Canada Releases Final PFAS Report and Risk Management Plan

By Krystal Spickler, program manager, Supply Chain team, UL Solutions

The Canadian government recently formalized its approach for the regulation of per- and polyfluoroalkyl substances (PFAS). In March 2025, a Final State of PFAS Report, updated risk management details, and a proposed order to add PFAS to Schedule 1 of the Canadian Environmental Protection Act, 1999 (CEPA) were published.

Although Canada currently regulates a handful of PFAS substances, their salts, and precursors through the Prohibition of Certain Toxic Substances Regulations, these actions address the entire class of PFAS excluding fluoropolymers. These publications also follow a mandatory information gathering on PFAS (survey under Sec. 71 of CEPA), which was due for parties without extensions in January 2025.

The Final State of PFAS Report

Two previous versions of the Report were published in draft form and underwent consultations for feedback. The Report consists of relevant information pertaining to the sources, occurrence, and potential impact of PFAS from an environmental or human health lens.

It highlights that the performance characteristics of PFAS lend the class to a wide range of applications across consumer, industrial and commercial sectors. They can be found in food packaging materials, drugs, medical devices, cosmetics, pesticides, electronics, and many other consumer goods. In addition to environmental hot spots containing elevated levels of PFAS, interaction with these products often contributes as sources for exposure.

Data gaps for the collective group were highlighted in the Report, but literature reporting bioaccumulative, immunotoxic, neurotoxic and reproductively damaging behaviors was also highlighted. The Report also notes that members of the class may be environmentally persistent, mobile, and are difficult to remove from the environment. 

PFAS in scope of the Report include those meeting the Organization for Economic Cooperation and Development (OECD) 2021 definition. This definition consists of many groups and sub-groups of PFAS, including well-known ones like perfluorocarboxylic acids (PFCAs) and perfluorosulfonic acids. Despite their alignment with the definition, the Report concluded that while the class of PFAS meets the criteria for addition to Schedule 1 of CEPA, fluoropolymers may have a different hazard profile and should be assessed separately.

Addition of PFAS to Schedule 1 of CEPA

As outlined in the Report, the class of PFAS was assessed and found to meet two criteria defining toxic substances outlined in section 64 of CEPA—namely, they may enter or are entering the environment in ways that constitute or could constitute danger in Canada to human health or life and they have or may have long-term harmful effects on the environment or biological diversity. Based on this assessment, the Ministers of the Environment and Health recommended addition of the class to Part 2 of Schedule 1 of CEPA.

Substances on Part 2 of Schedule 1 typically are regulated in a way that prioritizes pollution prevention rather than blanket bans. This action classifies the group of PFAS as ‘toxic’ and use of these chemicals can still be subject to targeted prohibitions once listed. Addition to Schedule 1 does not immediately establish any controls on the use of substances. Instead, it enables Government to take actions for risk management.

Fluoropolymers have been proposed for inclusion in the upcoming Plan of Priorities. No assessment timeline has been published.

Canada’s risk management approach for PFAS

A three-phase risk management plan was proposed to address the human health and environmental concerns associated with PFAS (excluding fluoropolymers) in Canada. The proposal notes that other ongoing activities relating to PFAS will continue and that they may evolve through consultation or other activities addressing other substances.

The first phase will impact use of PFAS in aqueous firefighting foams (AFFF). Some AFFFs have already been regulated in Canada; those with perfluorooctanoic acid (PFOA), perfluorooctane sulfonate (PFOS), long chain-PFCAs, their salts and precursors are already prohibited with some exceptions under the Prohibition of Certain Toxic Substances Regulations. The proposed risk management actions for AFFF would prohibit all remaining applications of PFAS in AFFF with consideration given to timelines.

The second phase would seek to eliminate use of PFAS in many consumer products with available alternatives. Consultations would tentatively take place in 2027. Examples specifically named include:

• Cosmetics
• Natural health products and non-prescription drugs
• Food contact applications
• Consumer mixtures such as cleaning products
• Textile applications
• Ski waxes
• Paints, coatings, sealants, adhesives, or other building materials for consumer use

The properties of PFAS in these products accomplish many technical functions, including lubrication, emulsification, grease-proofing, stain- or water-resistance, durability, or even act as surfactants. Many of these categories have already been named in numerous U.S. state laws regulating use of PFAS.

In the last phase, the Government plans to implement actions for uses of PFAS which may have less feasible alternatives. Examples of these include:

• Fluorinated gases (f-gases)
• Prescription drugs for humans and animals
• Medical devices
• Transport and military uses
• Industrial applications in food contact as well as the mining and petroleum sectors

Hydrofluoroolefins (HFOs) and hydrochlorofluoroolefins (HCFCs) are f-gases which have common application in refrigerants, foam blowing, propellants, and solvents. They also have commonly been adopted as more climate-friendly alternatives to ozone depleting substances and other greenhouse gases which have negative impacts on climate change.

Consideration for voluntary actions is also given in the proposal. Among these are increased information disclosure (such as labeling), industry-specific voluntary phaseouts, working with North American trading partners to assess alternatives and informed substitution, and exploration of removing PFAS from the list of permitted food additives.

Opportunities for engagement and feedback

Both the Risk Management approach and Order for addition for Schedule 1 are open for comments until May 7, 2025. Parties interested in the proposed Order for addition to Schedule 1 of CEPA may submit comments through the link below. Comments on the Risk Management Approach may be submitted at the contact information listed in the publication linked below.

State of per- and polyfluoroalkyl substances (PFAS) report

Canada Gazette, Part 1, Volume 159, Number 10: Order Adding a Toxic Substance to Part 2 of Schedule 1 to the Canadian Environmental Protection Act, 1999

Risk management approach for per- and polyfluoroalkyl substances (PFAS), excluding fluoropolymers

Proposed Plan of Priorities