August 2024: As part of the Chemicals Management Plan (CMP), Canada is collecting crucial information on chemical for guiding the prioritization, risk assessment, and risk management activities of Environment and Climate Change Canada (ECCC) and Health Canada (HC).

A data collection notice was published on July 29, 2024, concerning a list of perfluoroalkyl and polyfluoroalkyl substances (PFAS). Companies must respond by January 29, 2025, if they handled specific quantities of these substances in 2023.

The request for data

This notice requires to report, amongst other information, the products containing any substance listed in Schedule I of the notice, and the quantity of this substance manufactured, imported, or used in 2023.

The information must be submitted by electronic mean to the Environmental and climate change Canada’s single window.

Scope of the notice

Substances in the scope of the notice are any substance listed in Schedule 1 to the notice.

Cosmetics, including some packaging items, imported in Canada and containing PFAS listed in Schedule I of the notice are falling into the scope of the data reporting.

Compagnies under the scope of this notice are any company:

• manufacturing more than 1T of any substance listed in the Schedule I of the notice
• importing a substance listed in Part 1 of Schedule 1 in a total quantity exceeding 10 g, or a substance listed in Part 2 or Part 3 of Schedule 1 in a total quantity exceeding 100 kg, whether:

a) Alone;

b) Present at a concentration equal to or greater than 1 ppm in a mixture or product;

c) Present at a concentration equal to or greater than 1 ppm in a manufactured item that are:

(i) Intended for use by or for children under 14 years old,

(ii) Intended to come into contact with an individual’s mucous membranes,

(iii) Used as intended so that the substance may be inhaled or come into contact with an individual’s skin or orally.

Micro-enterprises (fewer than five employees or generating less than $30,000 in gross annual revenue) are exempt from this obligation.

Confidentiality

Companies can request that the information provided be treated as confidential under Section 313 of CEPA.

If you export products to Canada, we recommend that you inform your importers of products containing PFAS listed in Schedule I. The link to access to the list of PFAS.

We hope that this letter will be of help and stay at your disposal for any questions related to this topic. Should you have any question, please, feel free to contact your dedicated Customer Relationship Manager.