According to SiliconExpert’s database, over 39,000 components contain some form of PFAS across over 250 different types of components. 74% of all PFAS affected parts come from the United States, which is Canada’s biggest trade partner. Given the likelihood of companies importing components or substances containing PFAS, it is imperative that they understand the chemical makeup of their products to comply with the new reporting mandate. This will impact not only electronics manufacturers in Canada, but also foreign exporters doing business with Canadian importers as they can expect companies to reach out for more chemical information about the components they are importing.

Who Needs to Comply with the Canada PFAS Reporting Mandate?

According to the guideline manual, any person or entity that satisfied any of the following criteria during the 2023 calendar year is required to comply with the new PFAS reporting mandate:

• Manufactured a total quantity greater than 1000 g of a substance listed in Schedule 1
• Imported a total quantity greater than 10 g of a substance listed in Part 1 of Schedule 1, OR a total quantity greater than 100 kg of a substance listed in Part 2 or Part 3 of Schedule 1, whether the substance was alone, or at a concentration equal to or above 1 ppm in a mixture or in a product or at a concentration equal to or above 1 ppm in one of the categories of manufactured items
• Imported a total quantity greater than 100 kg of any substance listed in Schedule 1 at a concentration equal to or above 1 ppm in a manufactured item NOT listed in the categories of manufactured items
• Used a total quantity greater than 10 g of a substance listed in Schedule 1, whether the substance was alone, or at a concentration equal to or above 1 ppm in a mixture or in a product, in the manufacture of a mixture, a product, or a manufactured item

The guideline manual also lists examples of companies that are and are not exempt from reporting if you are unsure if you need to comply.

How to Comply with the Canada PFAS Reporting Mandate

Companies that are required to comply with the Canada PFAS reporting mandate must provide a CEPA section 71 response. In this particular case, the Canadian Government has provided a PFAS Excel Reporting File (ERF) that businesses must download and complete, and then submit via the Environment and Climate Change Canada’s Single Window.

When filling out the PFAS ERF, companies can expect to provide the following information for each PFAS substance:

• Name and description for each manufactured item containing PFAS
• Facility information that uses or manufactures with a PFAS substance
• Quantity of PFAS substances manufactured, imported, used, and/or exported