Canadian Plastics Registry FAQ
Note – the FAQ below is a streamlined interpretation of the Canadian Plastics Registry. For full details see Canadian Plastics Registry Notice.
Who is in scope?
(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
Is the Canadian Plastics Registry mandatory?
Yes.
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.
What plastics products are in scope of the Canadian Plastics Registry?
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:
What electronic and electrical equipment (EEE) are in scope?
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.
Are medical devices and professional electronics out of scope of the Canadian Plastics Registry?
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.
What categories of plastics need to be reported?
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 the Canadian plastics registry. These materials have separate NAPCS codes from the plastics under 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.
When is the submission due?
The first submission is due September 29 2025 for the first products in scope (packaging, a specific list of single use or disposable plastics, and electronics). Further products are in scope in following years.
The Canadian government timeline summary has an excellent summary table reproduced above.
Note – EEE and plastics packaging intended for professional or institutional users is reportable one year later than for consumer products (2026 not 2025).
Do you report the plastics in each of your products separately?
No.
In 2025, a company reports the sum of each plastic resin in their packaging or EEE by EEE sub category – 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
Do I report the waste generated by my facility?
Your business has to report any plastics packaging or products that you place in the professional or institutional waste stream if you put into the waste stream any plastics 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 reporting plastics would be the sum for all facilities.
What is considered a subcategory EEE (12) accessory?
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.
Is there a format for a Canadian Plastics Registry submission?
Even though the online portal (as of July 2024) is not yet open, the fields for reporting are described in the Section 41 notice. Contact Claigan for specific details.