From compliance to opportunity: embracing Canada's new Federal Plastics Registry 

In brief

• A new Canadian reporting requirement — the Federal Plastics Registry (FPR) — is set to impact companies that import, distribute and sell products and packaging in Canada.
• This initiative mandates that producers enhance their current extended producer responsibility (EPR) reporting practices by publicly disclosing detailed data on the composition of plastic in their packaging and products. 

What does this mean for my business?

The FPR aims to establish a central repository for data on plastic production and usage in Canada. Starting September 29, 2025, companies will be required to report annually through an online portal on the Environment and Climate Change Canada (ECCC) website. This report must detail the quantity and types of plastic they manufacture, import and place on the market across each province and territory. 

The data granularity exceeds current EPR reporting requirements: data disclosed must include the plastic resin type (e.g., low-density polyethylene resin), plastic resin source (virgin fossil-based resin, post-industrial or post-consumer recycled resin), waste stream (residential or other), quantities in kilograms and their calculation method (average bill of materials or other) and whether the plastics were manufactured in Canada or imported. Important to note, the federal government will make the data reported publicly available.

The reporting requirements are being implemented in four phases over 2025 to 2028. The deadline to report for Phase 1 is September 29, 2025, based on 2024 data. Note that reporting requirements depend on the industry and products placed on the market and should be assessed at the company level to ensure full compliance. 

The below example applies to a retailer that sells apparel and accessories, targeted by the first two phases of the FPR:

2025:

For phase one, reporting is required by September 29, 2025 on the quantity of plastic used in all packaging and single-use items (e.g., polybags, plastic hangers and hangtags, reusable shopping bags, ecommerce mailers and plastic gift cards).

2026:

The following year, the company must report on the plastic composition of its products (e.g., the polyester content in all fabrics used for garments and other soft goods such as curtains and linens, as well as the plastic resins found in footwear).

Further guidance from the government on Phase 2 is expected later in 2025.

How can you prepare?

Is your company ready to meet the detailed reporting standards for plastics found in your packaging and products? Here are three actionable steps to prepare for the Canadian Plastics Registry:

1. Assess your current state: Begin by determining which entities in your value chain are targeted by the FPR and who ultimately has the responsibility to report data annually through the online portal. Then, look to understand existing packaging and product procurement data and processes in place to report to the Federal Plastics Registry, identifying primary data gaps against the reporting requirements. If product-level data is missing, you may need to engage with suppliers to understand the level of effort and timelines to provide the requested data. Effective communication with suppliers is crucial so they understand their role in annual compliance. EY advisors can help you identify gaps during a current-state and supply chain mapping assessment to help streamline this process and establish a roadmap to meet requirements.
   
   
2. Collect supply chain data: Identify all packaging and products containing plastics and prioritize your data-gathering efforts to meet your disclosure timelines. Gather essential information from implicated suppliers, including resin type, source, product categories, subcategories and the quantity of each resin in packaging or products, in kg.
   
   For more accurate reporting, consider using the Specific Component Identification Method, which uses actual weights of plastic components. Alternatively, you could us the Average Bill of Materials Method for a more generalized approach. If there are gaps in your data, consider using the Fixed-Factor Calculator Method to estimate the missing information.
   
   Keep all source records on file, as producers will be subject to self-verification requirements for the first two years after the registry comes into force.
   
   
3. Update your reporting processes: Create new or modify existing internal reporting processes and systems to accurately collect and report the required data. Ensure internal teams across procurement and finance as well as key external suppliers are trained and prepared to report in a timely and accurate manner. Identify and implement improvements on data collection processes before the next disclosure cycle.

Should you consider a broader transformation of your supply chain?

While immediate compliance with the FPR and other product sustainability regulations may be a short-term goal, market forces are driving a focus on moving from a production-, consumption-, disposal-based “linear” economic model to a circularity model.

What market forces are calling for transparent, circular and sustainable supply chains?

• Evolving compliance obligations with regulatory risks associated with responding to new taxes, extended producer responsibility requirements and mandatory supply chain disclosures
• Rising customer, consumer, stakeholder and employee expectations for trust and transparency
• Growing consumer demand for sustainable packaging and products backed by substantiated claims
• Rapid technological advancements and competition in a time of disruption

Forward-thinking companies are transforming their global supply chain data collection and reporting processes to enhance efficiencies and meet sustainability commitments that rise to meet the challenge of these market forces. The benefits of undertaking a broad-based reporting and sustainable supply chain transformation can be long lasting and differentiating for consumer products brands.