Fuel Distributors

Reporting volumes distributed in 2023

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 2022. The report must be filed no later than June 1, 2024, for volumes distributed during the 2023 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, 2024. If none of the distribution activities covered by the RMRCECA were carried out in 2022 and 2023, and the 2022 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 2023 calendar year.

Fuels covered

The list of covered fuels by the RMRCECA and the emission factors that must be used are available in the following table:

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:

• Any form of trade or sale by a person or municipality, for consumption in Québec, of fuels that are refined, manufactured, blended, prepared or distilled in Québec by that same person or municipality;
• The sale or trade in Québec, for the purposes of consumption, trade or sale in Québec, of fuels from outside Québec, other than natural gas distributed by a natural gas distributor within the meaning of section 2 of the Act Respecting the Régie de l'Énergie (chapter R-6.01);
• The importation to Québec for the purposes of consumption, trade or sale in Québec, of fuels other than natural gas distributed by a natural gas distributor within the meaning of section 2 of the Act Respecting the Régie de l'Énergie (R-6.01);
• The distribution of natural gas for consumption in Québec by a natural gas distributor within the meaning of section 2 of the Act Respecting the Régie de l'Énergie.

A sale is considered made in Québec when the fuels brought into Québec are owned by a seller from outside Québec

The importation is considered made in Québec:

• Where the fuels come from outside Canada, when they are owned by a buyer in Québec who imports within the meaning of the Customs Act at the time they are brought into Québec.
• Where the fuels come from another province or a territory of Canada, when they are owned by a buyer in Québec at the time they are brought into Québec.

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.

Agreement between two fuel distributors

When the fuel comes from outside Québec, the seller and buyer can enter into an agreement in which they identify which of them is considered a distributor under the RMRCECA. In this case, the person thus designated must comply with all the requirements of the regulation. If the designated person fails to fulfill his or her obligations, the distributor who should have declared the emissions under the RMRCECA if no agreement had been entered into is required to remedy the situation as soon as possible.

When an agreement is entered into, the following information must be submitted by email to the Ministère:

• the name and contact information of each of the parties;
• the date on which the agreement was entered into;
• the type and total annual quantity of fuel covered by the agreement.

Reporting form

Please use the Québec Air Emissions Inventory (IQEA) online service to file your report. To assist you, a step-by-step procedure (PDF, 1 MB) has been designed specifically for fuel distributors.

Attestation forms

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.

• Attestation form – Large emitters (French, Word, 633 KB)

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.

• Attestation Form - Outside Québec (French, Word, 631 KB)

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.