Canadian Federal Plastics Registry

The Federal Plastics Registry (FPR), introduced by the Government of Canada, represents a significant step towards achieving a Canada-wide strategy on zero plastic waste by 2030 through 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, which will be phased in from 2025 to 2028, aims to enhance transparency, align with provincial extended producer responsibility (EPR) regulations, and support a circular economy. Through improved efficiency and effectiveness of EPR in Canada, the FPR strives to achieve cost savings of $500 million, greenhouse gas emissions reductions of 1.8 megatonnes, and the creation of 42,000 direct and indirect jobs.

Entities involved in the manufacture, import, and management of plastic products and resins will be required to report annually. The FPR also has potential implications for non-reporters and consumers.

The Federal Plastics Registry (FPR) was established to support Canada's goal of zero plastic waste by 2030. It aims to provide crucial data to track progress, inform policymaking, and improve the efficiency and effectiveness of extended producer responsibility (EPR) programs across Canada. By standardizing data collection and reporting, the registry will help reduce plastic pollution and promote circularity.

The following entities are required to report:

• Manufacturers and importers of Plastic Resins
• Producers of Plastic Products (e.g., brand owners, importers, manufacturers, retailers, etc.)
• Generators of plastic waste at industrial, commercial, or institutional (ICI) facilities
• Service providers in plastic management
  

The impacted categories include plastic resins, packaging, electronic and electrical equipment (EEE), single-use or disposable plastic products, agriculture and horticulture, tires, transportation, construction, fishing and aquaculture, and textiles and apparel.

Yes, the Federal Plastics Registry mandates annual reporting for a wide range of entities involved in plastic production and management.

Failure to comply with an obligation arising from the Notice, including failing to report, or providing false or misleading information, may result in penalties, including fines which can range from a maximum of $25,000 for an individual convicted summarily to a maximum of $500,000 for a large corporation convicted on indictment of a first offense and up to $1 million for subsequent offenses.

Where offences are continued on more than one day, entities may be liable to be convicted for a separate offence for each day on which it is continued. Directors and officers may also be held personally liable. Non-compliance could also lead to operational, market, legal, and financial risks.

Companies must report on the quantities and types of plastic products and resins they manufacture, import, and place on the Canadian market, as well as the plastic waste generated and collected for diversion or disposal. Reporting will be phased in by category of plastics products, starting in September 2025. The required data includes detailed information on plastic quantities, usage, design types, sources, and end-of-life management.

Companies must submit their 2024 data by September 29, 2025. Subsequent annual reporting deadlines will follow, with phased implementation for different categories of plastic products from 2025 to 2028:

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

Companies must report total plastic placed on the Canadian market, quantities of plastic used/disposed of, details of design types and sources, and end-of-life management. Data must be submitted through the Federal Plastics Registry online portal managed by Environment and Climate Change Canada (ECCC).

Organizations in scope may already have some of the data needed for the FPR through existing environmental levies and extended producer responsibility (EPR) programs, but the new registry likely requires more comprehensive and standardized reporting.

The FPR expands reporting requirements compared to existing mandates from provinces and territories, covering a broader range of plastic items and tracking them from production to end-of-life management, and aims to address inconsistencies in current data collection across jurisdictions. Standardizing data collection across Canada requires organizations to adjust reporting methods and gather additional data points, including detailed information on resin types, sources, and plastic packaging breakdowns. Reporting organizations may therefore need to implement new systems to track the data. The FRP's phased implementation timeline is meant to provide relief so that organizations can address this crucial gap expand their data collection efforts over a more pragmatic timeline.

While the Notice does not mandate third-party verification, entities may choose to obtain verification of datapoints submitted to the registry. In addition, certain entities may already be mandated to obtain third-party verification for provincial EPR programs or PROs/SOs requirements.

Provincial extended producer responsibility (EPR) laws

Extended producer responsibility (EPR) laws vary by province in Canada. To harmonize regulations, the Canadian Council of Ministers of the Environment (CCME) created a framework through the Canada-Wide Action Plan. In 2019, the CCME also introduced a plan for Zero Plastic Waste by 2030, aiming for full EPR programs nationwide. The establishment of the FPR illustrates the shifting responsibility for recycling packages from municipalities to producers.

Similar to the U.S., producers in most provinces can meet their EPR obligations through Producer Responsibility Organizations (PROs) and Stewardship Organizations (Sos). Producers can pay these organizations to handle the logistics of collecting and recycling the products.

_{* This chart is intended to be illustrative and does not cover every Canadian province with an EPR program.}

Pending Canadian EPR Laws

The Northwest Territories and Newfoundland implemented packaging enabling laws while Nunavut is the only territory without EPR packaging laws

European Packaging and Packaging Waste Regulation (PPWR)

The European Union's Packaging and Packaging Waste Regulation (PPWR), officially designated as Regulation (EU) 2025/40, was published in the Official Journal on January 22, 2025, aiming to overhaul the existing packaging framework to promote sustainability and circularity across the EU. It came into force on February 11, 2025. Its application is scheduled for mid-2026 (i.e., 18 months following the date of entry into force).

Overall, this new regulation aims to:

• Prevent and reduce packaging waste, including through better design such as more reuse and refill systems.
• Make all packaging on the EU market recyclable in an economically viable way by 2030.
• Safely increase the use of recycled plastics in packaging.
• Decrease the use of virgin materials in packaging and put the sector on track to climate neutrality by 2050.

To achieve these objectives, the new PPWR regulation includes new modalities to the EPR. For example, by introducing new eco-modulated EPR fees based on the recyclability performance of packaging products to incentivise more sustainable packaging design choices. As it also introduces harmonised labelling and marking requirements for different packaging formats, EPR symbols will still be allowed but will have to be provided via digital markings only.

Note that it is directly applicable in all EU member states, for all packaging placed on the EU market, and that non-EU companies selling in the EU must also comply.

Supply chain and procurement: Businesses that deal with companies required to report may need to adjust their operations to meet new demands for transparency and compliance. This can include changes in procurement practices, increased documentation requirements, and potential shifts to more sustainable materials.

Market influence: The registry may influence market behavior by encouraging suppliers and ecosystem alliances to prefer companies that comply with environmental regulations. This can result in increased pressure on non-reporting companies to adopt sustainable practices and align with the broader market trends toward zero plastic waste.

Brand and reputation: As companies are required to report on their plastic usage and waste, consumers may become more aware of the environmental impact of their purchases. This increased transparency can help drive consumer behavior towards more sustainable products and practices.

Product innovation: The registry will help encourage companies to innovate and develop products and packaging with less virgin plastic, higher recycled content, or alternative materials. Consumers may see a shift in the availability of products, with an increase in sustainable options and a potential decrease in single-use plastics.

Cost implications: Complying with the registry's requirements may involve additional costs for companies, which may be passed on to consumers. However, the long-term benefits of a circular economy and reduced plastic waste may outweigh these initial costs.

Companies outside of Canada that export their products to Canada do not need to report to the FPR. Only Canadian entities, with a Canadian address, that meet the reporting criteria must report.

While the FPR does not apply to plastic resins and products exported outside of Canada, Canadian businesses will need to ensure their practices align with any additional Canadian and international standards for plastics management. Adopting sustainable practices and complying with the registry can provide a competitive advantage in foreign markets. Cross-border collaboration may be necessary to ensure compliance.

Organizations potentially in scope of the FPR should confirm their reporting obligations, assess readiness, develop quantification methodologies, and prepare to report data through the federal online portal. Staying alert to ongoing developments and regulatory changes is crucial to ensure compliance and support Canada's Zero Plastic Waste Agenda.

Organizations not in scope should confirm with their pertinent suppliers if they are in scope, as they may be impacted indirectly at a later time.

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.