Canada Requires Reporting on 312 PFAS for 2023 Imported Products
Targeted audience |
Canada domestic manufacturers, Canada importers and upstream suppliers |
Products concerned |
Consumer products |
Key industries concerned with this insight |
Children’s product, Food contact articles, Furniture |
Application date |
January 29, 2025 |
Main content or requirements |
Canada requires Canadian businesses to provide information concerning PFAS manufactured, imported or used as a standalone substance, in mixtures or in articles in the 2023 calendar year. |
Reference |
https://canadagazette.gc.ca/rp-pr/p1/2024/2024-07-27/html/sup-eng.html |
On July 27, 2024, Canada's Minister of the Environment issued a Canada Gazette notice mandating a survey to gather data on the manufacture, import, and use of 312 specific per- and polyfluoroalkyl substances (PFAS). The survey aims to collect information on these substances whether in isolation, mixtures, products, or manufactured items within Canadian commerce for the calendar year 2023. The deadline for responding to the notice is January 29, 2025.
The following situations are required to implement the reporting requirements for the 312 PFAS listed in Schedule 1:
- Manufactured any of the 312 listed PFAS in a quantity above 1000g
- Imported more than 10g of Part 1 PFAS(273 PFAS) or more than 100kg of Part 2 PFAS(26 PFAS) or Part 3 PFAS(13 PFAS), whether the substance was alone or present above 1ppm in a mixture, product or in one of 12 specified categories of reportable manufactured items
- Imported more than 100kg of any of the 312 listed PFAS at a concentration equal or above 1ppm in a manufactured item outside the 12 specified categories
- Used more than 10g of any of the 312 listed PFAS – either alone or in a concentration above 1ppm in the manufacture of a mixture, product or manufactured item
12 specified categories of reportable manufactured items include items:
- Intended to be used by or for children under the age of 14 years
- Intended to come into contact with the mucosa of an individual
- Used as intended such that the substance may be inhaled, or come into dermal or oral contact with an individual
- Cookware or a cooking or serving utensil that is intended to come into direct contact with heated food or beverage
- Food packaging material, including single serve/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
- Reusable food or beverage container
- Food processing equipment, including conveyor belts, trays, vats, nozzles, moulds, and cutters that come into contact with food or beverage prior to packaging and distribution
- Clothing or footwear, including life jackets, personal flotation devices, and other safety apparel
- Bedding, sleeping bags, or towels
- 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 fibre, yarn, or fabric
- Carpet, vinyl or laminate flooring, or foam underlay for flooring, intended to be used by an individual
- Such that the substance is intended to be released from the manufactured item
The required information includes:
- Identification information (company / organization and person reporting)
- Facility information
- Quantity of the substance manufactured, imported, used in the manufacture of a good and exported
- Information on goods
The notice does not apply to a substance, whether alone, in a mixture, in a product or in a manufactured item that:
- is only in transit through Canada;
- is for personal use;
- is intended for use in a laboratory for analysis, in scientific research or as a laboratory standard;
- is, or is contained in, a hazardous waste or hazardous recyclable material within the meaning of the Cross-border Movement of Hazardous Waste and Hazardous Recyclable Material Regulations and was exported or imported pursuant to a permit issued under these Regulations;
- is, or is contained in, a pest control product registered under the Pest Control Products Act;
- is, or is contained in a fertilizer or supplement registered under the Fertilizers Act;
- is, or is contained in, a feed registered under the Feeds Act; or
- is mixed with, or attached to, a seed registered under the Seeds Act.
The notice also does not apply to micro-business with fewer than five employees or less than $30,000 in annual gross revenue.
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