Canada's Mandatory PFAS Reporting Deadline: Be Cautious Relying On Prior Compliance

The deadline for meeting reporting requirements of the Notice with respect to certain per- and polyfluoroalkyl substances issued by Environment Canada and Climate Change (ECCC) is Jan. 29, 2025 (the Notice). The reporting obligations and other details about the Notice can be found in our other article found here.

With the deadline to respond around the corner, companies captured under the Notice such as users, importers, and manufacturers, as well as those up the supply chain, may be seeking confirmation from vendors and suppliers that they independently comply with the Notice in place of carrying out the inquiry mandated by the Notice. Companies responding to such requests should carefully consider whether they actually comply with the Notice, especially if their answer is predicated on their compliance with another country's requirements. Indeed, companies should not assume a blanket compliance with the Notice on such basis as PFAS requirements vary between