Understanding the Section 46 Notice of Federal Plastics Registry
July 2, 2024On April 20, 2024 Environment and Climate Change Canada (ECCC) published a Section 46 notice in the Canada Gazette, Part 1, regarding new reporting requirements for certain plastic products. This notice, following a consultation process for which RCC provided extensive feedback, mandates producers to report comprehensive data on the lifecycle of plastics in Canada, impacting retailers and quick service restaurants. The notice applies to calendar years 2024, 2025 and 2026 and requires detailed information on the types and quantities of plastics introduced into the market and their subsequent downstream management. ECCC plans a phased implementation, with reporting deadlines set for September 29 of each reporting year, covering various product categories and resin types.
ECCC has committed to issuing guidance documents, providing IT system access for testing, and issuing the final reporting instrument by December 30, 2024. It must be noted that compliance with the Section 46 notice under the Canadian Environmental Protection Act (CEPA) is mandatory, with penalties for non-compliance or provision of false information including fines or imprisonment.