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ARTICLE · 19 FEBRUARY 2026

Environmental Enforcement Trends: Higher Penalties And Prosecutorial Focus On PFAS

Blake, Cassels & Graydon LLP
Blake, Cassels & Graydon LLP
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Blake, Cassels & Graydon LLP

Blake, Cassels & Graydon LLP

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Both in Canada and internationally, there has been increased regulatory focus on per- and polyfluoroalkyl substances (PFAS) due to their persistence in the environment and concerns regarding their health and ecological...

CanadaEnvironment
Ryan McNamara
Ryan McNamara
Jonathan Kahn
Jonathan Kahn
Lavinia Chui (Articling Student)
Lavinia Chui (Articling Student)
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Both in Canada and internationally, there has been increased regulatory focus on per- and polyfluoroalkyl substances (PFAS) due to their persistence in the environment and concerns regarding their health and ecological effects. As governments adopt more stringent regulations and increase enforcement activity related to PFAS, companies, particularly those involved in manufacturing, importing or selling consumer goods, are facing heightened compliance risks. A recent prosecution under the Canadian Environmental Protection Act, 1999 (CEPA) involving Estée Lauder Cosmetics Ltd. (Estée Lauder) illustrates the substantial consequences faced by companies that fail to comply with CEPA's toxic substance notification requirements and the conditions of compliance orders issued under CEPA, especially where PFAS are concerned.

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