Together for a Sustainable Future

Canada Requires Companies to Provide PFAS Information

by Hedy He Jul 30, 2024

On July 27, 2024, the Government of Canada published a notice in the Canada Gazette, Part I, Volume 158, Number 30. 1 This notice requires relevant companies to provide information on per- and polyfluoroalkyl substances (PFAS) listed in Schedule 1 of the notice (hereinafter referred to as “Schedule 1”) before January 29, 2025. The information shall be submitted to the Minister of the Environment using the online reporting system Environment and Climate Change Canada’s Single Window.

The purpose of this information gathering is to assess whether these PFAS are toxic or have the potential to become toxic. Additionally, the government aims to evaluate the necessary control measures for the risks posed by these substances.

Person Required to Provide Information

Information Required

During 2023, any person who:

  • Manufactured more than 1,000 g of any substance in Schedule 1

  • Imported more than 10 g of a substance in Part 1 of Schedule 1, or more than 100 kg of a substance in Part 2 or 3 of Schedule 1, either alone or above 1 ppm in a mixture, product, or manufactured item. Products include those in contact with mucous membranes; those may be inhaled, or come into dermal or oral contact with an individual; food, beverage containers; food packaging materials; food processing equipment, etc.

  • Used more than 10 g of any substance in Schedule 1, either alone or above 1 ppm in a mixture or product, to manufacture a mixture, product, or item

For substance listed in Part 1 or Part 3 of Schedule 1

1. If a person owns multiple facilities, they should submit a single consolidated response that includes information from all facilities.

 

2. The person must provide the following   information:

  • The person’s name, address, business number, and contact information of an authorized representative

  • A declaration that the information is accurate and complete

 

3. For each facility, the person must provide:

  • Name and address of the facility

  • Whether there are known releases of any listed substance to air, water or land

  • Description of any policies or procedures to manage, mitigate or minimize releases

 

4. For each substance, the person must   provide the following information for 2023:

  • Total quantities manufactured, imported, used, and exported

  • Application code and substance function codes set out in Schedule 2 and Schedule 3 of the notice

  • Description of goods containing the substance

  • Concentration of the substance in the goods

  • Whether the goods were exported, were for commercial or consumer use, or were intended for children 14 years of age or younger

For substance listed in Part 2 of   Schedule 1

In addition to the above information, the person must also provide technical data if available, such as:

  • Molecular weight distribution

  • Structural formula

  • Information on degradation, depolymerization and decomposition

  • Monomer details

  • Titles of any available data, studies or information related to the polymer substances that have not already been provided to the Government of Canada under the New Substances Notification Regulations (Chemicals and Polymers) or under section 70 of the Act

During 2023, any person who:

  • Imported more than 100 kg of any Schedule 1 substance above 1 ppm in a manufactured item other than those listed above

1. If a person owns multiple facilities, they should submit a single consolidated response that includes information from all facilities.

 

2. The person must provide the following information:

  • The person’s name, address, business number, and contact   information of an authorized representative

  • A declaration that the information is accurate and complete

 

3. For each substance, the person must provide the following information for 2023:

  • Description and name of each manufactured item containing the substance

This notice applies to successors or assigns of the affected persons. It does not apply to substances only in transit through Canada, for personal use, for lab analysis/research, hazardous waste/recyclables, registered as pest control products, fertilizers, or feeds, or mixed with registered seeds. Additionally, the notice does not apply to micro-businesses.

Hedy He
ChemLinked Regulatory Analyst
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