Mandatory Reporting of Certain Emissions of Contaminants into the Atmosphere

Regulation respecting mandatory reporting of certain emissions of contaminants into the atmosphere

Consult the essential information on the application of the Regulation respecting mandatory reporting of certain emissions of contaminants into the atmosphere.

Covered establishments

The Regulation applies to a calendar year and concerns, among others:

• any business operating an establishment that:
  • emits into the atmosphere a greenhouse gas or air contaminant at a level equal to or greater than the reporting threshold (French);
  • captures, stores, eliminates or re-uses greenhouse gas emissions;
  • transfers or receives greenhouse gas emissions from another operator;
• any business that distributes 200 litres or more of fuel;
• any business that purchases electricity produced outside Québec.

Contaminants covered

The contaminants covered (French) are:

• greenhouse gases (GHGs);
• the principal air contaminants, such as:
• sulphur dioxide (SO₂);
• nitrogen oxides (NO_x);
• particulate matter (PM, PM₁₀ and PM_2.5);
• volatile organic compounds (VOCs);
• carbon monoxide (CO);
• certain metals;
• polycyclic aromatic hydrocarbons (PAHs);
• dioxins and furans.

Information to be reported

Businesses must report, among others:

• the air emissions of covered contaminants that reach or exceed the reporting thresholds (French);
• the data needed to calculate emissions, such as:
  • the quantities of fuel used and their characteristics;
  • production data or raw materials data;
  • the emission factors used.

Confidential data is handled securely by the Ministère.

Reporting of air emissions and reporting thresholds

This section contains relevant information for businesses that are required to file an air emissions report.

Deadline

Your 2025 report must be submitted no later than June 1, 2026.

Emitters covered by the carbon market must submit their verification report, by email, within the same deadline.

GHG reporting thresholds

You must report your GHG emissions if at least one of the following conditions applies to your business:

• It emits 10,000 metric tons or more of GHGs in CO₂ equivalent during the calendar year;
• It distributes 200 litres or more of fuel;
• It captures, stores, eliminates or re-uses GHG emissions;
• It transfers GHG emissions to another operator;
• It receives GHG emissions from another operator.

You must continue to report your emissions as long as they remain at or above the reporting threshold for four consecutive years. Note that certain specific rules may apply to emitters covered by the carbon market.

Air contaminant reporting thresholds
You must report your air contaminant emissions (other than GHGs) if:

• you are required to report under Canada's National Pollutant Release Inventory (NPRI);
• your air emissions reach or exceed the reporting threshold (French) for one or more contaminants during the calendar year;
• you manufacture, prepare or otherwise use any of the following contaminants:
• ammonia;
• mercury and its compounds;
• lead and its compounds;
• cadmium and its compounds;
• benzene;
• formaldehyde;
• arsenic and its compounds;
• hexavalent chromium and its compounds.

For more details on the reporting thresholds, application terms and exemptions, consult the Guide for reporting to the National Pollutant Release Inventory.

Filing your report

To file your report, you must use the electronic service delivery for the Québec Air Emissions Inventory (IQEA e-service delivery). Go to the « Report your air emissions online » section to learn more.

What's new for the 2025 reporting period

Your 2025 report must comply with the amendments made to the Regulation in December 2024. The principal changes are as follows:

• New protocol QC.35 for the substitution of natural gas with biomethane:
  This protocol is intended to ensure that the volumes of biomethane:
• are biogenic in nature (they come either from biological sources or from organic matter);
• are injected into a natural gas network physically connected to the Québec network or are directly injected into it;
• are sold only once (no double counting).

If the biogenic origin cannot be demonstrated, the biomethane must be reported as natural gas.


• New deadline for submitting the verification report:
  If you send us a notice of correction for your report and a second verification is required, a new verification report must be submitted within 60 days following that notice.
  
  
• New threshold for a mandatory verifier visit:
  If changes have occurred in the emission sources and the quantity of GHGs related to those changes represents at least 25 % of the emissions covered by the carbon market reported the previous year, an on-site visit must be carried out by the verifier.

Going further

Previous amendments to the Regulation are available for the following years:

• 2023
• 2022 (French)
• 2021 (French)
• 2020 (French)

The data collected is used to produce:

• the annual inventory of greenhouse gas emissions (French);
• the annual inventory of the principal air contaminant emissions (French);
• the registry of greenhouse gas emissions (French);
• the registry of air contaminant emissions (French);
• the calculation of emissions coverage for emitters covered by the carbon market.

Reporting by fuel distributors

This section contains specific information for distributors who must file a report on the annual emissions attributable to the use of the fuel they distribute for consumption in Québec. To support you, a step-by-step procedure (PDF, 1 MB) has been designed specifically for you.

Covered distributors

Considering that a fuel can be sold more than once before its final use, you are responsible for filing a report if you are the first to distribute it in Québec and the quantity is equal to or greater than 200 litres (during a calendar year).

Items to consider for your report:

• Volumes to be reported: you must include only the volumes you have actually distributed, namely those that leave your inventory;
• Reference period: the report covers the period from January 1 to December 31 (calendar year);
• Obligation to report: you must continue to report your emissions as long as the distributed quantities are not below 200 litres for four consecutive years;
• Verification of the report: your report must be verified by a third party and must be accompanied by the verification report:
  • Exception: verification is not mandatory if you are filing your second, third or fourth report where the volumes are nil. If in doubt, do not hesitate to contact us;
• Exclusions: the Regulation does not apply to:
  • fuel used for air or marine navigation;
  • hydrocarbons used as a raw material by industries that transform hydrocarbon molecules through chemical and petrochemical processes;
  • sealed containers of one litre or less;
  • fuel contained in a tank installed as standard equipment for supplying a vehicle.

Covered fuels

The fuels covered by the mandatory report are as follows:

• Automotive gasolines;
• Diesels;
• Kerosene;
• Light oils (0, 1 and 2);
• Heavy oils (4, 5 and 6);
• Propane;
• Butane;
• Liquefied natural gas;
• Liquefied petroleum coke;
• Ethanol (100 %);
• Biodiesel (100 %);
• Natural gas;
• Compressed natural gas;
• Biomethane;
• Distillation gas (refinery);
• Coal coke;
• Petroleum coke;
• Coal.

The emission factors are used to calculate the GHG emissions attributable to the use of fuel. You must use those prescribed by the Regulation to calculate your emissions. Note that:

• when choosing an emission factor, it is important to consider both the type of fuel and how it is used. For example, the use of coloured diesel in stationary equipment corresponds, in common usage, to what is called light oil;
• each fuel making up a mixture must be reported separately.

Covered distribution activities

The covered distribution activities are as follows:

• Sale or trade of fuel produced in Québec:
  You are considered to carry out this activity if you sell or trade fuel that you have refined, manufactured, blended or distilled in Québec, for consumption in Québec.

• Sale or trade of fuel from outside Québec:
  This means that you sell or trade fuel imported from another province or another country, for consumption in Québec (except natural gas distributed by an authorized distributor).
  
  A sale is considered to have been made in Québec if the fuel brought into Québec is owned by a seller from outside Québec.

• Importation of fuel into Québec:
  You are deemed to carry out this activity if you import fuel to sell or trade in Québec (except natural gas distributed by an authorized distributor).

  An importation is considered to have been made in Québec:

• For fuel from outside Canada: when it is owned by a buyer in Québec who imports it within the meaning of the Customs Act at the time it is brought into Québec;
• For fuel from another province or a territory of Canada: when it is owned by a buyer in Québec at the time it is brought into Québec.

• Distribution of natural gas:
  This means that you distribute natural gas for consumption in Québec, in accordance with the Act respecting the Régie de l'énergie.

Filing your report

• To file your report, you must use the electronic service delivery for the Québec Air Emissions Inventory (IQEA e-service delivery). Go to the « Report your air emissions online » section to learn more.

What's new for the 2025 report

Improvements have been made to the reporting tool. Specifically, in the protocol used to report GHG emissions attributable to the distribution of fuel (annex QC-30), there are now three separate tables to facilitate the reporting of fuel quantities specifically related to:

• attestations received from emitters covered by the carbon market (Table 30.3);
• attestations received for quantities sold outside Québec (Table 30.5);
• agreements entered into with another business (Table 30.7).

An additional section addressing the distribution of biomethane has also been added to annex QC-30, following the regulatory amendments of December 2024.

Agreement between two fuel distributors

When the fuel comes from outside Québec, the seller and buyer can enter into an agreement to identify which of them will be considered the distributor under the Regulation. Note that such an agreement must be entered into only if one of the two entities is located outside Québec, and it must be considered in your report.

Attestation forms

An attestation is required to specify that the quantities of fuel distributed have been:

• consumed by an emitter covered by the carbon market:
• Attestation form – Large emitters (Word, 633 KB) (French);
• redistributed to a person outside Québec:
• Attestation Form – Outside Québec (Word, 631 KB) (French).

Note that the information contained in these attestation templates must be provided, but the format of the attestation may vary.

Report your air emissions online

The electronic service delivery for the Québec Air Emissions Inventory (IQEA e-service delivery) allows you to submit your report securely thanks to the clicSÉQUR-Entreprises (French) authentication service. To support you, a step-by-step procedure (French,PDF, 1.7 MB) has been designed for you.

Main steps to access online reporting

Step 1: Obtain your access with clicSÉQUR-Entreprises

• Above all, your business must be registered with clicSÉQUR-Entreprises.
• Obtain your access by contacting the electronic services manager (ESM) at your business. This step is detailed in the Registration process for electronic services managers (ESMs).

Step 2: Access the IQEA e-service delivery to report your air emissions

• Log in with the user ID provided by your ESM after clicking on the web button below:
  
• Begin entering your report on January 1.
• Submit your report no later than June 1.

Need help: For questions concerning registration with clicSÉQUR-Entreprises, contact the customer service (French) of clicSÉQUR‑Entreprises. For any other question, you can contact our team.

Note that:

• each transaction made using the clicSÉQUR user ID has the same legal value as if you had provided written and signed instructions;
• for optimal use, you must use one of the supported browsers (French).

Contact the team responsible for the report

For any question on the Regulation or on the reporting of air emissions, contact the team responsible for the report at the following:

Telephone: 418 521-3833, option 1 (toll-free: 1 800 561-1616, ext. 39126)
Email: declaration.atmosphere@environnement.gouv.qc.ca