The evolving landscape of PFAS regulation in Canada

The regulatory landscape for Per- and Polyfluorinated Alkyl Substances (PFAS) is undergoing dramatic transformation worldwide. As we continuously monitor these regulatory developments, we’ve observed increased public concern through mainstream media coverage and growing government attention to these “forever chemicals.”

In Canada, this regulatory evolution reached a significant milestone on March 5, 2025, when the federal government released its final State of PFAS Report alongside a proposed risk management approach, now closed for public comment. Our teams have been actively reviewing these proposals to provide strategic guidance on potential impact across industries. 

The new approach aligns with the government’s 2021 commitment to investigate regulating PFAS as a unified class, with the notable exception of fluoropolymers. While this simplifies regulation, it raises scientific and practical concerns. With approximately 4,700 PFAS compounds differing in structure, properties and toxicology, a one-size-fits all framework may not adequately address these differences. Ongoing consultation with industry stakeholders will be essential to navigate these complexities and develop practical, science-based solutions. 

• Part 1: Chemicals considered for prohibition  

• Part 2: Chemicals considered for pollution prevention actions

This classification has evolved for PFAS over time:

• 2006: Perfluorooctane sulfonate (PFOS) and its salts added to Part 1 (prohibition)
• 2013: Perfluorooctanoic acid (PFOA) and other long-chain perfluoroalkyl carboxylic acids, their salts and precursors added to Part 2 (pollution prevention)
• 2025 Proposal: Addition of the full class of PFAS (excluding fluoropolymers) to Part 2, enabling broader pollution prevention measures

Understanding the practical implications of these classifications helps organizations prepare for compliance requirements. 

The 2022 Prohibition of Certain Toxic Substances Regulations (not yet in force) would eliminate many exemptions for PFAS use, especially affecting Aqueous Film-Forming Foams (AFFFs). Combined with the 2025 approach prohibiting currently unregulated PFAS in firefighting foams, this could lead to a near-total ban on AFFF use. We provide technical support for industries in identifying compliant, effective firefighting alternatives.

The federal government has taken action to collect more information about PFAS use in Canada.

1. Survey: A Notice with respect to certain PFAS was conducted to survey manufacturers, importers, and users of 312 different PFAS; this information was due on January 29, 2025, but many affected businesses obtained extensions through June 2025.  

2. NPRI reporting: In 2024, the federal government consulted on adding 131 PFAS to annual National Pollutant Release Inventory (NPRI) reporting, with reporting on the 2025 calendar year proposed to begin in June 2026.

These initiatives signal a commitment to evidence-based decision-making while creating new compliance obligations for affected businesses.  

Our experience with these complex reporting requirements can help ensure accurate and timely submissions.

Since 2018, various branches of the federal government and the Canadian Council of Ministers of the Environment (CCME) have released environmental quality screening values for various PFAS. Environment and Climate Change Canada (ECCC) released Federal Environmental Quality Guidelines (FEQGs) for PFOS in 2018. Health Canada (HC) set Maximum Acceptable Concentrations (MACs) for PFOS and PFOA in drinking water in 2018, and in 2019 released Drinking Water Screening Values (DWSVs) for 9 other PFAS. These are now superseded by HC's 2024 Objective for Drinking Water Quality, considering a water concentration sum of 25 different PFAS. HC also derived Soil Screening Values (SSVs) for 11 PFAS in 2019, and in 2021, CCME released Canadian Environmental Quality Guidelines (CEQGs) for PFOS in soil and groundwater.

Notably, there are currently no official sediment quality screening values for PFAS in Canada.

Provincial and territorial governments have responded differently to PFAS. 

• British Columbia, Alberta, and the Atlantic provinces, have included individual PFAS in their environmental quality screening values.  
• Ontario has provided its "Qualified Persons, Risk Assessment" with informal guidance on how to approach PFAS in regulatory submissions.

All provinces and territories maintain environmental protection statutes that effectively prohibit discharges of chemicals that may cause adverse health effects, though specific wording and conceptual frameworks vary by jurisdiction.  

Our national presence enables region-specific compliance guidance tailored to local regulatory requirements across all Canadian jurisdictions.

The pace of PFAS regulation in Canada mirrors the rapid advancement of scientific understanding about these compounds. While adapting to the shifting regulatory landscape requires vigilance and flexibility, regulators are open to meaningful consultation as they implement measures to address these emerging contaminants.

We help clients stay ahead of regulatory change through proactive monitoring, impact assessments and technical expertise in sampling, analysis, remediation, toxicology, and alternative solutions; offering a strategic advantage in managing PFAS-related risks and identifying opportunities amid this transformative regulatory environment.