NPRI reporting requirements, thresholds and filing deadlines
NPRI reporting depends on facility activities and substance thresholds. For 2026 data, the notice sets June 1, 2027 as the deadline. File through SWIM.
NPRI reporting applies to Canadian facility owners or operators who meet the applicable facility, activity and substance criteria. For 2026 calendar-year information, the 2025 to 2027 notice sets June 1, 2027 as the submission deadline.
The National Pollutant Release Inventory uses different tests for different substances and facilities. A site below 20,000 employee-hours can still have reporting duties. Start with the notice, not a previous facility record or last year's checklist. ECCC's reporting guide explains the requirements.
But the notice prevails if the guide and the notice differ.
Who must report to the NPRI?
Check the facility type and activities before calculating substance quantities. The ordinary employee criterion is 20,000 hours during the calendar year, not a strict ten-person headcount. The calculation includes part-time and term staff, students, owners' on-site work and operational contractors. Paid overtime, vacation and sick leave also count under the guide's employee calculation.
Several activities remove the ordinary employee-hours requirement. Under Schedule 3 of the notice, these include:
- Non-hazardous solid-waste or biomedical/hospital-waste incineration at 26 tonnes per year or more.
- Hazardous-waste incineration and sewage-sludge incineration.
- Wood preservation and terminal operations.
- Wastewater systems discharging to surface waters at an average of at least 10,000 m³ per day.
- Pits and quarries producing at least 500,000 tonnes per year.
The applicable substance criteria still need assessment. A separate rule covers facilities subject to federal chromium electroplating, chromium anodizing and reverse etching regulations. They must report hexavalent chromium and its compounds regardless of the ordinary employee, 50 kg and 0.1% criteria. Part 4 air-emission rules can also apply below 20,000 hours. See Schedule 3.
Facility type changes which Parts need review. The guide directs contiguous facilities and offshore installations to consider Parts 1 to 5. Portable facilities consider Parts 2 to 5, while pipeline installations consider Parts 4 and 5.
Responsibility also depends on ownership timing. The owner or operator on December 31 reports for the whole calendar year. If operations cease, the last owner or operator reports for the operating portion of that year, under Schedule 3 section 5.
NPRI substance list and reporting thresholds
Use Schedule 1 of the 2025 to 2027 notice for the legal NPRI substance list. Schedule 3 sets the reporting tests. Schedule 4 specifies the information to submit.
MPO means manufactured, processed or otherwise used. It does not mean released. A Part 1 substance can require reporting even when releases, disposals and off-site recycling are zero. The table below summarizes Schedule 3. It cannot replace the full applicability assessment. Concentrations are by weight, and tonnes are metric.
| List section | Threshold basis | Conditions to check |
|---|---|---|
| Part 1A | 10 tonnes MPO, generally at 1% or more | Employee/activity tests apply. By-products and tailings can count regardless of concentration. |
| Part 1B | Substance-specific MPO and concentration thresholds | Examples: mercury and compounds, 5 kg with no concentration threshold; cadmium and compounds, 5 kg at 0.1%; lead and compounds, 50 kg at 0.1%; ethylene oxide, 1 kg at 0.1%. Check Table 1 and applicable facility rules. |
| Part 1C | 1 kg MPO of each individually listed PFAS, generally at 0.1% or more | Employee/activity tests apply. Do not combine all PFAS for the 1 kg test. |
| Part 2 | 50 kg of combined listed PAHs released, disposed of or transferred off-site for recycling | That 50 kg must result from incidental manufacture and/or tailings. Employee/activity criteria ordinarily apply. Creosote wood preservation has a separate any-quantity rule for resulting PAHs. |
| Part 3 | Specified activities rather than a general mass or concentration threshold | Includes relevant incineration and pentachlorophenol wood preservation, plus listed industrial activities with the employee criterion. |
| Part 4 | Annual releases to air | Check the substance thresholds below and special small-site, combustion and oil-and-gas rules. |
| Part 5 | At least 1 tonne of an individual listed VOC released to air | Check the benzene and combustion provisions. Section 15 has no general 10-tonne total-VOC prerequisite. |
Part 4 air-release thresholds
Schedule 3 Table 2 sets annual air-release thresholds of:
- 20 tonnes each for carbon monoxide, nitrogen oxides, sulphur dioxide and total particulate matter.
- 10 tonnes for total volatile organic compounds, or VOCs.
- 0.5 tonne for PM10.
- 0.3 tonne for PM2.5.
For specified facilities below 20,000 hours, and for pipeline installations, stationary fuel-combustion provisions affect the threshold calculation. Sections 14 and 17 can exempt air releases that come only from stationary external combustion equipment. Two conditions apply. Cumulative nameplate capacity must be below 10 million Btu/hour. The only fuel may be commercial grade natural gas, liquefied petroleum gas, Number 1 or 2 fuel oil, or a combination of those fuels. Section 14 is written as an exception to subsection 11(1). Section 17 is written as an exception to subsection 15(1). Do not assume either exemption also switches off subsections 11(2) and 11(3). Read those sections before you exclude these releases.
Small oil-and-gas sites need a separate check. A NAICS 211110 facility, other than a compressor station, with fewer than 20,000 employee-hours must report all Part 4 substances if one Part 4 substance meets its air-release threshold. A light or medium crude-oil battery under 20,000 hours must report total VOCs when oil throughput is at least 1,900 m³/year. Section 15(2) also requires benzene reporting when either special criterion applies. See sections 11 and 15.
Update PFAS and ethylene oxide assessments
The 2025 to 2027 requirements introduce 163 individually listed PFAS in Part 1C. Ethylene oxide moves to Part 1B at 1 kg and 0.1%, with special education and training provisions. These changes can affect an older applicability checklist. Use ECCC's changes page and the current notice.
For PFAS in waste rock, seek clarification from ECCC before deciding how to count the material toward the threshold. The guide and Schedule 3 subsection 6(3) do not describe the same substance groups for this calculation.
NPRI reporting deadlines and record retention
Keep the data year separate from the filing year. The notice sets these deadlines:
| Calendar year covered | Submission deadline |
|---|---|
| 2025 | June 1, 2026 |
| 2026 | June 1, 2027 |
| 2027 | June 1, 2028 |
Check ECCC's official deadlines page when preparing the return. Don't assume a facility-specific extension.
If the facility reported a substance in the preceding year but meets none of the current reporting criteria, notify ECCC by the relevant deadline. Include the reason. The guide calls this a Does Not Meet Criteria, or DNMC, report. Simply stopping filing can miss this duty.
Keep underlying information, calculations and measurements for three years from the applicable submission deadline. The notice requires storage at the facility or the owner/operator's principal place of business in Canada. The retention period does not automatically start on the actual filing date.
How to submit an NPRI report through SWIM
Use ECCC's NPRI reporting page to open Single Window Information Manager (SWIM). SWIM is the online reporting route. Schedule 4 section 6 also permits a report by mail. For online reporting:
- Sign in through GCKey or Sign-In Partner. Check your profile, organization and access permissions using the Single Window guidance.
- Select the NPRI program and the correct facility and reporting year. Start a blank report or use an existing submission to prepopulate it, as described in the NPRI tutorials.
- Refresh facility details and complete the general reporting questions. Enter and check current-year quantities. Prepopulated data still needs review. The tutorials warn that some content may be out of date, so screen labels may differ.
- Submit the report with the required electronic statement of certification. Creating an account or saving a report does not complete this step. The reporting guide also explains updates to current and previous submissions.
RegAffairs AI answers who needs to report to Canada's NPRI, with citations to the reporting notice. For the actual return, use Schedule 4 to check the required report contents.