Canada's PFAS Reporting Requirements: What You Need To Know

The Government of Canada has provided additional guidance to stakeholders regarding compliance with a mandatory survey requiring manufacturers, importers and users of 312 per- and polyfluoroalkyl substances (PFAS) to report information about their activities in Canada during the 2023 calendar year. This mandatory survey obligation, which was initiated by way of a Notice issued under section 71 of the Canadian Environmental Protection Act, 1999 (the Notice), must be completed by January 29, 2025.

The purpose of section 71 notices is to gather information to inform decision-making for risk management measures, likely in the form of future regulation, related to these substances.

In what follows, we discuss who must report under the Notice, what information must be supplied, how to determine which compliance obligations are applicable, and how to fulfil such obligations.