Table of Contents
- How are PFAS regulated in Canada?
- What was the 2024 PFAS Section 71 notice?
- The 2024 notice is not the same as ongoing PFAS reporting
- What is the Canadian NPRI PFAS requirement?
- Does NPRI reporting apply to every product manufacturer?
- Why product data still matters
- Supplier information and Canadian PFAS compliance
- What information did Canada request under the 2024 notice?
- PFAS reporting vs PFAS product restrictions
- What should product manufacturers do?
- 1. Identify Canadian products and facilities
- 2. Map PFAS-containing materials
- 3. Collect supplier information
- 4. Map PFAS to manufacturing activities
- 5. Maintain supporting evidence
- 6. Monitor regulatory changes
- Canada PFAS requirements and the global regulatory landscape
- Managing PFAS data across Canadian products
- What should manufacturers do now?
Canada's PFAS regulatory framework includes information-gathering requirements, pollution reporting obligations and developing risk-management measures that can affect manufacturers, importers and companies placing products on the Canadian market.
For product manufacturers, the important distinction is between PFAS information gathering under the Canadian Environmental Protection Act (CEPA) and ongoing reporting requirements such as the National Pollutant Release Inventory (NPRI).
The compliance question is therefore not simply whether a product contains PFAS.
It is:
Which Canadian requirement applies, what information is required, and how can the manufacturer connect PFAS information to its products, suppliers and facilities?
How are PFAS regulated in Canada?
Canada is assessing PFAS as a broad class of substances under CEPA.
The federal PFAS programme includes:
- Information gathering under CEPA Section 71
- Risk assessment and risk-management activities
- National Pollutant Release Inventory reporting
- Existing restrictions on specific PFAS and uses
- Further regulatory measures that may develop from the government's assessment
Health Canada and Environment and Climate Change Canada identify PFAS in a wide range of products and applications, including textiles, electronics, vehicles, cosmetics, food packaging and firefighting foams.
For product manufacturers, this makes PFAS data increasingly relevant across the supply chain.
What was the 2024 PFAS Section 71 notice?
Canada published a Notice with respect to certain PFAS under Section 71 of CEPA on July 27, 2024.
The notice covered 312 PFAS substances and collected information about their presence in Canadian commerce, including PFAS present alone, in mixtures, products or manufactured items.
The reporting deadline was January 29, 2025.
The information requested included:
- Company information
- Facility information
- Quantities manufactured
- Quantities imported
- Quantities used in manufacturing goods
- Quantities exported
- Information about goods containing the substances
Companies subject to the notice were required to report information they possessed or could reasonably be expected to have access to.
The 2024 notice is not the same as ongoing PFAS reporting
This distinction is important for anyone updating older PFAS content.
The 2024 Section 71 notice had a specific reporting period and deadline. It should not be presented as though companies are still responding to that same notice in 2026.
Instead, manufacturers should monitor the separate reporting and risk-management requirements that now apply.
What is the Canadian NPRI PFAS requirement?
Canada added 163 PFAS and PFAS salts and precursors to a new Part 1, Group C of the National Pollutant Release Inventory.
The requirements apply beginning with the 2025 reporting year.
Facilities that meet the applicable employee threshold and manufacture, process or otherwise use 1 kilogram or more of an individual listed PFAS at a concentration of at least 0.1% by weight may have to report releases, disposals and transfers for recycling. The thresholds apply to each listed PFAS individually.
The reporting deadlines are:
- 2025 reporting year: June 1, 2026
- 2026 reporting year: June 1, 2027
- 2027 reporting year: June 1, 2028
This is a different obligation from the 2024 Section 71 information-gathering notice.
Does NPRI reporting apply to every product manufacturer?
No.
NPRI reporting is facility-based and depends on the requirements in the applicable notice, including employee and substance thresholds.
A company should therefore determine whether its Canadian facilities meet the relevant NPRI criteria before assuming that the requirement applies.
However, product manufacturers should not ignore the requirement simply because the finished product is not itself being reported.
PFAS information may still need to be traced back through:
Product → component → material → PFAS → facility activity
This becomes particularly important where PFAS are used during manufacturing or processing.
Why product data still matters
Even where the reporting obligation is facility-based, product and supplier data can be necessary to establish where PFAS are used and in what quantities.
A manufacturer may have PFAS information distributed across:
- Supplier declarations
- Material specifications
- Bills of materials
- Component records
- Purchasing systems
- Manufacturing records
- Chemical inventories
- Laboratory results
Without connecting these datasets, the compliance team may struggle to determine which PFAS are present and where they enter the manufacturing process.
Supplier information and Canadian PFAS compliance
PFAS information may originate with a supplier rather than the final product manufacturer.
For example, a component supplier may know that a coating contains a listed PFAS, while the finished-product manufacturer only knows the component part number.
The manufacturer may therefore need to establish:
Supplier → Material → Component → BOM → Product → PFAS
Supplier information may include:
- Substance identity
- CAS number
- PFAS concentration
- Material or component affected
- Intended use
- Quantity
- Supporting declaration or test evidence
For the broader supplier-data workflow, see PFAS Supplier Chemical Transparency.
What information did Canada request under the 2024 notice?
The 2024 Section 71 notice demonstrates the level of product and supply-chain information that Canadian authorities may require.
The guidance requested information concerning substances in products and manufactured items in Canadian commerce, including quantities and information about goods.
This means companies should not treat PFAS identification as a simple substance-list exercise.
A useful internal data model connects:
PFAS → concentration → material → product → quantity → Canadian activity → evidence
That structure makes it easier to respond to regulatory information requests and assess future requirements.
PFAS reporting vs PFAS product restrictions
Reporting and product restrictions are different regulatory questions.
A reporting requirement asks whether information must be provided to the Canadian government.
A product restriction asks whether a substance or product can be manufactured, imported, sold or used under specified conditions.
A company should therefore avoid concluding that a product is “compliant in Canada” simply because no current PFAS reporting obligation applies.
The product may still need to be assessed against other applicable Canadian chemical requirements.
What should product manufacturers do?
A practical Canadian PFAS workflow can start with six steps.
1. Identify Canadian products and facilities
Determine which products are sold or imported into Canada and which facilities manufacture, process or use relevant PFAS.
2. Map PFAS-containing materials
Identify materials, components, coatings and treatments where PFAS may be present.
3. Collect supplier information
Close gaps where internal product records cannot establish PFAS identity, concentration or use.
4. Map PFAS to manufacturing activities
Determine whether listed PFAS are manufactured, processed or otherwise used at Canadian facilities and whether applicable NPRI thresholds are met.
5. Maintain supporting evidence
Retain supplier declarations, material information, test data, quantities and regulatory assessments.
6. Monitor regulatory changes
Canada's PFAS programme continues to evolve, so the assessment should be revisited when new information-gathering or risk-management measures are introduced.
Canada PFAS requirements and the global regulatory landscape
Canadian requirements should be managed as part of a broader PFAS compliance programme.
The same product may also need to be assessed under:
- US federal PFAS requirements
- US state PFAS requirements
- EU REACH
- EU PFAS restrictions
- Japan CSCL
- Other national chemical requirements
See Global PFAS Regulations: A Compliance Map for Product Manufacturers for the international picture.
For Japan-specific requirements, see Japan PFAS Regulations Under CSCL.
For the EU, see EU PFAS Restriction: Scope, Status and Timeline.
The underlying supplier and product data can often support multiple assessments, but each jurisdiction must still be evaluated against its own requirements.
Managing PFAS data across Canadian products
For a large product portfolio, maintaining PFAS information manually can create gaps between regulatory requirements and product records.
A compliance team may need to answer:
- Which products contain PFAS?
- Which suppliers have provided evidence?
- Which components remain unresolved?
- Which PFAS are used at Canadian facilities?
- Which listed PFAS may meet NPRI thresholds?
- Which products or facilities could be affected by future requirements?
- What evidence supports the assessment?
Regilient's PFAS Compliance Software connects PFAS identification and tracking with supplier data collection, product-level assessment, regulatory monitoring and compliance documentation.
The workflow can connect:
Supplier data → Material → Component → Product → PFAS → Regulation → Compliance status → Evidence
This gives compliance teams a common product and substance data foundation rather than maintaining separate PFAS spreadsheets for every jurisdiction.
What should manufacturers do now?
Canadian manufacturers and importers should:
- Review whether the 2025–2027 NPRI PFAS requirements apply to their facilities.
- Identify listed PFAS used or processed at relevant concentrations and quantities.
- Map PFAS information to materials, components and products.
- Close supplier-data gaps.
- Maintain evidence supporting quantities, concentrations and product information.
- Monitor Canada's ongoing PFAS risk-management activities.
The key is to separate current reporting obligations from future regulatory developments, while maintaining enough product and supplier data to respond when requirements change.