As we reported in our July 25, 2024, blog, Environment and Climate Change Canada (ECCC) issued the “Updated draft state of per- and polyfluoroalkyl substances (PFAS) report.”
In March 2025, ECCC issued a notice: “Government of Canada publishes State of Per- and Polyfluoroalkyl Substances (PFAS) Report and proposed Risk Management Approach.” The notice outlines the proposed approach to address PFAS.
PFAS Background
PFAS are a class of chemicals used worldwide for a variety of applications since the 1940s. Thousands of PFAS have been manufactured over the decades. They are stable compounds (carbon-fluorine bond) that are persistent in the environment, and because they do not readily degrade, they are often called “forever chemicals.”
Because of their chemical makeup, they are effective for a wide variety of uses. They were widely used in firefighting foams and fume suppressants in plating. However, they have also been used in several consumer products, including water/stain repellents (e.g., carpet, furniture, etc.), cosmetics, dental floss, and much more. PFAS are also critical in certain Department of Defence applications as well as for “green energy.” Their wide application is one of the reasons they are widely present in the environment and human and animal blood serum.
There is evidence that some of these PFAS compounds may pose a human health risk in low concentrations (parts per trillion level). Some of the health concerns include certain cancers, developmental delays, interference with natural hormones, and more.
In response to the potential risk associated with PFAS, governments around the world are formulating plans to reduce exposure to these compounds. Earlier this year (January 29, 2025), companies across Canada were required to comply with a mandatory PFAS reporting requirement.
In March 2025, ECCC issued a notice: “Government of Canada publishes State of Per- and Polyfluoroalkyl Substances (PFAS) Report and proposed Risk Management Approach.”
Risk Management Approach for PFAS
The government of Canada has issued several reports regarding PFAS dating back to at least 2018. With the release of this risk management approach, the government is establishing further PFAS prohibitions.
Below is the summary of the proposed risk management approach published in March as provided by ECCC.
Phase 1: prohibition of the use of PFAS, excluding fluoropolymers, not currently regulated in firefighting foams, due to high potential for environmental and human exposure.
Phase 2: prohibition of the uses of PFAS, excluding fluoropolymers, not needed for the protection of health, safety, or the environment, which includes consumer applications. Prioritization of uses for prohibition is based on, and will take into account, costs and benefits, availability of suitable alternatives, and other socio-economic considerations. Proposed uses to be regulated in Phase 2 include:
- cosmetics
- natural health products and non-prescription drugs
- food packaging materials, food additives, non-industrial food contact products such as paper plates, bowls, and cups
- paint and coating, adhesive and sealant, and other building materials available to consumers
- consumer mixtures such as cleaning products, waxes, and polishes
- textile uses (including in personal protective equipment such as firefighting turnout gear); and
- ski waxes
Phase 3: prohibition of the uses of PFAS, excluding fluoropolymers, requiring further evaluation of the role of PFAS for which currently there may not be feasible alternatives and taking into consideration socio-economic factors, including:
- fluorinated gas applications
- prescription drugs (human and veterinary)
- medical devices
- industrial food contact materials
- industrial sectors such as mining and petroleum; and
- transport and military applications
At each phase of risk management, exemptions will be considered when necessary, with attention to feasible alternatives and socio-economic factors.
To inform risk management decision-making, information on the following topics should be provided (on or before May 7, 2025), to the contact details identified in section 8 of this document:
- availability of alternatives to PFAS, or lack thereof, in products and applications in which they are currently used
- estimated timeframe to transition to alternatives to PFAS, including any challenges
- socio-economic impacts of replacing PFAS, including costs and feasibility of elimination or replacement; and
- quantities, and concentrations of PFAS (including Chemical Abstracts Service Registry Numbers, units of measurement, and applications) in products manufactured in, imported into, and sold in Canada (if not already provided through the section 71 notice)
Regarding the timing (see Section 8.2) of actions by ECCC, Table 3 in the document provides the following:
Phase 1: Consultation: Summer/Fall 2025 Proposed Regulation: Spring 2027.
Phase 2: Consultation to follow the publication of proposed Phase 1 Regulations: 2027.
Phase 3: Consultation to follow Phase 2 risk management: To be determined.
Industry and other stakeholders can submit comments (see Section 8) before May 7, 2025.
PFAS Expertise
Dragun Corporation has been actively involved (in technical and regulatory developments) for several years, including the Annual PFAS Experts Symposium (invitation only). We have worked on several projects, from consultation and remediation to litigation support.
Dragun Corporation developed a “PFAS Resource” page that includes a variety of resources specific to PFAS. This page includes information specific to the regulation of PFAS in Canada.
If you have questions about PFAS or need assistance with an issue related to PFAS, please contact our office or contact Christopher Paré, P.Geo., directly at 519-948-7300, Ext. 114.
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.
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