On December 12, 2025, Environment and Climate Change Canada (ECCC) promulgated the Landfill Methane Regulations (LMR), SOR/2025-279 under the Canadian Environmental Protection Act, 1999 (CEPA). This new federal regulation is aimed at reducing methane emissions from municipal solid waste (MSW) landfills operated in Canada. The LMR establish a consistent national baseline that complements (and in some cases surpasses) provincial approaches and include monitoring, surface methane concentration performance limits, and annual reporting obligations for subject landfills.
Who is covered?
The Regulations apply to landfills that meet either of these conditions:
- The landfill disposed of any quantity of MSW after January 1, 2010, and has more than 450,000 tonnes of MSW-in-place, or
- The landfill disposed of more than 20,000 tonnes of MSW in 2025 or any subsequent calendar year, and has more than 200,000 tonnes of MSW-in-place.
The Regulations do not apply to landfills or distinct non-contiguous portions of a landfill that are under final cover and ceased to accept waste before January 1, 2010. The Regulations do not apply to landfills that received only specific waste types such as
- hazardous waste
- non-biodegradable wastes such as soil, rock, asphalt, concrete, brick, glass, ceramics, clay products, inert slag, asbestos-containing waste, and metals
- waste produced from forest products operations
- construction and demolition waste
Annual Methane Generation Assessment
Once a landfill has determined their applicability to LMR, the next step involves calculating annual methane generation quantities from calendar year 2025 and submitting the Methane Generation Assessment Report to ECCC. The first report is due on June 1, 2026 for calendar year 2025. This report is to be submitted using the ECCC Regulatory Services Platform (RSP).
ECCC has published a Landfill Methane Modelling Tool to facilitate this assessment. The modelling tool is built on a first-order decay approach aligned with IPCC methods, and it incorporates waste-material categories & quantities and parameters (DOC, DOCf, decay rate constant k) with options to determine decay rates based on precipitation (including leachate recirculation adjustment) or IPCC climate zone (wet/dry).
Open landfills that exceed 664 tonnes/year methane generation and closed landfills that exceed 1,000 tonnes/year methane generation have further compliance obligations under the LMR. However, landfills with 2025 methane emissions below these thresholds do not have any further compliance obligations. They are required to do annual calculations in the future years to determine if they continue to stay below these thresholds. Therefore, landfill operators should treat the methane modelling workflow as a repeatable annual compliance process, with data ownership and internal QA—rather than a one-off calculation.
Compliance Timelines
The compliance timeline (i.e., timeline by when methane control requirements come into effect) vary depending on the modelled methane generation and are as follows:
- January 1, 2028 – for landfills that have 1,000 tonnes or more methane generation and have existing landfill gas recovery systems
- January 1, 2029 – for landfills that have 1,000 tonnes or more methane generation and do not have existing systems
- January 1, 2035 – for landfills that have 664 tonnes or more but less than 1,000 tonnes methane generation
Methane Control
The LMR requires subject facilities to limit releases and demonstrate effective management of landfill gas. The three key emission control requirements in this regulation are:
- Eliminate venting of landfill gas and destroy or use all recovered methane
- Comply with landfill surface methane concentration limits through monitoring at prescribed frequency and conducting timely repairs when measured concentrations exceed the standards
- Conduct ongoing monitoring of equipment and associated components to identify and repair methane leaks
In practice, this regulation shifts the compliance question from “Do we have a landfill gas system?” to “Can we demonstrate, through measurements and records, that methane is being captured, routed, and controlled in a way that meets the LMR’s performance expectations and monitoring frequencies?”
The technical guidance document released by ECCC stipulates measuring both flow and methane concentration for landfill gas conveyed to destruction/utilization devices. This includes measuring methane concentration at least monthly and LFG flowrate at least every 15 minutes.
Ongoing Monitoring
Monthly well monitoring
Recovery wells must be monitored monthly for key indicators such as gauge pressure, oxygen concentration, gas composition, and flow conditions.
Equipment leak detection (LDAR-style)
The LMR require equipment leak detection surveys three times per year, with at least 60 days between surveys, using US EPA Method 21 (unless alternative methods are approved). A methane concentration of 500 ppmv or greater at an equipment component is considered a methane leak.
This is a meaningful operational expansion for many sites, because it is component-based and documentation-heavy. Effective compliance usually requires a defined equipment inventory, consistent survey routes, repair tracking, and verification practices integrated into the maintenance management system.
Surface methane limits & monitoring
The surface emissions monitoring (SEM) is intended to identify localized hotspots and penetrations where methane is escaping, so that corrective measures can be taken. Monitoring is generally required three times per year in seasonal windows (Jan–May; Jun–Aug; Sep–Dec), with at least 60 days between surveys, and applies in areas that have not received waste in the prior 12 months (with certain reduced-frequency options when conditions are met). The technical guidance document details two main measurement pathways: a ground-based survey method (with specific spacing and procedures), and an optional drone-based approach aligned with EPA OTM-51, with required ground follow-up in certain situations.
The regulations define exceedance for a surface methane concentration to be ≥ 500 ppmv, and for a zone-average surface methane concentration: ≥ 25 ppmv (averaged over a 4,500 m² zone).
Many landfills can operate recovery infrastructure and still fail surface performance if cover integrity, penetrations, condensate/leachate features, or well tuning are not managed tightly.
Ongoing Reporting & Recordkeeping
Once methane control requirements begin, an annual report is due June 1 each year, with reporting submitted through the online Regulatory Services Platform (RSP).
The regulation requires extensive recordkeeping across modelling inputs, monitoring event details, instrument specifications and calibrations, maps and zone definitions for SEM, coordinates and concentrations, and documentation of exceedances and follow-up actions.
For multi-site operators, the most cost-effective approach is to standardize early: one set of templates, one GIS convention for zones and transects, one controlled repository for calibration and field logs, and one repeatable internal QA step before anything is submitted or archived. This will help reduce the risk of preventable noncompliance, especially when fieldwork is performed by rotating staff or third-party contractors.
Conclusion
The LMR are performance-based and data-driven, meaning success depends on building a repeatable program that connects modelling, monitoring, corrective actions, and defensible reporting. Trinity can help you confirm applicability, complete methane generation assessments, design SEM/LDAR and wellfield monitoring programs, and prepare report-ready documentation so your team is positioned for smooth compliance. If you have any questions on this new regulation, please contact Sundar Sadashivam at Trinity’s Toronto office or call 416.391.2527.
