Reminder - Extension Deadline of July 29, 2025 for Canada’s PFAS Mandatory Survey
PFAS (per- and polyfluoroalkyl substances) makes up a group of chemicals, some of which are known for persisting in the environment, and for having a negative environmental impact. Examples of their use in the HVAC industry would include some refrigerants and some electrical components.
You may recall that the government of Canada issued a mandatory survey in 2024, setting a deadline for January 2025 for submitting information on the PFAS. Many companies received a six-month extension, setting a new deadline around July 29, 2025 for responses to the survey.
More information on the mandatory survey, including links to the original Canada Gazette notice and Environment and Climate Change Canada’s (ECCC) Guidance Document, are available in the following In the Air post: click here
HRAI has received guidance, shown below, from ECCC that may be helpful for members working towards the July 29th mandatory survey deadline.
If you have any questions, please feel free to reach out to HRAI’s Director of Regulatory Affairs, Perry Chao at pchao@hrai.ca.
Guidance from Environment and Climate Change Canada and Health Canada, for the 2025 CEPA Section 71 Mandatory Survey on PFAS
A significant amount of helpful information is available in ECCC’s Guidance Document, but ECCC has provided answers to additional questions to provide advice on the type of information, and effort that should go into collecting and submitting data for the mandatory survey.
Q: What information does ECCC understand companies to hold?
Companies subject the notice are required to provide information that they possess or that they would be reasonably expected to be able to access. This includes, but is not limited to, information that may be in the possession of employees or other agents of the company.
For example:
- Companies involved in the commercial production of substances, mixtures, products, or manufactured items should have access to quantities and concentrations of substances contained in those items.
- Importers are reasonably expected to have access to import records and supporting documentation such as Safety Data Sheets (SDS), product data sheets, etc.
Q: What should companies do when suppliers are not responsive?
If quantity information cannot be calculated exactly because certain suppliers are unresponsive, companies may make a judgement call to come up with alternative approaches to generate estimates. ECCC would expect that assumptions or approaches would be documented in the Notes field in the Excel Reporting File.
Q: How much effort should companies put into obtaining data from suppliers?
Companies are expected to make reasonable efforts to obtain the data from their supply chain, including efforts to follow up with non-responsive suppliers. Providing documentation to demonstrate reasonable efforts to obtain data is not expected. However, it is a company’s responsibility to perform due diligence, and EC/HC recommends documenting and keeping records of relevant communications.
There is no requirement to conduct tests to comply with the notice. However, companies subject to the notice should make reasonable efforts to obtain information through their supply chain.
If members are unable to obtain information even after making reasonable efforts, but they suspect that their goods contain PFAS, ECCC recommends that they submit this information in a Declaration of Stakeholder Interest (SHI). An SHI should be submitted through Single Window (see Annex B of the guidance manual for more instructions on submitting an SHI) and is not restricted to a particular format.
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