Canada Publishes GHG Reporting Requirements for 2022-2023

By Fatemeh Bamdad, senior regulatory specialist, Supply Chain team, UL Solutions 

On Jan. 28, 2023, Environment and Climate Change Canada (ECCC) published a notice in part I of the Canada Gazette on reporting requirements for Greenhouse Gases (GHGs) for the 2022 and 2023 calendar years. 

The notice mandates the facilities that meet the reporting criteria set out in Schedule 3 of the notice, report their annual GHG emission information, as specified in Schedules 4 to 18 of the notice, to the Minister of Environment. The report shall be submitted no later than June 1, 2023 and June 3, 2024 for the calendar years of 2022 and 2023, respectively. 

As specified in Schedule 3, any facilities that emit 10,000 tons or more of Carbon dioxide equivalent (CO2 eq.) or more of the GHGs listed in Schedule 1 of the notice, are subject to the reporting requirements set out in this notice. This includes, but is not limited to, facilities involved in lime, cement, aluminum, iron and steel manufacturing, electricity and heat generation, and petroleum refining. It also includes facilities that are "engaged in CO2 capture, CO2 transport, CO2 injection or CO2 storage in the 2022 and 2023 calendar years or both."

The GHG reporting notice is part of the Greenhouse Gas Reporting Program (GHGRP), established in 2004, to collect and publish annual GHG emission information from a wide range of facilities. Since then, a reporting notice covering one or two calendar years, has been published in the Canada Gazette to outline the eligible facilities and the required information.

Since 2016, the Canadian Government has expanded the GHGRP in a two-phase plan in which the reporting threshold was decreased (in 2017) and more industry sectors were added to the list of facilities subject to expanded reporting requirements (in 2018).

The recent notice covers two calendar years (2022 and 2023) and maintains the requirements of the two initial phases, while adding one industry sector to the list presented in Schedule 3 (North American Industry Classification System (NAICS) Code 331490- Non-ferrous metal (except copper and aluminum) rolling, drawing, extruding and alloying).

Schedule 1 of the notice identifies the GHGs subject to the reporting criteria and their Global Warming Potential (GWP). Schedule 2 defines applicable terms and Schedule 3 provides reporting criteria and the instructions for how to determine total emissions in CO2 eq. using the total mass of each GHG and its respective GWP.

General administrative and Industry-specific reporting requirements are fully described in Schedules 4 to 18 of the notice. Required information includes, but is not limited to:

• Total quantity of direct emissions of Carbon dioxide, Methane, and Nitrous oxide reported by source category;
• Total quantity of Methane and Nitrous oxide emissions from certain biomass combustion facilities;;
• Total quantity of CO2 emissions from biomass combustion; and
• Total quantity of Sulphur hexafluoride, Hydrofluorocarbon and Perfluorocarbon emissions per industrial process/industrial product use.

*Note that according to the GHGRP, facilities subject to expanded reporting requirements are not allowed to submit provincial reports. 

Industry sectors and interested stakeholders are strongly encouraged to refer to the full text of the notice for complete details. Additional information about the GHGRP can be found on the Government of Canada’s Greenhouse Gas Emissions: Inventories and Reporting website.

Recommended action: Operators of the reporting facilities must submit the required information before the assigned deadlines. Offences of failing to comply or providing false or misleading information will result in penalties.

Reference

Notice with respect to reporting of greenhouse gases (GHGs) for 2022 and 2023. Canada Gazette, Part I- Supplement, Vol. 157, No. 4, January 28, 2023.