Canada’s plastics registry

Canada’s plastics reporting rules just changed the game. If your business touches plastic—anywhere in the supply chain—your compliance clock is ticking.

Phase 2 of the Federal Plastics Registry is coming fast, expanding requirements and raising the bar for every manufacturer, importer, and manager of plastic products. Miss the mark, and you risk hefty fines—and personal liability.

Here’s what Phase 1 taught us, and how you can get ahead before the next deadline hits. Two months have passed since organizations filed their inaugural reports in response to Phase 1 of the Notice with respect to reporting of plastic resins and certain plastic products for the Federal Plastics Registry for 2024, 2025 and 2026, dated April 20, 2024 (the “Federal Plastics Registry” or FPR). Through 2025, KPMG helped entities involved in the manufacture, import, and management of plastic packaging, products, and resins navigate the complexities of the new reporting obligations. In this blog, we share key insights and lessons learned from Phase 1 FPR reporting to help organizations as they prepare for Phase 2.

For more information, frequently asked questions, and insights gleaned from our review of the FPR, including how KPMG can support you, please see our previous article: Canadian Federal Plastics Registry: Understanding the implications for your business, suppliers and consumers.

On April 20, 2024, the Government of Canada introduced the FPR in alignment with its Canada-wide strategy on zero plastic waste by 2030. The FPR establishes a reporting system focused on the collection of standardized data on plastic products, packaging, and resins manufactured in Canada, imported into Canada, or placed on the Canadian market. The reporting system, to be phased in from 2025 to 2028, aims to enhance transparency, align with provincial extended producer responsibility (EPR) regulations, support a circular economy, and inform future regulations.

For convenience, a table outlining plastic packaging, product categories and reporting timeframes is set out below:

_{Source: Federal Plastics Registry, Government of Canada (March 7, 2025)}

Failure to comply with an obligation under the FPR or providing false or misleading information, may constitute an offence under the Canadian Environmental Protection Act (CEPA) and result in fines of up to $500,000 for the first offence of a large corporation, and $1 million for subsequent offenses, with directors and officers also being held personally liable.

Phase 1 reporting has revealed valuable insights relevant to organizations preparing for future phases.

• Multidisciplinary approach: Success in Phase 1 hinged on integrating legal interpretation with technical expertise. The complexity of legally defined product categories and the intricate producer hierarchy obligations presented substantial challenges. To meet this challenge, our firm has adopted a multidisciplinary model, bringing together legal and technical expertise, to deliver fit-for-purpose, comprehensive and integrated support.
• Key terms: Many key terms remain undefined or lack clear definition, requiring legal interpretation (e.g., manufacturer, importer, placed on the market, service provider, residential waste stream, brand owner, etc.). In addition, reliance on ECCC’s guidance for defined terms and key concepts comes with legal risk—while regulator guidance is informative, it is not legally binding.
• Thresholds: For many organizations, the de minimis exemption (i.e., those who manufacture, import, or place less than 1000 kg of plastic products or packaging on the market per calendar year are exempted from reporting) is a low bar and will feel even lower in Phase 2. This is because Phase 2 significantly expands the scope of reportable plastics, including more product categories, material types, and activities, meaning that the same threshold (1,000 kg) will capture a much broader range of items and organizations that were previously out of scope. For context, the exemption applies to the quantity of plastic within an item and is not based on the overall weight of the item itself. What is more, companies are asked to calculate their quantities of an item under a given activity and then determine a combined national amount (i.e., 500 kgs of plastic that is imported and then later placed on the market would be calculated as 1,000 kgs of plastic).
• Kick-off meetings: Early education on reporting obligations proved essential. Clients benefited from a clear understanding of their obligations under the registry, setting the stage for efficient and accurate compliance.
• Applicability questionnaire: Completing a detailed applicability questionnaire, with interpretation facilitated by our legal team, helped clients assess their obligations and clarify the scope of their reporting. Working sessions with clients fostered collaboration, deeper understanding and resolved ambiguities.
• Parallel workstreams: While completing questionnaires, we simultaneously advanced work on quantification, scoping, and definitions guidance—drawing on technical expertise to develop efficient processes and clear methodologies.
• Optionality and interpretation: Phase 1 highlighted that within the reporting requirements, there is considerable optionality for methodologies and areas that require nuanced interpretation of legal definitions and hierarchies. Our team helped clients identify these areas, assess the potential impacts, and provided guidance through the decision-making process, ensuring informed and strategic reporting choices, while mitigating legal risk.
• Extension requests: Despite a lack of clear guidance in Phase 1, our team supported clients to successfully obtain reporting deadline extensions when needed.
• Integration and future-proofing: Consideration of future Phase 2 reporting requirements was paramount to ensure that processes can be scaled, adapted and repurposed to support future Phases and evolving plastics and waste-related regulatory requirements for years to come.
  

As we transition toward Phase 2 of the Federal Plastics Registry, with a reporting deadline of September 29, 2026, our focus shifts to supporting clients to operationalize lessons learned and expanding our outreach to impacted sectors. Phase 2 promises to be more comprehensive and operational in nature, with new guidance pending, expanded reporting requirements, and increased complexity.

Given the expanded product categories, inclusion of Institutional, Commercial and Industrial (ICI) facilities and waste management service providers, the following sectors are expected to be significantly impacted by the Phase 2 requirements:

• Manufacturing
• Energy and Natural Resources
• Retail and Distribution
• Construction
• Transportation/Automotive
• Textiles and Apparel
• Agriculture and Horticulture
• Fishing and Aquaculture
• Waste Management

Proactive engagement, informed by Phase 1 lessons and expert multidisciplinary support, will be critical. With the Phase 2 reporting deadlines less than 10 months away, organizations should begin preparing now to ensure timely and effective compliance. Our team is prepared to help clients navigate new complexities, clarify obligations, and turn compliance into an opportunity for growth.

KPMG in Canada offers an integrated team of sustainability and circular economy advisory, reporting, trade and customs, and legal subject matter experts with deep industry experience to assist Canadian organizations with assessing, reporting, monitoring, and improving plastics management. Our comprehensive support includes advising on regulatory compliance, developing processes and controls, providing training, and preparing reports according to the Environment and Climate Change Canada (ECCC) Notice and additional guidance.