Brief Summary of the Federal Plastics Registry – Phase 1 

If you sell products that contain plastic in any of the packaging materials you may be obligated to report the volume of plastic used under the Federal Plastics Registry. Read more to determine how this mandatory reporting may affect you business in Canada. 

Overview of the Federal Plastics Registry (FPR) 

The Federal Plastics Registry (FPR) is a national initiative by Environment and Climate Change Canada (ECCC) to collect standardized data on plastics across their lifecycle—from production to end-of-life. The goal is to support Canada’s transition to a circular plastics economy and reduce plastic pollution. 

Phase 1 of the FPR focuses on collecting data from producers of: 
Plastic packaging 
Single-use or disposable plastic products 
Electronic and electrical equipment (EEE) 

Reports for Phase 1 are due in 2025, covering data from calendar year 2024. 

Who Must Report in Phase 1 

1. Entities required to report include: 
   Producers of plastic packaging and products 
   Importers of plastic-containing goods 
   Brand owners, manufacturers, retailers, and marketplace facilitators who place plastic products on the Canadian market 
2. The term “producer” is broadly defined and includes: 
   Canadian brand owners 
   Importers (if the brand owner is not in Canada) 
   Sellers or facilitators (if neither of the above applies) 

Key Definitions Relevant to Cosmetics, NHPs, and Non-Prescription Drugs 

1. Plastic Packaging includes: 
   Primary packaging (e.g., bottles, jars, tubes) 
   Secondary packaging (e.g., boxes, blister packs) 
   Tertiary packaging (e.g., shipping materials) 
2. Residential Waste Stream refers to plastic packaging or products that are: 
   Typically disposed of by households 
   Collected through municipal waste or recycling programs 

If a product’s packaging is reasonably expected to end up in the residential waste stream, it falls under the scope of Phase 1 reporting. 

Requirements for Manufacturers and Importers of Cosmetics, NHPs, and Non-Prescription Drugs 

1. Reporting Obligation
   Manufacturers and importers of these products must report if:
   They place plastic packaging on the Canadian market 
   The packaging is likely to enter the residential waste stream

   This includes: 
   Cosmetic containers (e.g., shampoo bottles, lotion tubes) 
   NHP packaging (e.g., vitamin bottles, blister packs) 
   Non-prescription drug packaging (e.g., pill bottles, nasal sprays) 

2. Information to Report 
   Producers must report the following for each product category: 
   Type of plastic resin used (e.g., PET, HDPE, LDPE) 
   Source of resin (virgin, recycled, bio-based) 
   Weight of plastic placed on the market 
   End-of-life fate (e.g., collected, recycled, landfilled) 

3. Calculation Methods 
   Three methods are provided to estimate plastic weights: 
   Specific Component Identification: Direct measurement of each component 
   Average Bill of Materials (ABOM): Use of average weights for similar products 
   Fixed Factor Method: Use of standard conversion factors 

   Companies may choose the method that best suits their data availability. See the guide linked below for more details on each calculation method. 

4. De Minimis Exemption 
   Entities are exempt if they: 
   Place less than 1 tonne of total plastic packaging on the market annually 
   Have less than $1 million in gross annual revenue in Canada 

   However, if either threshold is exceeded, reporting is mandatory. 

Examples from the Guidance 

Example: Cosmetic Importer 
A company imports face creams in plastic jars and sells them under its own brand in Canada. Since the jars are plastic packaging and enter the residential waste stream, the company must report the weight and type of plastic used. 

Example: NHP Manufacturer 
A Canadian manufacturer produces vitamin supplements in plastic bottles. As the brand owner and manufacturer, it must report the plastic packaging data, including resin type and weight. 

Reporting Process 

1. Platform 
   Reports must be submitted through the Federal Plastics Registry online portal, which will be launched in 2025.
   The online portal can be accessed at: Regulatory Services Platform
2. Timeline 
   Data Year: 2024
   Reporting deadline: September 29th, 2025 
3. Confidential Business Information
   Companies may request confidentiality for sensitive data but must justify the claim. Not all data will be eligible for protection.

Compliance and Enforcement 

The FPR is backed by a Canada Gazette Notice, making it a legal requirement under the Canadian Environmental Protection Act (CEPA). Non-compliance may result in enforcement actions, including penalties. 

Next Steps for Businesses 

1. Assess your obligations: Determine if your packaging meets the criteria.
2. Collect data: track plastic types and weights used in 2024.
3. Choose a calculation method: Select the most appropriate estimation approach.
4. Prepare for reporting: Familiarize yourself with the FPR portal and requirements.
5. Consult the guidance: Use the full document for detailed examples and tools. 

Guide for Reporting to the Federal Plastics Registry – Phase 1 

DELL TECH HAS PROVIDED PROFESSIONAL, CONFIDENTIAL CONSULTING SERVICES TO THE SPECIALTY CHEMICAL INDUSTRY IN CANADA, THE USA, EUROPE AND ASIA FOR THE LAST 40 YEARS.