Reporting volumes distributed in 2018
Distributors must report the annual emissions attributable to the combustion or use of fuels distributed for consumption in Québec in accordance with the Regulation respecting mandatory reporting of certain emissions of contaminants into the atmosphere (RMRCECA), as amended in December 2017. The report must be filed no later than June 1, 2019, for volumes distributed during the 2018 calendar year (from January 1 to December 31).
All covered fuel distributors are also subject to the Regulation respecting a cap-and-trade system for greenhouse gas emission allowances (C&T Regulation). Their report must be verified by a third party and the verification report must be filed no later than June 1, 2019. If none of the distribution activities covered by the RMRCECA were carried out in 2017 and 2018, and the 2017 report was accompanied by a verification report, it is possible that the report may not need to be verified. To be sure, please contact the team in charge of the Québec Air Emissions Inventory (IQEA) by phone at 418 521-3833 or by email.
Distributors are required to report greenhouse gas emissions attributable to the combustion or use of fuels so long as the distributed amount is not less than 200 litres over four consecutive years.
Distributors must use the primary distribution point as the measuring point for fuels from outside Québec. Volumes kept in stock should not be reported if they were not actually distributed in the 2018 calendar year.
Distribution activities covered
Anyone who is the first to perform one of following activities in Québec with respect to 200 litres or more of fuel is subject to the regulation:
However, the following are not covered: fuel contained in a fuel tank installed as standard equipment for supplying the engine of a vehicle; fuel in a sealed container of one litre or less.
In cases where a distributor is able to demonstrate that amounts of fuel he distributed in Québec were ultimately consumed by a large emitter covered by the C&T Regulation, an attestation signed by the person who actually received the fuel from the distributor confirming the total amounts consumed during the year for each type of fuel is required. Fuel used for transport by a large emitter should not be taken into account.
In cases where a distributor is able to demonstrate that amounts of fuel he distributed in Québec were ultimately redistributed to a person outside Québec, an attestation signed by the person who actually received the fuel from the distributor confirming the total amounts received during the year for each type of fuel is required.
Only fuel for which the distributor must produce a report should be taken into account.
The format of the attestations may differ from the suggested model. However, the required data must be reported.