Canada Announces Planned Changes to Federal Plastics Registry Reporting Requirements

Introduction

On December 19, 2025, Environment and Climate Change Canada (ECCC) announced planned changes to reporting requirements for the Federal Plastics Registry (FPR). The FPR requires annual reporting on the quantity and types of plastic manufactured, imported and placed on the Canadian market. For more details, see our previous Blakes Bulletin: Canada Publishes Notice for the Reporting of Plastic.

In response to stakeholder feedback on the complexity of reporting for the upcoming Phases 2 and 3, ECCC announced a deferral of reporting under these phases, pursuant to the Notice with respect to reporting of plastic resins and certain plastic products for the Federal Plastics Registry for 2024, 2025 and 2026 (Notice). According to the update, Phase 1 reporting obligations will remain in place for the 2026 and 2027 calendar years.

Previous Approach

The phased approach was originally intended to proceed as follows:

1. Phase 1 required those who manufactured, imported and placed on the market in Canada (i) plastic resins, (ii) plastic packaging, (iii) electronic and electrical equipment, and (iv) single-use or disposable products destined for the residential waste stream to report by the deadline of September 29, 2025, on 2024 data.
2. Phase 2 expanded reporting on additional product categories, including textiles and apparel manufactured, imported and placed on the market in 2025. This phase was to apply not only to products destined for the residential waste stream but also to products destined for the industrial, commercial and institutional waste streams, as well as construction, demolition and renovation waste streams.
3. Phase 3 expanded reporting on plastics collected at end of life and sent for diversion and disposal in additional product categories, including electronic and electrical equipment and tires.

Key Takeaways

Organizations must continue to report Phase 1 data for the 2024, 2025 and 2026 calendar years by September 29 of the following year. This means that producers of packaging, single-use or disposable plastics, and electronics and electrical equipment destined for the residential waste stream must continue to comply with existing reporting requirements under the Notice.

ECCC has indicated that it will publish a notice of intent in the Canada Gazette in winter 2026 to communicate its plans to delay Phases 2 and 3, followed by a new notice in summer 2026 establishing reporting requirements for the 2027, 2028 and 2029 calendar years, for which reports will need to be submitted in the following year.

ECCC has also stated that stakeholders will have several opportunities to provide feedback on these proposed changes in 2026 as part of efforts to streamline and optimize reporting requirements.

For more information or for assistance with submitting comments on these proposed changes, please reach out to our key contacts or any other member of our Environmental group.