Environment and Climate Change Canada (ECCC) recently notified stakeholders of its intent to delay the reporting requirements with respect to Phases 2 and 3 of the Federal Plastics Registry (FPR). The deadlines for reporting with respect to Phases 2 and 3 of the FPR are set to come into force in September 2026 and September 2027, respectively. Phases 2 and 3 reporting expand on the scope of Phase 1 reporting to add reporting requirements with respect to plastics (packaging and certain products) destined for commercial, industrial and institutional waste streams, as well as information on the generation and management of certain plastic wastes, among other requirements. The delay of Phases 2 and 3 does not affect Phase 1 reporting requirements; organizations captured by Phase 1 of the FPR must continue to meet their reporting obligations for all reporting years.
The FPR was established pursuant to subsection 46(1) of the Canadian Environmental Protection Act, 1999 for the purpose of providing ECCC with information about the lifecycle (e.g., production, use and disposal) of plastic products and packaging in Canada. ECCC published its Notice with respect to reporting of plastic resins and certain plastic products for the Federal Plastics Registry for 2024, 2025 and 2026 on April 20, 2024, which details the plastic products, packaging and associated activities that require reporting under the FPR for the 2024, 2025 and 2026 calendar years.
The stated reason for the delay in Phase 2 and 3 reporting is to allow time for ECCC to streamline and optimize reporting requirements based on feedback from stakeholders and to allow organizations more time to collect data.
ECCC has indicated that that it will publish a Notice of Intent in the Canada Gazette early in 2026 to communicate the delay of Phases 2 and 3 of the FPR. ECCC will publish a new Notice in the Canada Gazette in summer 2026 to establish the reporting requirements for the FPR for the 2027, 2028 and 2029 calendar years.
If you have any questions about reporting to the FPR, please contact the authors or a member of Bennett Jones' Environmental Law Group.
