Reminder – Deadline for Submitting PFAS Information is January 29, 2025

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Companies that produce, import, or use PFAS chemicals may need to submit information to Environment and Climate Change Canada (ECCC) by January 29, 2025. ECCC issued a notice under Section 71 of the Canadian Environmental Protection Act for this mandatory survey notice for PFAS chemicals. 

It is still possible to request an extension, but ECCC may take 15 business days to respond to a request. 

Requesting an Extension 

A request for an extension to the January 29, 2025 deadline must be submitted in writing to substances@ec.gc.ca and must include: 

  • Organization name 

  • Contact information 

  • Substance identifier(s) involved 

  • The reason for the request, and 

  • An estimate of the amount of time needed 

You may also use the word document template available at this link to send a letter to ECCC at substances@ec.gc.ca from your company. 

Background 

PFAS (Per- and polyfluoroalkyl substances) are a group of over 4,700 substances that encompass a broad range of chemistries and adverse environmental effects have been observed for well-studied PFAS. Examples of their use in the HVAC industry can include some refrigerants and some electrical components. 

Manufacturers, importers, and users of PFAS products/materials will need to submit information, by completing submitting information in an Excel Reporting File on their use of PFAS chemicals by January 29, 2025. For this notice, an importer is the person responsible for the movement of a reportable substance into Canada from another country. 

Your organization is required to submit information if, during the calendar year if it: 

  • manufactured more than 1000 g of a PFAS; 

  • imported into Canada more than 10g of certain PFAS (as set out in Schedule 1, Part 1); 

  • imported into Canada more than 100 kg of other certain PFAS listed in Part 2 or Part 3 of Schedule 1, whether alone or present in quantities equal to or exceeding 1 part per million (ppm) in a mixture or product, or in specified manufactured items that are listed at Section 2(2)(c) of the Notice, including various manufactured items intended to come into contact with humans and food products;1 

  • imported more than 100 kg of any PFAS containing more than 1 ppm in a Manufactured Item, other than those listed at Section 2(2)(c) of the Notice; or 

  • used a total quantity greater than 10 g of any PFAS, whether the substance was alone or at a concentration at or above 1 ppm in a mixture or in a product, or in the manufacture of a mixture, product, or manufactured item. 

 Key Exemptions – activity that the notice is not meant to capture: 

  • micro-businesses that have fewer than 5 employees or make less than $30,000 in annual gross revenue annually 

  • ordered a product containing a reportable substance from a warehouse located in Canada 

  • transferring a mixture, product, or manufactured item containing a reportable substance across provincial borders to be stored in a different warehouse 

  • purchasing or receiving a reportable substance alone, in a mixture, in a product, or in a manufactured item that was already located in Canada 

  • a foreign supplier (that is, exporting to Canada, located outside of Canada) is not subject to the notice; the importer to Canada must respond to the notice if the criteria are met 

More information on which substances are subject to reporting, who is subject to reporting, exclusions, and the information required, is available on the Gazette site: https://canadagazette.gc.ca/rp-pr/p1/2024/2024-07-27/html/sup-eng.html  

A Guidance Document has more detailed information on completing your submission and is available at the following link: https://www.canada.ca/en/environment-climate-change/services/evaluating-existing-substances/pfas-s71-guidance-manual.html 

For more information: 

Perry Chao 

Director, Regulatory Affairs 


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