Canada PFAS: How to Comply with New Reporting Mandate

By: Joe Corbisiero on September 16th, 2024

Canada’s Minister of the Environment has issued a new reporting mandate to obtain information on the manufacturing, importing, and use of PFAS ‘forever chemicals’ during the 2023 calendar year. The notice in the Canada Gazette calls out 312 specific per- and polyfluoroalkyl substances listed in Schedule 1 of the reporting mandate.

The new reporting mandate deadline is approaching quickly, and businesses must submit their data by January 29th, 2025.

The new reporting mandate comes after recent studies found high levels of PFAS in rainwater worldwide, leading to increased scrutiny of the use of PFAS in supply chains. The United States Environmental Protection Agency recently enacted similar PFAS reporting requirements, which started in November 2023.  

Impact of Canada PFAS Mandate on Electronics

While Canada has already listed PFAS subsets PFOA and PFOS as toxic substances, the addition of the broad 312 PFAS substances to the reporting mandate creates an additional challenge for electronics importers and manufacturers. With only 6 months to comply from the announcement date of the reporting rule, electronics manufacturers may find themselves scrambling to trace their supply chain and account for the chemical composition of their bill of materials.

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

Fulfill Your PFAS Reporting Mandate with SiliconExpert

As the January 2025 reporting deadline approaches, SiliconExpert can provide the compliance data needed to complete the PFAS Section 71 ERP and fulfill your company's reporting mandate.  Our professional services team can examine your bill of materials and manufacturing lists for the 312 PFAS substances and provide the necessary compliance data.

Complete My PFAS Report

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