Reminder on Mercury Reporting Requirements for 2025 Activities

Trade Update • Jan. 21, 2026

Key Points

• Manufacturers, importers, and certain exporters of mercury-containing products must report on 2025 activities.
• Reports are due March 31, 2026.
• Amendments to the Products Containing Mercury Regulations (PCMR) took effect June 19, 2025.
• Changes include additional prohibitions, updated exempted product categories, lower maximum mercury concentrations, export reporting requirements, and alignment with US EPA reporting cycles starting in 2027.
• Reports must be submitted through ECCC’s Single Window Information Manager (SWIM).

This is a reminder for businesses involved in the import, manufacture, or export of products containing mercury that they must report 2025 activities under the Products Containing Mercury Regulations. These regulations, in force since 2015, require manufacturers and importers of exempted mercury-containing products to submit reports to ECCC every three years. Past reporting deadlines were March 31 following the calendar years 2016, 2019, and 2022. Reporting will continue in 2025, 2027, 2030, and every third year thereafter.

The 2025 amendments, effective as of January 19, 2025, introduce additional prohibitions, changes to exempted product categories, lower allowable mercury concentrations, mandatory reporting on export activities, and alignment of reporting cycles with the US EPA starting in 2027

Regulatory Scope

The Products Containing Mercury Regulations prohibit the import and manufacture of mercury-containing products, except for defined exemptions listed in Section 3. Several exemptions apply to specific lamp types and uses. Accurate classification under the correct schedule item remains necessary for compliant reporting.

Key Changes Under the 2025 Amendments

The 2025 amendments to the Products Containing Mercury Regulations introduced key changes.

• Revised Exemptions: Updated list reflecting new prohibitions, modified product categories, and reduced maximum mercury levels for some exempted products.
  
• Canadian Business Address: Reports must now include the principal place of business in Canada.
• Export Reporting Requirement: Importers and manufacturers exporting mercury-containing products must include export activities in their submissions.
• Aligned Reporting Cycles: Starting in 2027, reporting schedules will match US EPA timelines:
  • 2025 data: due March 31, 2026
  • 2027 data: due March 31, 2028
  • Every third year thereafter

Reporting Schedule

• 2025 data: due March 31, 2026
• 2027 data: due March 31, 2028
• 2030 data: due March 31, 2031
• Every third year thereafter

The 2027 reporting cycle replaces 2028 to align Canadian reporting with US EPA timelines.

5 Steps for Easy Reporting

1. Read the Compliance Guide. Familiarize yourself with key reporting requirements, including prohibitions, exemptions, and amendments.
2. Gather Relevant Information. Use optional spreadsheet templates to track imports, manufacture, and exports. Prepare organizational details including principal Canadian business address and report submitter information. For 2025 reporting, use the updated spreadsheet reflecting 2024 amendments.
3. Register or Access SWIM. Create a secure account in the Single Window Information Manager. Instructions: SWIM guidance. Contact gigu-swim@ec.gc.ca for assistance.
4. Fill Out and Submit Your Report. Use the SWIM dashboard to create, save, edit, and submit reports. Refer to the Reporting Guide for detailed instructions. For support, contact produits-products@ec.gc.ca.
5. Keep Records. Maintain electronic copies of all records for at least five years, including non-reporting years. ECCC may request additional information to verify compliance.

How GHY Can Help?

GHY specializes in helping businesses navigate and reduce the impacts of tariffs through strategic solutions tailored to their needs. Our experts can audit your supply chain to identify inefficiencies, uncover cost-saving opportunities, and ensure compliance with evolving trade regulations. We also employ tariff engineering techniques to optimize product classification and sourcing strategies, minimizing duty exposure and maximizing profitability.

By partnering with GHY, your business gains access to the tools and expertise needed to streamline operations and stay competitive in a challenging trade environment.

Contact Us Today! Booking a Meeting, email consult@ghy.com, or call +1 (800) 667-0771.