Canada’s 2025 PFAS Reporting Mandate: What Manufacturers Must Do Now

On July 27, 2024, the Canadian government activated a mandatory information-gathering notice under CEPA Section 71, covering 312 PFAS listed in Schedule 1. This marks a major shift in PFAS compliance for manufacturers and importers, requiring detailed, substance-level disclosures for the 2023 reporting year (identities, concentrations ≥ 1 ppm, quantities, and 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:

The Section 71 notice, published in the Canada Gazette Part I (July 27 2024), obliges companies that manufactured, imported, or used any listed PFAS in 2023 to report detailed substance-level data. Reporting applies to PFAS in mixtures, products, and manufactured items above the concentration and quantity thresholds outlined below.

• Regulating untracked PFAS like those in firefighting foams

• Risk-based phasing driven by socio-economic impact and alternatives

• 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

The new rule defines precise reporting thresholds and conditions:

• Part 1 substances: report if > 10 g manufactured, imported, or used (alone or in mixtures/products/manufactured items) at ≥ 1 ppm.
• Part 2 and Part 3 substances: report if > 100 kg at ≥ 1 ppm.
• Imported manufactured items outside the 12 listed categories: report if > 100 kg of any listed substance at ≥ 1 ppm.
• Excluded: entities with < 5 employees or < $30 000 annual gross revenue.

The reporting period covers calendar year 2023, with submissions due January 29 2025.

Non-Compliance Comes at a Cost

Violations under CEPA can attract administrative monetary penalties (AMPs) of up to $25 000 per violation for companies, and for serious offences prosecuted by indictment, fines from $500 000 to $6 million for large corporations and potential imprisonment for responsible officers.

The reputational risk? Even higher. Regulators, customers, and the public are watching how companies handle PFAS.

PTFE (Teflon): The Most Watched Substance

PTFE (polytetrafluoroethylene) is included on the CEPA Schedule 1 PFAS list and is reportable at ≥ 1 ppm if quantity thresholds are met. Validate each CAS entry directly against Schedule 1 to confirm reporting obligations.

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

• Canada’s PFAS crackdown aligns with global trends:

• EU is finalizing a sweeping PFAS ban under REACH.

• US EPA is moving aggressively under TSCA Section 8(a)(7)

• Australia and Japan are preparing similar frameworks

If you're operating internationally, this isn’t just about Canadian compliance—it’s about global continuity.

Legal basis: Canada Gazette Part I (Vol. 158, No. 30, July 27 2024) – PFAS Section 71 Notice under the Canadian Environmental Protection Act.

<h2>Canada’s Next Step: PFAS Risk-Management Approach (March 2025)</h2> <p>On <strong>March 5 2025</strong>, the Government of Canada released its final <em>State of PFAS Report</em> and companion <em>Risk Management Approach</em> under the <strong>Canadian Environmental Protection Act (CEPA)</strong>. The plan proposes to regulate the <strong>entire class of PFAS (excluding fluoropolymers)</strong> by adding them to <strong>Part 2 of Schedule 1</strong> — enabling future prohibitions and restrictions.</p> <p>The approach outlines a <strong>three-phase strategy</strong>:</p> <ul> <li><strong>Phase 1 (2025–2027):</strong> Prohibit PFAS in firefighting foams and other high-release uses.</li> <li><strong>Phase 2 (2027–2029):</strong> Extend restrictions to consumer-product applications where safer alternatives exist.</li> <li><strong>Phase 3 (beyond 2029):</strong> Broaden coverage to additional industrial sectors once alternatives are validated.</li> </ul> <p>Consultation on the proposed Order runs until <strong>May 7 2025</strong>, with the first regulatory instruments expected by <strong>spring 2027</strong>. This shift marks Canada’s transition from <em>PFAS reporting</em> (under the 2024 Section 71 Notice) to <em>class-wide risk management and potential prohibition</em>.</p> <p><strong>Sources:</strong> <a href="https://www.canada.ca/en/environment-climate-change/news/2025/03/government-of-canada-publishes-state-of-per--and-polyfluoroalkyl-substances-pfas-report-and-proposed-risk-management-approach.html" target="_blank">Government of Canada – State of PFAS Report & Risk Management Approach</a>; <a href="https://gazette.gc.ca/rp-pr/p1/2025/2025-03-08/html/reg2-eng.html" target="_blank">Canada Gazette Part I – Proposed Schedule 1 Addition</a>.</p>

What You Should Be Doing Now

To stay ahead:

• Map your supply chain: Request Full Material Disclosures (FMDs) from all vendors

• Automate PFAS tracking across product lines

• Conduct gap analysis against CEPA, TSCA, and REACH

• Engage experts to validate your scoping, thresholds, and exemptions

Need to Simplify Your CEPA PFAS Reporting?

Acquis helps companies manage complex PFAS obligations through:

• Automated substance-level data tracking

• FMD-based supplier engagement

• Threshold validation against CEPA and TSCA

• Custom PFAS dashboards and audit-ready outputs .

→ Speak to our Compliance Experts