases 2 and 3 are delayed, businesses should use this time to strengthen data collection processes and risk mitigation strategies.