On July 27, 2024, The Canada Gazette issued a “Notice with respect to certain per- and polyfluoroalkyl substances (PFAS).” The notice requires regulated companies who manufactured, imported, or used prescribed quantities of listed types of PFAS in Canada to report by January 29, 2025. Failure to meet the deadline can result in fines of up to $500,000 for the first offence and $1,000,000 for subsequent offences.
Mandatory PFAS Reporting: Who Has to Report?
In the Guidance Manual provided by Environment and Climate Change Canada and Health Canada, it states that the notice applies to any person who, during the 2023 calendar year, satisfied any of the following criteria:
- Manufactured a total quantity greater than 1000 g of a substance listed in Schedule 1
- Imported a total quantity greater than 10 g of a substance listed in Part 1 of Schedule 1, OR a total quantity greater than 100 kg of a substance listed in Part 2 or Part 3 of Schedule 1, whether the substance was alone, or at a concentration equal to or above 1 ppm in a mixture or in a product or at a concentration equal to or above 1 ppm in one of the categories of manufactured items in Table 1
- Imported a total quantity greater than 100 kg of any substance listed in Schedule 1 at a concentration equal to or above 1 ppm in a manufactured item NOT listed in the categories of manufactured items in Table 1
- Used a total quantity greater than 10 g of a substance listed in Schedule 1, whether the substance was alone, or at a concentration equal to or above 1 ppm in a mixture or in a product, in the manufacture of a mixture, a product or a manufactured item
What Is Reported
According to Section 11 of the Guidance, if you had activity with a reportable substance, you must consolidate information across the entire company and across all facilities for the 2023 calendar year and provide a single response to the notice. When responding to the notice, you must report the quantities of the reportable substance itself, and not the quantity of the mixture, product or manufactured item containing the substance. For each reportable substance, you must enter the total quantity for each activity during the 2023 calendar year. The total quantities entered into the Excel Reporting Format are:
- The total quantity manufactured of the substance itself (this includes both intentional and incidental production of the substance)
- The total quantity of the substance imported alone (i.e., not in a mixture, product or manufactured item)
- The total quantity of substance imported in a mixture or product (e.g., paint, shampoo, polishes)
- The total quantity of the substance imported in a manufactured item (e.g., couch, frying pan, calculator, textile)
- The total quantity of substance used in the manufacture of a good
- The total quantity exported alone, in a mixture or in a product (you are not required to report export quantities of substances in manufactured items)
Overview of mandatory PFAS reporting criteria and requirements (Source: Guidance Manual Environment and Climate Change Canada and Health Canada). The source for this diagram is found in the Guidance Manual here.
Requesting Extension
With the reporting deadline quickly approaching, some companies may want to request additional time. Requests for additional time to respond to the notice must be submitted in writing to substances@ec.gc.ca and must include:
- Organization name;
- Contact information;
- Substance identifier(s) involved;
- Reason for the request.
This is a brief overview of the PFAS reporting requirement, see the Guidance Manual for the details. The deadline for reporting is only months away. With the significant monetary penalties associated with missing this deadline, you may want to assess whether this is applicable to your company sooner than later.
If you need assistance with this PFAS Reporting or other environmental issues, contact Christopher Pare’, P.Geo. Q.P. at 519-948-7300, Ext. 114.
Dragun Corporation does not use artificial intelligence in drafting our blogs or any other material.
Alan Hahn drafted this blog. Alan has an undergraduate degree in Environmental Studies and completed a graduate program in Environmental Management. He has worked in environmental management for more than 45 years. He has written hundreds of blogs and articles. His published work includes HazMat Magazine, BizX Magazine, Michigan Lawyers Weekly, GreenStone Partners, Manure Manager Magazine, and Progressive Dairy.
Christopher Paré, P.Geo, reviewed this blog. Chris is a senior geoscientist and manager of Dragun’s Windsor, Ontario, office. Chris has more than 30 years of experience on projects ranging from environmental site assessments (Phase One/Two ESA), excess soils, remedial investigations, soil and groundwater remediation, Permits to Take Water, Records of Site Conditions, vapour intrusion, and site decommissioning. Chris is a frequent speaker, author, and expert witness. See Chris’ bio.
Follow Dragun Corporation on LinkedIn, X, or Facebook.
Sign up for our monthly environmental newsletters.
Principled Foundation | Thoughtful Advice | Smart Solutions
Established in 1988