Canada NPRI Reporting Requirements
Who needs to report to Canada's NPRI?
You have to report to the NPRI if you own or operate a facility in Canada that meets at least one substance-specific reporting threshold in the current NPRI notice. That notice is the Notice with respect to the substances in the National Pollutant Release Inventory for 2025, 2026 and 2027, issued under CEPA 1999 subsection 46(1) and published in Canada Gazette Part I, Vol. 159, No. 10 on 8 March 2025 [1]. The notice says that such a person, if they have or may reasonably be expected to have access to the required information, "shall provide the Minister of the Environment with this information" (Canada Gazette).
Approach: I searched the CEPA Environmental Registry for the NPRI notice series and read the full notice in the Canada Gazette. The registry lists no amending notice for 2025-2027.
Who is covered (Schedule 3, s. 1)
In a given calendar year, the facility must meet a Part 1-5 substance threshold and at least one of these (s. 1(1)):
- (a) A listed activity takes place, however many hours employees work:
- non-hazardous solid waste incineration of 26 tonnes or more of waste
- biomedical or hospital waste incineration of 26 tonnes or more of waste
- hazardous waste incineration
- sewage sludge incineration
- wood preservation
- terminal operations
- wastewater discharge to surface waters averaging 10 000 m³ or more per day
- production of 500 000 tonnes or more at pits or quarries
- (b) Employees work 20 000 hours or more in total. "Employee" includes an owner who works on site and contractors doing work related to the facility's operations.
- (c) The person is subject to the Chromium Electroplating, Chromium Anodizing and Reverse Etching Regulations (SOR/2009-162).
- (d) Employees work less than 20 000 hours, but the facility meets the Part 4 criteria (criteria air contaminants).
- (e) The facility is a pipeline installation.
"Facility" means a contiguous facility, a portable facility (PCB destruction equipment, asphalt plants, concrete batching plants), a pipeline installation or an offshore installation (Schedule 2).
Out of scope (s. 1(2)): a facility whose only activities in the year are:
- oil or gas exploration or drilling of oil or gas wells,
- wastewater discharge averaging less than 10 000 m³ per day, or
- production of fewer than 500 000 tonnes at pits or quarries.
Substance thresholds
| Part | Trigger |
|---|---|
| 1, Group A | Manufactured, processed or otherwise used at 10 t or more, at a concentration of 1% or more (s. 6, Table 1) |
| 1, Group B | Thresholds set per substance, for example mercury 5 kg; cadmium 5 kg; lead, arsenic and hexavalent chromium 50 kg; ethylene oxide 1 kg; cyanide group 1 000 kg (Table 1) |
| 1, Group C (PFAS) | 1 kg, at a concentration of 0.1% or more (Table 1) |
| 2 (PAHs) | 50 kg or more in total released, disposed of or sent off site for recycling, from incidental manufacture or tailings; also any amount from creosote wood preservation (ss. 8-9) |
| 3 (dioxins/furans, HCB) | Specific activities only, such as incineration, pentachlorophenol wood preservation, or (with 20 000 hours or more) smelting, cement, EAF steel and 25 MW+ fossil-fuel boilers (s. 10) |
| 4 (CACs) | Air releases at or above: CO, NOx, SO₂ and total PM 20 t; VOCs 10 t; PM10 0.5 t; PM2.5 0.3 t (s. 11, Table 2) |
| 5 (speciated VOCs) | 1 tonne or more released to air (s. 15) |
Facility-type rules in Parts 4 and 5:
- Oil and gas extraction facilities (NAICS 211110, not compressor stations) under 20 000 hours report all Part 4 substances once any one of them crosses its threshold (s. 11(2)).
- Light or medium crude oil batteries with throughput of 1 900 m³/yr or more report total VOCs, even under 20 000 hours (s. 11(3)).
- Facilities under 20 000 hours count only air releases from stationary fuel combustion toward the Part 4 and 5 thresholds (ss. 13 and 16).
- No Part 4 or 5 report is required if the only air releases come from external combustion equipment with a combined nameplate capacity under 10 million BTU/h burning only natural gas, LPG or No. 1/2 fuel oil (ss. 14 and 17).
Quantities excluded from threshold calculations (s. 2(1), s. 3)
- Activities: education or training of students (except ethylene oxide, s. 6(4)); research or development; vehicle maintenance and repair (painting, stripping and rebuilding still count, s. 2(2)); fuel distribution, storage or retail outside terminal operations; wholesale or retail sale of articles or products containing the substance; retail sale of the substance; renewable natural resource management; dentistry.
- Materials: substances contained in articles, structural materials, janitorial supplies, intake water or air, overburden, and inert waste rock or tailings.
Who files, and when
- Who: whoever owns or operates the facility on 31 December files for the whole year. If the facility shut down, the last owner or operator files for the period it was operating (s. 5).
- Deadlines:
- 2025 data: by 1 June 2026
- 2026 data: by 1 June 2027
- 2027 data: by 1 June 2028
- Dropping out: a facility that reported for the previous year but no longer meets any criterion "shall notify the Minister" and give the reason by the same deadline.
- Records: keep records for three years (CEPA s. 46(8)).
If you give me the facility's activities, employee hours and substance quantities, I can work through whether it triggers reporting.