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Per- and polyfluoroalkyl substances (PFAS) are a group of human-made chemicals used in many everyday products for their heat, stain, and water-resistant properties. These include items like clothing, furniture, cookware, food packaging, and fire-fighting foams. But the same properties that make PFAS useful also make them a challenge for our environment and health. These 鈥榝orever chemicals鈥� are highly persistent, meaning they don鈥檛 break down easily, and there鈥檚 growing evidence linking PFAS exposure to adverse health effects in humans.

As awareness and concern around PFAS have grown, so have the regulations. In Canada, we鈥檙e seeing a major shift in how PFAS are tracked, reported, and managed. Here鈥檚 a breakdown of what鈥檚 happening and what it means for businesses.

What's in place and what's coming?

Environmental Standards

PFAS have been manufactured and used for over 80 years, but only recently have they become the focus of regulatory agencies. Provinces like British Columbia, Nova Scotia, and Alberta have introduced their own standards for PFAS in soil and water, while Quebec is expected to become the first province to regulate PFAS in biosolids. At the federal level, Health Canada has released an updated drinking water objective, and both federal and provincial governments have published various non-regulated criteria to guide monitoring and management.

Mandatory Reporting

Beyond the focus on PFAS in environmental media, a was put in place by the federal government in July 2024 which mandated reporting by manufacturers, importers, and users of 312 specified PFAS in the 2023 calendar year. This reporting requires information related to each of the 312 PFAS including the quantities involved and the type of activity (e.g., manufacture, import, or use in manufacturing), as well as the function of the substance, and industry application. If your company is in scope and fails to report, the consequences can be significant. Beyond potential financial penalties and fines, there are reputational risks, as customers, investors, and the public are paying closer attention to how organizations manage PFAS. Perhaps most importantly, not reporting PFAS use could mean losing the opportunity to help shape how future regulations are developed and applied to your operations.

2025 Updates

A number of other items were advanced by the federal government in March 2025:

• State of PFAS Report: The third version of this report, outlining what Canada knows about PFAS, their uses, and potential risks.
• Risk Management Approach: An updated risk management document that lays out the government鈥檚 plans to mitigate and control PFAS risks going forward.
• Toxic Substances Listing: An listing the class of PFAS, excluding fluoropolymers, as toxic substances under the Canadian Environmental Protection Act (CEPA).
• National Pollutant Release Inventory (NPRI): Environment and Climate Change Canada (ECCC) announced that 163 PFAS will be added to the beginning with the 2025 reporting year.

These advancements signal a significant shift toward broader PFAS oversight at the federal level. The reporting requirements are part of a data-gathering effort aimed at creating a national picture of how PFAS are used and managed in Canada, and to inform future regulatory decisions. As a result, companies and organizations that haven鈥檛 historically tracked PFAS may now need to understand their exposure to the regulatory requirements and develop protocols to address them. More importantly, it鈥檚 clear that going forward, there will be a greater need to understand the presence of PFAS throughout supply chains and to track that presence as regulation and restrictions evolve.

The challenges and what's working

Supply Chain Visibility

Many suppliers may not be familiar with PFAS or may rely on manufacturers who don鈥檛 provide PFAS-specific data. If they are aware of PFAS, the information that鈥檚 available or provided might not fully align with the data you are tracking as part of your risk management efforts. That鈥檚 why clear, specific communication is key. For example, instead of asking suppliers if there are PFAS in their products, ask:

• Which items contain PFAS?
• What are the substance identifiers?
• What are the concentrations or total quantities?

One approach to enhance supply chain visibility is to build PFAS questions into vendor and product onboarding processes. This could include adding disclosure clauses to contracts, requesting updates when formulations change, or requirements around blind submissions if further regulatory reporting is required and product confidentiality is desired. You鈥檒l also want to consider how much data you want to collect 鈥� just what鈥檚 required to address Canadian or other international obligations, or more detailed information to help you manage future risk. It鈥檚 also beneficial to communicate your intentions as a customer if you are planning to transition away from PFAS in your products.

Ultimately, this is a give and take. Building strong, collaborative relationships with your suppliers can help you get timely information and respond more effectively as regulations change.

Data Management

Many organizations don鈥檛 have a centralized system for managing supply chain data. Instead, many still rely on PDFs, emails, or spreadsheets to track product composition, in turn making reporting challenging and future-proofing even more difficult.

Centralized, standardized databases that connect procurement, suppliers, and product data are invaluable. Good data management helps not only with compliance but also with Environmental Social and Governance (ESG) reporting, customer questions, and internal risk assessments.

Understanding What to Track and Report

There鈥檚 often confusion about who is responsible for tracking PFAS and what reporting obligations apply to each party (i.e., manufacturer, importer, end user). And once supplier data is received, it鈥檚 not always clear whether it鈥檚 sufficient, what assumptions can reasonably be made, or how long this data should be tracked and stored.

Companies can respond to these challenges by training their teams, developing internal review processes, and considering legal or expert guidance. It's also important to determine what can be considered reasonable due diligence and how to demonstrate and document that you鈥檝e taken reasonable steps to meet requirements.

The Role (and Limits) of Software

With all the uncertainty, it鈥檚 no surprise that a growing market of tools is emerging to help track PFAS and support compliance. These tools can assist with data collection and supplier engagement, but they still require a solid understanding of the data and how to interpret regulations.

Before investing, ask:

• Will this tool help us meet reporting obligations or just collect more data?
• Does it integrate with our existing systems?
• Can it grow with our future needs?

It鈥檚 important to remember that software can support your strategy, but it can鈥檛 replace it.

What's next?

The federal government is taking a phased approach to PFAS regulation. Over the next 3 鈥� 6 years, we鈥檒l likely see increased focus on restricting PFAS in consumer goods such as cosmetics, textiles, food packaging, and so on. Within the next 10 years, regulations are expected to expand to include restrictions on PFAS in medical devices, industrial food contact materials, prescription drugs, and other applications.

Consequently, businesses will need to continue to proactively track PFAS use across their supply chains, understand where PFAS may appear in their products and processes, and stay ahead of both Canadian and international regulations. As Canada鈥檚 PFAS regulations evolve rapidly, moving from reactive compliance to proactive preparation is crucial. The more you understand your products, supply chain, and data, the better positioned you鈥檒l be.