The passage of Bill C-68, culminating in Royal Assent in June 2019, marked a significant development in Canada’s ongoing Oceans Protection Plan, particularly in how it intersects with supply chain transparency for marine-based industries. For fisheries and offshore energy firms, the implications of this legislative shift are slowly but surely becoming clearer as the focus turns to practical implementation in 2020 and beyond. While the original ambitions of the Oceans Protection Plan centered on environmental conservation, emergency response readiness, and partnership with Indigenous communities, this latest expansion quietly but forcefully extends the government’s reach into the realm of marine logistics reporting.
What may not have been obvious at first glance is just how much the new provisions in Bill C-68 affect the day-to-day operations of companies dependent on maritime transport. The mandate for greater traceability—of both catch and cargo—has made the supply chain itself a matter of regulatory scrutiny. And this, of course, raises new challenges, particularly as companies attempt to balance operational efficiency with the expectations of transparency frameworks that are, frankly, still evolving in real time. The regulatory apparatus is there, but the interpretive guidance sometimes lags behind.
For companies navigating this space, one immediate action point is to engage more directly with the open data resources provided by the Department of Fisheries and Oceans (DFO). The DFO’s vessel movement data sets, accessible through its various portals, offer detailed records on ship positions, voyage histories, and port calls. This data, when combined thoughtfully with internal shipment records, creates an opportunity—perhaps even an obligation—to construct an auditable chain of custody for marine exports. For fisheries operators, this means demonstrating not just where a catch was landed but how it traveled from ocean to processing facility and, eventually, to export markets. Offshore energy firms, for their part, must show that crude shipments or LNG cargos are traceable from platform to terminal with minimal opacity.
That said, simply accessing data is not enough. The trickier part, as many firms are discovering, lies in integrating this external data with internal logistics records in a way that is both accurate and meaningful to regulators. There’s also the question of frequency: while some operators have gotten by with annual or biannual disclosures in the past, the new norms appear to favor more frequent updates, aligning with the quarterly reporting cadence encouraged by Bill C-68’s supporters.
To that end, fisheries and energy companies alike are beginning to experiment with templates for quarterly marine supply chain emissions disclosures. These reports typically aggregate data on vessel movements, fuel consumption, and emissions profiles, matched against volumes of cargo or catch transported. It’s not a simple exercise. The data must be cleaned, standardized, and, in many cases, interpreted with care—since vessel emissions can vary widely depending on routing, load factors, and weather conditions, among other variables. What’s more, the audience for these disclosures is not just the regulator; investors, trading partners, and increasingly vocal environmental stakeholders are watching closely.
Some firms have started publishing these disclosures as part of broader sustainability or CSR updates, while others are trialing standalone marine transparency reports. Either way, there’s a growing sense that these documents are as much about narrative as they are about numbers. Companies are learning to explain, not just report—to contextualize emissions figures, describe mitigation strategies, and outline future commitments in a way that feels genuine rather than formulaic. It’s a subtle but important shift, driven in part by the reality that raw data, without interpretation, risks being misunderstood or misused.
Another layer of complexity comes from reconciling the various data sources. DFO vessel data is invaluable, but it must be married with records from port authorities, customs agencies, and internal shipping logs to paint a complete picture. Inevitably, discrepancies arise. Ships may change routes due to weather or congestion, leading to variations in actual versus planned emissions profiles. Cargo transfers between vessels can introduce gaps in the traceability chain that are not easily resolved without manual checks or supplementary documentation. There is a learning curve here, and firms are finding that the cost of getting it right is not insignificant, both in terms of time and resources.
And then there’s the broader policy context to consider. Bill C-68 doesn’t exist in isolation; it interacts with other initiatives, both domestic and international, aimed at decarbonizing marine transport and improving supply chain integrity. For instance, companies exporting to markets like the EU increasingly find that their Canadian compliance efforts also serve to meet foreign due diligence or environmental reporting requirements, albeit with tweaks. But this overlap is not always perfect. At times, firms must reconcile conflicting reporting standards or thresholds, an exercise that can be frustrating but also instructive in revealing where future harmonization might be needed.
In this evolving regulatory landscape, the best-prepared firms are those that approach transparency as a continuous process rather than a compliance checkbox. The integration of DFO open data into internal reporting systems, the careful design of emissions disclosure templates, and the willingness to engage constructively with regulators and civil society all form part of what is likely to become standard operating practice. That said, no company has perfected this yet. The field is still adapting, the templates are still being refined, and the discussions—both internally and externally—are far from settled.