Canada Plastic Registry Announced

On April 22, 2024, Canada announced the implementation of a Federal Plastic Registry to monitor the types and volumes of plastic products, including plastic packaging used in agriculture and food manufacturing, through their life cycle on the Canadian market.

Environment and Climate Change Canada (ECCC) announced the establishment of Federal Plastics Registry to require plastic resin manufacturers, producers of plastic products (including importers), and service providers to report each year, starting in 2025, on the quantity and types of plastic they place on the market and how that plastic moves through the economy.

The reporting requirement extends to the quantity of plastic that is collected and diverted, reused, repaired, remanufactured, refurbished, recycled, processed into chemicals, composted, incinerated, and landfilled.

Annual reporting to the Federal Plastics Registry will start in September 2025, for data related to the
2024 calendar year, and continue until September 2027. ECCC indicated that reporting requirements for beyond 2027 would be covered by a future information-gathering notice.

Small businesses that generate less than one metric ton of plastics per year are exempt from reporting.

Examples of plastic products subject to the reporting requirement include:

• Plastic packaging, filled and unfilled, rigid and flexible, within the following subcategories:
•  Beverage containers
•  Food contact materials
• Plastic products used in agriculture and horticulture, such as totes and drums, bags,  bale wraps, bags or tubes.
• Agricultural and horticultural film and sheeting (e.g. for silage, mulch, flooring, plant
  protection)
•  Structural plastic, and CO2 tubing for greenhouses; propagation trays and growing pots
• Maple syrup tubing and taps; agricultural and horticultural twine

Additional information and full requirements can be found in ECCC’s Federal Plastics Registry Notice.

In complying with plastic reporting requirements, Canadian importers may request information from
their suppliers, such as U.S. exporters of agriculture and food products, who thus end up sharing in the
effort of collecting and reporting on the data. Moreover, non-resident importers (NRIs) – U.S. based companies exporting to Canada and acting as the importer of record – may be directly subject to the reporting requirements.

ECCC is likely to rely on the information collected via the Federal Plastics Registry to inform the
development of future plastic reduction regulations, or measures, such as requirements related to
minimum recycled content, or plastic packaging reduction requirements.

In 2023, Canada was the number one export market for U.S. agricultural and related products valued at $32.9 billion, of which the high-value consumer-oriented category totaled a record $20.2 billion.