A Guide to Canada’s New Mandatory PFAS Reporting

On July 27th, Canada’s Minister of the Environment issued a notice via the Canada Gazette announcing a mandatory reporting rule to collect information on 312 specific PFAS that were manufactured or imported in the 2023 calendar year.

The purpose of this exercise, similar to the EPA’s PFAS reporting rule, is to use the information to guide future regulations of PFAS. While yet another PFAS regulation may not be surprising within a constantly changing worldwide regulatory landscape, what may come as a shock to companies is the due date: businesses only have 6 months to collect this data, with the reporting window closing on January 29, 2025. Information must be reported via the online reporting system Environment and Climate Change Canada’s Single Window.

Businesses only have 6 months to collect this data, with the reporting window closing on January 29, 2025.

Who Needs to Adhere to Canada’s New PFAS Reporting Requirements?

The notice establishes guidelines for any person who, during 2023, manufactured or imported PFAS alone, in a mixture, in a product or other manufactured item. The specific criteria for in-scope businesses are listed below.

• Manufactured a total quantity greater than 1,000 grams (g) of a PFAS listed in Schedule 1;
• Imported a total quantity greater than ten g of a PFAS listed in Part 1 of Schedule 1, or a total quantity greater than 100 kilograms (kg) of a PFAS listed in Part 2 or Part 3 of Schedule 1, whether the PFAS was alone, or at a concentration equal to or above one part per million (ppm) in a mixture or in a product, or at a concentration equal to or above one ppm in certain manufactured items;
• Imported a total quantity greater than 100 kg of any PFAS listed in Schedule 1 at a concentration equal to or above one ppm in a manufactured item not listed; or
• Used a total quantity greater than ten g of a PFAS listed in Schedule 1, whether the PFAS was alone, or at a concentration equal to or above one ppm in a mixture or in a product, in the manufacture of a mixture, a product, or a manufactured item.

Smaller concentrations apply to a manufactured item:

• That is intended to be used by or for children under the age of 14 years;
• That is intended to come into contact with the mucosa of an individual;
• That is used as intended in a manner such that the substance may be inhaled or come into dermal or oral contact with an individual;
• That is cookware, or a cooking or serving utensil that is intended to come into direct contact with heated food or beverage;
• That is food packaging material, including single-serve and/or disposable bowls, plates, cups, other serving ware, as well as food cans and lid liners, that are intended to or may come into direct contact with food or beverage;
• That is a reusable food or beverage container;
• That is food processing equipment, including conveyor belts, trays, vats, nozzles, molds, and cutters that come into contact with food or beverage prior to packaging and distribution;
• That is clothing or footwear, including life jackets, personal flotation devices, and other safety apparel;
• That is bedding, sleeping bags, or towels;
• That is furniture, mattresses, cushions, or pillows intended to be used by an individual, where the substance is contained in foam or leather or in a textile fiber, yarn, or fabric;
• That is carpet, vinyl, or laminate flooring, or foam underlay for flooring, intended to be used by an individual; and
• Such that the substance is intended to be released from the manufactured item.

It’s important to note that while this rule is mandatory for companies inside Canada, companies worldwide will be affected as Canadian businesses start reaching out to their supply chains for PFAS information. The guidance manual published alongside this notice includes a letter to help businesses survey their supply chain for the required information. 

It’s important to note that while this rule is mandatory for companies inside Canada, companies worldwide will be affected as Canadian businesses start reaching out to their supply chains for PFAS information

What PFAS Information Is the Canadian Government Requesting?

While a majority of the information required is related to the company itself and its business details—locations, contacts, etc.—you must also report the following for each substance:

• Description and common name of mixture, product or manufactured item containing the substance
• Quantity of substance manufactured, reported in grams or kilograms
• Quantity of substance imported alone, in a mixture, product or manufactured item
• Quantity of substance used
• Quantity of substance exported alone, in a mixture, product or manufactured item
• Application code(s) set out in schedule 2 that applies to the substance
• Function code(s) set out in Schedule 3 that applies to the substance
• Concentration or range of concentration of substance by weight in the goods
• Indication of commercial, consumer or childrens product use

While more detailed information is available in the notice, specific guidance may depend on whether you’re handling the chemical itself; if it’s contained within a mixture, product, or manufactured item; if the information is available to you; and in which schedule and part the PFAS in question falls under.

How Can Z2Data Help?

Z2Data’s PFAS solution covers all the requirements of Canada’s reporting rule, while also building the foundation for good PFAS standing and internal knowledge to assess risk on regulations to come. Z2Data provides full-service supplier campaigning with a team dedicated to supplier outreach. Our team validates your suppliers and your provided contact data, merges it with our known contact data, then campaigns each supplier. We maintain internal supplier profiles indicating the best approach to contacting a supplier and retrieving the required data from them. 

Our platform is your record of due diligence for any regulation. For each regulation, on each part, you can update the compliance statuses, provide the supporting documentation, update notes, and keep a completed history of any action on the part. You can then search for any document or part, create evidence packages when needed, and roll-up analysis on product levels to ensure the final product is compliant with any regulation, including Canada’s new PFAS reporting.