A paper food package can still contain reportable plastic. Thin PE or PLA coatings, clear windows, plastic lids, barrier films and adhesive layers may represent a small share of the total pack weight, but Canadian producers and importers may need accurate resin and quantity data for the Federal Plastics Registry.
Quick answer: do not rely on a finished-product description such as “kraft paper box.” Build a component-level material record showing the board, each coating or film, window, liner, lid and other plastic component. Canadian reporting organizations should confirm their legal obligations, while overseas suppliers should be ready to provide polymer identity and weight data that can be connected to shipped quantities.
What the Federal Plastics Registry Covers in 2026
Environment and Climate Change Canada states that reporting for Phases 2 and 3 has been postponed, while Phase 1 reporting continues for the 2024, 2025 and 2026 calendar years. Reports submitted in 2026 cover applicable 2025 data. The Registry applies to plastic resins, packaging and specified plastic products manufactured, imported or placed on the Canadian market.
For the 2025 and 2026 calendar years, the federal guidance says reporting is required from producers that manufacture, import and place plastic packaging, electrical and electronic equipment, and single-use or disposable plastic products on the market. Companies should check the current Notice, definitions, thresholds and exemptions rather than relying only on a product category.
Who Reports and Who Supplies the Data?
Only organizations in Canada with a Canadian address report to the Registry. An overseas paper-packaging exporter does not file the Canadian report, but it may hold information the Canadian importer needs. The Government of Canada specifically notes that foreign suppliers should support importers with information on resin identities, sources and quantities.
Define responsibilities in the purchasing process:
- Canadian brand owner or importer: determines reporting status and submits the report.
- Packaging converter: provides the bill of materials and component weights.
- Film, coating and lid suppliers: identify polymer families and specifications.
- Data owner: maintains product-to-SKU conversions and shipment totals.
Plastic Components Hidden inside “Paper” Packaging
Common components to review include:
- PE extrusion coatings on cups, bowls and takeaway boxes;
- PLA or other biopolymer coatings;
- PET or PLA windows in bakery and salad cartons;
- PP, PET or other plastic lids;
- lamination films and heat-seal layers;
- plastic barrier liners or bags supplied with paper packs;
- adhesives or labels where the reporting method requires them; and
- secondary and transport packaging placed on the Canadian market.
“Compostable,” “bio-based” or “water-based” descriptions do not automatically mean plastic-free. Ask for a composition statement rather than inferring the resin from marketing language.
Create a Component-Level Data Sheet
For each packaging SKU, record:
- finished product code and description;
- net weight per piece;
- component name and material;
- resin identity where applicable;
- plastic weight per component and per finished piece;
- percentage by weight;
- supplier and specification revision;
- country of manufacture;
- pieces per carton; and
- the conversion formula from imported pieces or cartons to kilograms.
How to Calculate Thin Coating Weight
A coating may not be practical to remove and weigh from every finished cup. Use a documented calculation based on coated area and coat weight, then validate it against supplier specifications or laboratory measurements.
For example:
plastic weight per piece = coated surface area × coating mass per square metre
Record whether the value covers one-sided or two-sided coating and whether seams or process variation are included. For a window, use the approved film thickness, density and cut area, or a verified supplier weight.
Control Changes during the Reporting Year
The same SKU can change when a film source, coating weight or lid material is revised. Maintain effective dates for every bill-of-material version. Shipment quantities should be matched to the version actually supplied, not automatically multiplied by the latest specification.
A change-control form should capture the old and new material, implementation date, affected orders, reason for change and approval. This also supports food-contact and performance review.
Federal and Provincial Reports Are Separate
The Federal Plastics Registry does not replace provincial EPR reporting. Provincial definitions, calculations and fee categories may differ. Build one master packaging-material dataset, then map it to each reporting scheme instead of forcing every scheme into one classification column.
Buyer Audit Questions
- Can the supplier identify every plastic or polymer-containing component?
- Is polymer identity supported by a current specification?
- Can coating and film weights be calculated per finished piece?
- Are values linked to the correct production revision?
- Can carton quantities be reconciled with import records?
- Will the supplier notify the buyer before material changes?
- Can data be exported in the buyer’s requested units and template?
Build Reporting Data into the RFQ
Request the bill of materials and plastic-weight data during quotation. A low unit price can become expensive when the importer must reconstruct coating, window and lid information near a reporting deadline.
EcoGreenPack can provide product dimensions, packing quantities and available material specifications for buyer data review. Contact EcoGreenPack with the SKU list, Canadian importer requirements and requested reporting template.
Official Source
See the Government of Canada Federal Plastics Registry page. Reporting organizations should review the current Notice and obtain professional advice where needed.
