Latest Update: Phase 2 and Phase 3 Reporting Are Postponed

The latest major update is that reporting for Phases 2 and 3 of the Federal Plastics Registry has been postponed. However, companies should not interpret this as a cancellation of Canada plastics reporting.

Organizations must continue to report Phase 1 data for the 2024, 2025, and 2026 calendar years according to the reporting requirements in the Federal Plastics Registry notice.

For 2025 and 2026 calendar years, reporting is required for producers that manufacture, import, or place the following on the Canadian market:

• Plastic packaging
• Electronic and electrical equipment
• Single-use or disposable plastic products

Canada also clarifies that resin manufacturers, waste generators, and service providers are not required to report for the 2025 and 2026 calendar years under the current Phase 1 continuation.

A new notice is also expected to continue information-gathering activities for the Federal Plastics Registry for the 2027, 2028, and 2029 calendar years.

Quick Answer: Does Your Company Need to Report?

Your company may need to report under Canada’s Federal Plastics Registry if it manufactures, imports, or places plastic packaging or certain plastic products on the Canadian market.

You should review your obligations if your company:

• Sells products in plastic packaging in Canada
• Imports packaged products into Canada
• Manufactures plastic packaging in Canada
• Places private-label products on the Canadian market
• Sells electronic or electrical equipment containing plastic
• Sells single-use or disposable plastic products
• Acts as the Canadian brand owner, importer, supplier, retailer, or marketplace facilitator in certain situations
• Exceeds the applicable de minimis threshold

Phase 1 reporting focuses on producers of plastic packaging, electronic and electrical equipment, and single-use or disposable products destined for the residential waste stream.

What Is the Federal Plastics Registry?

The Federal Plastics Registry is Canada’s national system for collecting information about plastics. It is designed to provide standardized data on the quantity and types of plastic that organizations manufacture, import, place on the market, collect, reuse, repair, recycle, compost, incinerate, or landfill.

The purpose is to improve visibility over plastic use, waste, value recovery, and pollution in Canada. The registry supports Canada’s broader zero plastic waste agenda and helps decision-makers understand how plastic moves through the economy.

For companies, the FPR creates a formal reporting obligation. Reporting is mandatory for persons that meet the requirements, and Canada states that failure to report, late reporting, or knowingly submitting false or misleading information may lead to penalties under CEPA.

What Is Covered in Phase 1?

Phase 1 currently covers three main product groups.

1. Plastic Packaging

Plastic packaging includes both filled and unfilled packaging. This can include packaging used around products even when the product itself is not yet fully in scope.

Examples may include:

• Flexible plastic bags
• Plastic films
• Plastic pouches
• Plastic containers
• Plastic bottles
• Plastic caps and closures
• Plastic protective packaging
• Plastic packaging used for private-label products

Companies should pay close attention to packaging because packaging may be reportable even when the product inside is not the main focus of the reporting phase.

2. Electronic and Electrical Equipment

Electronic and electrical equipment, often called EEE, is included in Phase 1 when destined for the residential waste stream. This can affect companies selling consumer electronics, electrical appliances, devices, tools, accessories, and products containing plastic components.

Canada’s guidance gives examples showing that electronics can contain multiple reportable plastic resin types, and those resin quantities may need to be reported separately.

3. Single-Use or Disposable Plastic Products

Single-use or disposable plastic products are also included in Phase 1. These are products generally designed to be used once or for a short period before disposal.

Examples may include certain food service items, disposable plastic goods, and other covered single-use or disposable product categories.

Federal Plastics Registry vs Provincial EPR Reporting

A common question is whether Canada’s Federal Plastics Registry replaces provincial extended producer responsibility reporting.

The answer is no.

The Government of Canada states that the FPR does not replace provincial reports that producers must submit. Provincial reporting requirements vary across Canada, and provinces do not share their EPR data with the federal government. Provincial reporting supports EPR programs and helps provinces and producer responsibility organizations calculate EPR fees.

This means a company may need to manage both:

• Federal Plastics Registry reporting
• Provincial packaging EPR reporting

For companies selling across multiple Canadian provinces, this can create duplicate but non-identical reporting work. The same product or packaging data may need to be mapped differently depending on the federal or provincial requirement.

That is why many companies are moving from spreadsheet-based reporting to structured product compliance software.

What Data Must Be Reported?

Canada plastics reporting requires companies to collect detailed information about plastic products and packaging. The required data may include:

• Product or packaging category
• Product or packaging subcategory
• Resin type
• Resin source
• Waste stream
• Quantity of plastic manufactured in Canada
• Quantity of plastic imported into Canada
• Quantity of plastic placed on the market in Canada
• Quantity placed on the market by province or territory where required
• Calculation method used
• Supporting records and evidence

The Federal Plastics Registry guidance shows reporting fields such as resin type, resin source, methods used to determine quantity, plastic quantity imported into Canada, plastic quantity manufactured in Canada, and plastic quantity placed on the market in each province or territory.

A key point is that companies should report the plastic-only weight, not necessarily the full weight of a product or package. For example, if a product contains metal, paper, glass, and plastic, the reporting focus is the plastic portion.

Canada Plastics Reporting Data Checklist

Before preparing an FPR submission, companies should build a structured data inventory. A practical checklist includes:

Canada’s guidance says obligated reporters must identify calculation methods when submitting data. Possible methods include the specific component identification method, the average bill of materials method, and the fixed-factor calculation method.

Canada Plastics Reporting Deadlines

The reporting deadline is September 29 of the year following the data collection year. For Phase 1, Canada’s guidance states that the 2024 data report was due on September 29, 2025.

For current planning, companies should prepare for the following Phase 1 timeline:

Canada also states that Phase 1 focuses on reports due in 2025 on 2024 data, 2026 on 2025 data, and 2027 on 2026 data.

Is There a Small Business Exemption?

Some companies may qualify for an exemption if they are below the reporting threshold. Canada’s guidance explains that companies are responsible for calculating the amount of plastic packaging and products they import, manufacture, and place on the market to determine whether the de minimis exemption applies. These calculations must be performed annually.

This is important because a company that was exempt in one year may not be exempt in the next year if its product volume, packaging volume, imports, or Canadian market activity changes.

Companies should keep records of de minimis calculations and reconfirm their reporting status every year.

What If Supplier Data Is Missing?

Many companies do not already have complete plastic composition data for every SKU, package, or component. This is especially common when finished products are imported, when packaging is designed by a supplier, or when resin data is not listed on ordinary product specifications.

Canada’s guidance addresses this directly. If a company is subject to the notice, it must provide information it possesses or may reasonably be expected to access. The novelty of the FPR requirements is not considered a sufficient reason for not providing information.

Canada also states that Phase 1 reporting may require contacting upstream suppliers, and that obligated reporters are expected to contact suppliers if more information is needed about product composition.

This is one of the biggest practical challenges for FPR compliance. Companies may need to collect supplier data on:

• Plastic component weights
• Packaging layer weights
• Resin type
• Resin source
• Recycled content
• Product composition
• Packaging composition
• Bill of materials data
• Supporting technical documentation

A strong supplier workflow is essential because plastics reporting depends on information that may sit outside the compliance team.

Recordkeeping and Compliance Risk

Canada plastics reporting is mandatory for organizations that meet the reporting requirements. Persons who fail to report, report late, or knowingly provide false or misleading information may face CEPA penalties.

Companies also need to keep records. Canada’s Phase 1 guidance states that obligated persons must keep copies of all records for three years after the reporting deadline, including detailed records of data and calculations.

This means companies should not only prepare a final number for submission. They should also retain:

• Supplier declarations
• Packaging specifications
• Product composition data
• Resin classifications
• Calculation files
• Methodology notes
• Assumptions
• Approvals
• Version history
• Evidence supporting de minimis determinations

Without organized records, it may be difficult to prove how a reported figure was calculated.

Common Canada Plastics Reporting Mistakes to Avoid

Companies preparing for Federal Plastics Registry reporting should avoid these common errors:

Reporting Total Product Weight Instead of Plastic Weight

The FPR focuses on plastic quantities. If a product includes several materials, companies need to isolate the plastic portion.

Missing Packaging That Is Still in Scope

Packaging can be reportable even when the product inside is not the main reporting focus. This is especially important for importers, private-label retailers, and brands using multiple packaging layers.

Confusing Federal FPR Reporting With Provincial EPR Reporting

The FPR does not replace provincial EPR reporting. Companies may need both federal and provincial reporting processes.

Waiting Too Long to Contact Suppliers

Supplier data collection can take weeks or months, especially for companies with many SKUs, global suppliers, or complex packaging formats.

Failing to Document Calculation Methods

Canada requires companies to identify the calculation methods used. Calculation logic should be retained with the report, not reconstructed later.

Not Rechecking Exemption Status Annually

A company may be below the threshold one year and above it the next. Canada advises companies to keep de minimis records and reconfirm obligations annually.

Step-by-Step Plan to Prepare for Canada Plastics Reporting

Step 1: Confirm Whether You Are an Obligated Producer

Identify whether your company manufactures, imports, or places covered plastic packaging or plastic products on the Canadian market. Pay attention to private-label products, imported products, marketplace sales, and products sold through Canadian distributors.

Step 2: Identify All Covered Products and Packaging

Create an inventory of covered products and packaging. Include packaging layers, plastic components, electronic and electrical equipment, and single-use or disposable products.

Step 3: Classify Products by FPR Category and Subcategory

Map each product and packaging item to the correct Federal Plastics Registry category and subcategory. Misclassification can lead to inaccurate reporting.

Step 4: Collect Resin Type and Resin Source Data

Request resin information from suppliers, packaging manufacturers, component suppliers, or contract manufacturers. Resin type and source are key reporting data points.

Step 5: Calculate Plastic Quantities in Kilograms

Use a consistent calculation method to determine plastic quantities. Canada’s guidance allows different methods, including specific component identification, average bill of materials, and fixed-factor calculation methods.

Step 6: Allocate Placed-on-Market Quantities

Where required, allocate quantities by Canadian province or territory. This may require sales, logistics, ERP, distributor, or shipment data.

Step 7: Validate Data Before Submission

Check for missing resin types, inconsistent weights, duplicate SKUs, incorrect units, and missing supplier evidence.

Step 8: Keep Records for Three Years

Store the final submission, source data, calculation methods, supplier documents, and internal approvals for at least three years after the reporting deadline.

How ComplyMarket Helps with Canada Plastics Reporting

Canada plastics reporting is difficult because the required data is spread across product teams, packaging teams, suppliers, procurement, logistics, and sustainability departments. ComplyMarket helps companies turn this fragmented process into a structured, repeatable compliance workflow.

ComplyMarket’s Canada Plastics Reporting solution is designed to operationalize FPR compliance as a repeatable, audit-ready business process, especially for companies managing many SKUs, multi-layer packaging, and supplier-driven resin data.

1. Producer Determination and Phase 1 Applicability

ComplyMarket can support companies in assessing whether they are likely to fall within Phase 1 reporting obligations and identifying which products, packaging, and business activities need review.

2. SKU and Packaging Mapping

FPR reporting requires products and packaging to be mapped to the correct categories and subcategories. ComplyMarket’s service includes SKU and packaging mapping to Phase 1 categories and residential waste stream decisions.

4. Supplier Data Collection Workflows

Because FPR reporting often requires supplier information, ComplyMarket supports supplier data request workflows aligned with the “reasonably accessible” information expectations described by Canada.

5. Calculation Method Documentation

ComplyMarket helps document calculation methods and maintain audit-ready workpapers. This supports defensible reporting and reduces the risk of inconsistent spreadsheet calculations.

6. Reporting Outputs and Evidence Control

ComplyMarket’s platform can help centralize packaging layers, component weights, resin type and source, version history, supplier evidence, data validation, and reporting outputs.

7. Record Retention and Audit Readiness

Canada requires records to be kept for three years after the reporting deadline. ComplyMarket’s Canada Plastics Reporting service includes support for certification readiness and a three-year record-retention pack.

Why Companies Should Act Now

Even though Phases 2 and 3 have been postponed, Phase 1 reporting continues. Companies should use this period to strengthen internal systems, improve supplier data collection, and reduce reliance on manual spreadsheets.

The most prepared companies will be those that can answer:

• Which products and packaging are in scope?
• Which legal entity is responsible for reporting?
• What resin types and resin sources are used?
• What is the plastic-only weight by SKU, package, and component?
• Which calculation method was used?
• Which supplier evidence supports the data?
• Can the company reproduce the report later if asked?

If the answer to any of these questions is unclear, the company should improve its plastics reporting process before the next deadline.

FAQ: Canada Plastics Reporting and the Federal Plastics Registry

What is Canada plastics reporting?

Canada plastics reporting refers to the mandatory reporting of certain plastic resins, plastic packaging, and plastic products under Canada’s Federal Plastics Registry. The registry collects data to track plastic across its lifecycle.

Is Federal Plastics Registry reporting mandatory?

Yes. Canada states that reporting to the FPR is mandatory for persons that meet the reporting requirements. Failure to report, late reporting, or knowingly submitting false or misleading information may lead to CEPA penalties.

What is the latest Federal Plastics Registry update?

Reporting for Phases 2 and 3 has been postponed, but organizations must continue to report Phase 1 data for the 2024, 2025, and 2026 calendar years.

Who must report in Phase 1?

Phase 1 applies to producers that manufacture, import, or place plastic packaging, electronic and electrical equipment, and single-use or disposable plastic products on the Canadian market.

Does FPR replace provincial EPR reporting?

No. The FPR does not replace provincial reports. Provincial EPR reporting requirements vary, and provinces do not share their EPR data with the federal government.

What is the Canada plastics reporting deadline?

The deadline is September 29 of the year following the data collection year. For example, 2025 data is due in 2026, and 2026 data is due in 2027.

What records should companies keep?

Companies should keep copies of all records for three years after the reporting deadline, including data, calculations, supplier evidence, and methodology documentation.

How can ComplyMarket help?

ComplyMarket helps companies manage Canada Plastics Reporting through producer determination, SKU and packaging mapping, resin data validation, calculation method documentation, supplier data workflows, portal submission support, and audit-ready record retention.