Extended producer responsibility laws require companies to track the materials they put on the market and fund programs to collect and recycle those materials at the end of the product lifecycle. Like in the U.S., companies doing business in Canada must navigate a patchwork of EPR laws for packaging materials, as all but four of its 13 provinces and territories now have such regulations in place.

However, under the Canadian government’s Federal Plastics Registry, plastics producers operating in Canada are obligated to report the quantities of plastic they place on the Canadian market as a whole each year, as well as specify the source of the resins used (i.e., recycled or virgin petroleum). Generators of plastic waste who send waste for disposal or diversion also must report, as well as service providers who collect plastic waste, making Canada’s registry somewhat broader than most EPR programs in the U.S.

ICYMI: Canada Mandates Plastics Reporting To Inform Future EPR Efforts

Now, as the first reporting deadline for the registry approaches on September 29, it’s important to know your company’s potential obligations for the nationwide initiative to collect data as part of Canada’s plan to move toward the goal of zero plastic waste by 2030.

Reporting Requirements

The Canadian government has published guidance for the current registry deadline, which covers 2024 data, and the reporting portal is open in Canada’s Regulatory Services Platform (login required).

Canada defines “producer” as one of the following:

  • A brand owner or intellectual property holder who resides in Canada.
  • The first person/entity to manufacture or import a plastic product in Canada.
  • A Canadian retailer who supplies the product to the consumer.


Organizations outside of Canada that export their products to Canada do not have an obligation to report to the registry. Small businesses that manufacture, import, generate or manage less than 1,000 kilograms (2,204.62 pounds) of plastic products or packaging per calendar year are also exempt.

Reporting requirements are scheduled in phases, starting this month, with reporting due on three categories of plastic placed on the market during the 2024 calendar year:

  • Plastic packaging – bottles, containers, wraps, bags, etc.
  • Single-use and disposable plastics – straws, cutlery, cups, etc.
  • Plastic components in electronic and electrical equipment for residential use – TVs, computers, appliances, etc.

The program is expected to expand to include reporting on textiles and apparel in coming years.

RELATED: Canada Sets Stage, Schedule For Single-Use Plastics Ban

For the Phase 1 reporting deadline on September 29, obligated producers must report:

  • Category and subcategory of packaging or plastic products (one of the three listed above)
  • Resin type (see Schedule 1 for a list)
  • Resin source (virgin, bio-based, post-consumer recycled, post-industrial recycled)
  • Quantity of each resin (in kg) by product category and resin type
  • Calculation methods


Also, reporting companies must keep copies of the information required for at least three years after the reporting deadline. This includes calculations, measurements and other data on which the information reported to the registry is based.

Companies often must rely on their supply chain partners to provide these details, and the Canadian government of Canada has drafted a letter template (available in English, French, Chinese and Spanish) to request information on the plastic composition of products or packaging. To receive a copy, email RFP-FPR@ec.gc.ca with the subject “Foreign Supplier Letter” and include the languages you need.

Penalties for noncompliance can be steep, with up to $25,000 per offense for individuals and up to $500,000 per offense for companies. Repeat offenses can double those fines to $50,000 for individuals and $1 million for companies.

Opportunity For Innovation, Cost Savings

The registry requirements may present an opportunity, as paying more attention to packaging should reveal prospects for cost savings through more efficient use of materials.

EPR laws are meant to encourage businesses to redesign their packaging to be less wasteful, but with promo, protecting the decoration is often a critical part of what the packaging does. That doesn’t mean there aren’t opportunities for better choices, however.

RELATED: Guide To Reducing Waste In Packaging For Promotional Products

“This has highlighted the need for better data on packaging, not just for EPR, but also doing a carbon footprint on our products,”  Brianna Mazze, vice president of compliance and sustainability for Ontario-based SRG, the No. 17 supplier in the PPAI 100, told PPAI Media last November. “… The best, most sustainable packaging is no packaging at all, so if we can just eliminate some, there could be cost savings from there, too.”

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