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The government of Canada announced a new program requiring certain companies to report on plastic production and disposal. The requirement is being implemented under the Canadian Environmental Protection Act, 1999 which allows the Canadian Environmental Protection Agency (CEPA) to collect data for official purposes. Data will be stored in the Federal Plastics Registry. The Canadian government states in a press release that:

“The Federal Plastics Registry will require companies (including resin manufacturers, service providers, and producers of plastic products) to report annually on the quantity and types of plastic they manufacture, import, and place on the market. Producers of plastic products and service providers will also be required to report on the quantity of plastic collected and diverted, reused, repaired, remanufactured, refurbished, recycled, processed into chemicals, composted, incinerated, and landfilled. They will also be required to report on the amount of plastic waste generated on their industrial, commercial, and institutional premises.”

The move is part of a nationwide strategy to reduce plastic waste called the “Action Plan on Zero Plastic Waste.” The government hopes that robust data gathered on plastic production and waste will fuel policy solutions at federal, provincial, territorial, and municipal levels. The first reporting under the rules will occur in September 2025 for producers of plastic packaging and products, based on 2024 data. Lawmakers have taken a phased-in approach which allows exemptions for small producers while ratcheting up scoping requirements and reporting criteria each year until 2027. But if you are in the group facing the 2025 reporting deadline, you need to be gathering the following data for this year:

  • the total quantity, in kilograms, of plastic packaging and products, by resin, resin source, category and subcategory, that are destined for the residential waste stream or the industrial, commercial and institutional waste stream and the construction, demolition, and renovation waste stream and that are
    • manufactured in Canada, if any,
    • imported into Canada, if any, and
    • placed on the market in Canada in each province and territory,
  • the method used to determine the quantities referred to in the subsections above.

This could get tricky, especially in making assumptions/determinations about what plastic products “are destined for the waste stream” and what product use timeframe the reporting entity is supposed to use in making that determinations.

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The Editor

Zachary Barlow is a licensed attorney. He earned his JD from the University of Mississippi and has a bachelor’s in Public Policy Leadership. He practiced law at a mid-size firm and handled a wide variety of cases. During this time he assisted in overseeing compliance of a public entity and litigated contract disputes, gaining experience both in and outside of the courtroom. Zachary currently assists the editorial team by providing research and creating content on a spectrum of ESG… View Profile