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Canadian regulations

Canada Announces PFAS Mandatory Survey

Oct. 2, 2024
The reporting aims to compile detailed data on PFAS manufacturing, imports, and usage, which will influence future regulations.

Canada intends to use the information to establish baseline commercial use data.

The notice applies to PFAS at a concentration equal to or above one ppm in a manufactured item in the following categories:
  • Intended to be used by or for children under the age of 14 years;
  • Intended to come into contact with the mucosa of an individual;
  • Used as intended in a manner such that the substance may be inhaled or come into dermal or oral contact with an individual;
  • Cookware, or a cooking or serving utensil intended to come into direct contact with heated food or beverage;
  • Food packaging material, including single-serve and/or disposable bowls, plates, cups, other serving ware, as well as food cans and lid liners, that are intended to or may come into direct contact with food or beverage;
  • A reusable food or beverage container;
  • Food processing equipment, including conveyor belts, trays, vats, nozzles, molds and cutters that come into contact with food or beverage prior to packaging and distribution;
  • Clothing or footwear, including life jackets, personal flotation devices and other safety apparel;
  • Bedding, sleeping bags or towels;
  • Furniture, mattresses, cushions or pillows intended to be used by an individual, where the substance is contained in foam or leather or in a textile fiber, yarn or fabric;
  • Carpet, vinyl or laminate flooring, or foam underlay for flooring, intended to be used by an individual; and
  • A substance intended to be released from the manufactured item.
 
While companies outside of Canada are not subject to the notice, firms importing products must respond to the notice if the above criteria are met. Canada “encourages” foreign suppliers to inform their Canadian customers that they import a reportable substance and may meet the reporting criteria. According to the guidance manual, a letter to help Canadian stakeholders obtain data from their foreign suppliers is available for download. The guidance manual notes that if confidential business information can’t be shared with Canadian stakeholders, foreign suppliers and Canadian importers can submit information in the form of a blind submission.
 
As is always the case, these reporting obligations are important to discharge, and care needs to be applied in doing so. Expect inquiring entities to review all publicly available information submitted by companies globally, so it’s essential to adhere to standard operating procedures to ensure consistency.
About the Author

Lynn L. Bergeson, Compliance Advisor columnist

LYNN L. BERGESON is managing director of Bergeson & Campbell, P.C., a Washington, D.C.-based law firm that concentrates on conventional, biobased, and nanoscale chemical industry issues. She served as chair of the American Bar Association Section of Environment, Energy, and Resources (2005-2006). The views expressed herein are solely those of the author. This column is not intended to provide, nor should be construed as, legal advice.

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