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On July 27, 2024, the Canadian government activated a PFAS reporting requirement under CEPA (Canadian Environmental Protection Act), signalling a major shift in PFAS compliance for manufacturers and importers. This regulation requires detailed, substance-level disclosures covering product names, PFAS concentrations, total quantities, and end uses.
If you're importing or manufacturing PFAS—or products containing them—you’re on the hook.
What Does the New CEPA Rule Really Require?
Canada’s revised risk management scope—published by Environment and Climate Change Canada and Health Canada outlines a phased regulatory strategy to eliminate high-risk PFAS, with a clear push toward:
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Regulating untracked PFAS like those in firefighting foams
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Risk-based phasing driven by socio-economic impact and alternatives
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Reducing PFAS exposure in the environment and human populations
This is not just about legacy chemicals like PFOA and PFOS. The regulation spans hundreds of PFAS—and you’ll need to identify, quantify, and report them.
Key Canada PFAS Reporting Rules: What You Need to Track
Here’s where the CEPA PFAS rule gets tricky:
1. Scope Is Broader Than You Think
Canada’s PFAS inventory includes ~300 substances. And unlike TSCA, Canada’s scope and thresholds are layered across three substance lists—with varying triggers by product category.
If you're in electronics, textiles, automotive, or medical devices, you're likely impacted.
2. Reporting Thresholds Are Low
- PTFE (Teflon) has a 0.0001% threshold or 100 kg import volume
- Juvenile goods and cookware have lower trigger thresholds
- Concentration + quantity both apply to determine reportability
3. Micro-Business Exemptions
Companies with under 5 employees or less than $30,000 in revenue may be exempt—but it’s not automatic. Documentation is required.
4. De Minimis Doesn’t Mean De-Risked
Concentration thresholds exist—but exemptions don’t remove your audit trail obligations.
Non-Compliance Comes at a Cost
The financial risk? Steep:
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Up to $500,000 for corporations
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Up to $25,000 for individuals
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Repeat offenses? Double the fine
The reputational risk? Even higher. Regulators, customers, and the public are watching how companies handle PFAS.
PTFE (Teflon): The Most Watched Substance
PTFE is everywhere—electronics, industrial coatings, cable insulation, gaskets, and seals. Under CEPA, it’s now reportable based on extremely low thresholds.
If you're using PTFE, don’t assume you’re safe—verify and document your usage immediately.
Confidentiality Options Are Limited
Worried about trade secrets? You can claim CBI status under CEPA—but it requires a substantiated justification. That means submitting evidence at the time of filing.
How Canada Aligns Globally
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Canada’s PFAS crackdown aligns with global trends:
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EU is finalizing a sweeping PFAS ban under REACH.
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US EPA is moving aggressively under TSCA Section 8(a)(7)
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Australia and Japan are preparing similar frameworks
If you're operating internationally, this isn’t just about Canadian compliance—it’s about global continuity.
What You Should Be Doing Now
To stay ahead:
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Map your supply chain: Request Full Material Disclosures (FMDs) from all vendors
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Automate PFAS tracking across product lines
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Conduct gap analysis against CEPA, TSCA, and REACH
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Engage experts to validate your scoping, thresholds, and exemptions
Need to Simplify Your CEPA PFAS Reporting?
Acquis helps companies manage complex PFAS obligations through:
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Automated substance-level data tracking
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FMD-based supplier engagement
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Threshold validation against CEPA and TSCA
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Custom PFAS dashboards and audit-ready outputs .