(1) A person who manufactures, imports, and places plastic resins on the market in Canada;
(2) A person who is a producer of specific plastic products (which include electronics, automobiles, and other specific plastic containing products);
(3) A person who is a generator of packaging and plastic product waste at their industrial, commercial, or institutional facility;
(4) A person who is a service provider for the management of specific plastics or plastic products

And

(a) Manufactures, imports, or places on the market more than 1,000 kg of plastic products or packaging per calendar year,
or
(b) Generates more than 1,000 kg of packaging and plastic product waste at their industrial, commercial, or institutional facility per calendar year.
or
(c) Manages more than 1,000 kg of plastic as a waste service provider

Yes, each year manufacturers and importers, producers of plastic products, generators of plastic waste, and service providers must report.

A Canadian Environmental Protection Act (CEPA) Section 46 notice in Part 1 of the Canadian Gazette is required for entities in scope of the notice.

Yes,

In section 3.2 of the Guide for reporting to the Federal Plastics Registry – phase 1 the De minimus provision is defined. This provision ensures only significant contributors to plastic waste are included. It states, “Persons that manufacture, import, or place on the market less than 1000 kg of plastic products or packaging per calendar year are exempt from reporting requirements”. This threshold is determined by the total combined weight of packaging and plastic manufactured, imported, and placed on the market.

Yes.  Companies can apply individually for an extension in a manner similar to CEPA PFAS reporting.  Companies need to justify their extension request including the reason for requiring the extension and to what benefit would that company’s extension be to the Canadian Plastics Registry.  

Extensions to be sent by email to FPR-RFP@ec.gc.ca

The Canadian plastics registry contains a list of what specific plastic products are in scope of the registry.

Simplified list of in-scope plastic products:

The Canadian plastics registry list of EEE is virtually identical to the EU RoHS electrical and electronic equipment (EEE). 

The list includes provisions that suggest that the same exclusions from scope exist as EU RoHS, such as large scale industrial tools, large scale fixed installations, and components that require further manufacturing steps before being used by the end user.

Electrical medical devices and most categories of professional electronics such as monitoring and control equipment are specifically in scope.

Until further guidance is available, the general ‘rule-of-thumb’ is that if your product would be in scope of the EU RoHS, it is in scope of the EU plastics registry (EEE).

However, EEE and packaging intended for professional or institutional users is not reportable until 2026 (for the 2025 calendar year). This is one year later than for consumer EEE and packaging.

Yes, municipal, provincial, and federal entities are also responsible for reporting to the Federal Plastics Registry.

The Canadian plastics registry categories of plastics are based on the North American Product Classification System (NAPCS) Canada 2022 Version 1.0. This coding system is new from Statistics Canada, and does not match other common plastic coding systems such as the ASTM International Resin Identification Coding System.

Natural and synthetic rubbers (such as silicone rubbers) are not included in the thermoplastic and thermoset resin codes listing in the Canadian plastics registry. These materials have separate NAPCS codes from the plastics under the scope of reporting. Until further guidance is available, it is assumed that these elastomers would not be reportable under the Canadian plastics registry. Further guidance is expected as the complete exclusion of rubber would make the mandatory reporting for tires less effective.

No.

In 2025, a company reports the sum of each plastic resin in their packaging or EEE by EEE subcategory – further separated between consumer and professional products.

Example – a brand with over 1 tonne each of imported laboratory equipment, consumer medical devices, and professional medical devices reports the sum of each reportable plastic resin for each of those three groups. 

Report 1 – sum of each resin in professional monitoring and control equipment
Report 2 – sum of each resin in consumer medical devices
Report 3 – sum of each resin in professional medical devices

Your business has to report any plastic packaging or products that you place in the professional or institutional waste stream if you put into the waste stream any plastic packaging or in scope products above 1 tonne per annum.

For a manufacturing facility, this includes all the in scope plastics that you place in the waste stream from both operations and employees. For restaurants, their is complexity between what they place on the market for takeout and place into the waste stream at their place(s) of business.

For a business with multiple facilities in Canada, the reportable plastics are the sum produced in all facilities. 

There is no definite list of accessories, but the examples (cables, adaptors, cords, chargers) are all self contained electronics in their own right. These fully manufactured electronics would have to be reported as a separate EEE subcategory.

Since all the examples are full manufactured accessories, it would be reasonable to assume that this category does not extend to incomplete electronics (such as components or repair parts) for EEE. Further guidance may provide additional detail and granularity.

Environment and Climate Change Canada (ECCC) released a new Federal Plastics Registry draft Excel Reporting Template. If you have any questions regarding this new reporting template please contact Claigan.