Environment and Climate Change Canada (ECCC) has delayed the implementation of Phases 2 and 3 of the Federal Plastics Registry (FPR) sending a wave of relief through the Canadian manufacturing and retail sectors. This move by ECCC acknowledges the challenges companies faced with Phase 1 reporting, and the immense data hurdles producers face in tracking complex resin and industrial waste streams.
At CGlobal, the EPR consulting division of H2 Compliance, we are helping our clients utilize this additional time to bridge the “data gap” between their supply chains and upcoming FPR requirements.
Why were Phase 2 and 3 of the Federal Plastics Registry Delayed?
The Federal Plastics Registry Phase 2 & 3 delay is a direct response to industry feedback regarding the complexity of the initial rollout. While the ECCC remains committed to a zero-plastic-waste future, the pause on Phases 2 and 3 allows for:
- Improved reporting guidance: ECCC will have time to provide clarifications and improved reporting guidance based on Phase 1 learnings and feedback
- Operational Readiness: Companies will have time to work on their data gathering and data quality processes
- Improved policy: Better FPR data on plastics production, use, and waste in Canada will inform circular economy policy development
The New Reporting Roadmap
It is vital to note that while Phases 2 and 3 are delayed, the obligation for Phase 1 remains in effect. The next Phase 1 reports will be due on September 29, 2026.
What is the “Summer 2026 Notice”?
Section 46 of the Canadian Environmental Protection Act (CEPA) created the FPR, and the ECCC is expected to publish a new Section 46 Notice in Summer 2026. This notice will act as the new rulebook, likely providing the “clear and achievable” guidance that industry organizations have been calling for. At this time, it is expected that reporting will not be retroactive; it will begin from the new start dates.
How to Prepare During the Federal Plastics Registry Delay
A delay is not cancellation. Companies that wait until 2026 to organize their data will face significant risks under CEPA enforcement.
- Educate yourself on the FPR with resources like this article and gain valuable support from EPR experts, like the team at CGlobal.
- Confirm obligation: Under which Phase does your company have obligations? Phase 1 covers those who place plastic in packaging, electronic and electrical equipment, and single-use or disposable products to the residential waste stream. Phase 2 covers additional product categories such as plastic resin, tires, transport products (cars/trucks), construction material, agriculture/horticulture equipment, fishing/aquaculture gear, and textiles. Phase 2 also expands the scope to Industrial, Commercial, and Institutional (ICI) streams and waste generated on these premises.
- Engage Suppliers Early: Use the pause to gather resin composition data from international suppliers—this remains the most difficult data point for most.
- Review your data: Is your data gathering and quality assurance process robust? Is it audit-ready?
- Monitor the De Minimis Threshold: Confirm if your total plastic waste stays below the 1,000 kg exemption limit.
Expert EPR Consulting for the Road Ahead
Navigating the Federal Plastics Registry requires a partner who understands the intersection of Canadian law and global supply chain logistics. CGlobal can provide technical expertise to turn this regulatory delay into a long-term compliance strategy.
Published December 22nd, 2025
This article was generated with the assistance of Artificial Intelligence.