NEW! QC: Understanding QC mandatory GHG emission reporting requirements

As fuel distributers, some CPA member companies may be required to report their greenhouse gas (GHG) emissions under the provincial Regulation respecting mandatory reporting of certain emissions of contaminants into the atmosphere (RRMRCECA).

Any business that has produced more than 200 litres of fuels between January 1 and December 31, 2018, and that is the first in Québec to perform one of the following fuel-related activities, is considered an emitter under the RRMRCECA:

• The sale or trading, by a person or municipality, of fuels that are refined, manufactured, mixed, prepared or distilled in Québec by the same person or municipality;
• The sale or trading of fuel in Québec that comes from outside Québec;
• Importing fuel into Québec;
• The distribution of natural gas in Québec.

Fuel contained in a fuel tank installed as standard equipment to supply a vehicle’s engine, or fuel in a 1-litre or smaller sealed container, is not targeted by this regulation.

With Ontario’s withdrawal from the carbon market, some of your suppliers may have modified their contracts. Special attention should therefore be paid to these contracts in order to establish whether or not your activities are subject to compliance with the RRMRCECA.

Companies that are required to report their emissions are also subject to the Regulation respecting a cap-and-trade system for greenhouse gas emission allowances. For this purpose and in accordance with section 6.6 of the RRMRCECA, this declaration must be verified by a third party.

Information required to produce GHG emissions reports can be found on Québec’s environment ministry website in a section specifically for fuel distributors: http://www.environnement.gouv.qc.ca/air/declar_contaminants/carburant-combustibles/declaration.htm (in French).

For more information on the cap-and-trade system, visit the Carbon Market website (in French).