RCC seeks member comment on federal draft state of per and polyfluoroalkyl substances (PFAS)

The Government of Canada has published a Draft State of Per- and polyfluoroalkyl substances (PFAS) Report for a 60-day public comment. The related notice was published in the Canada Gazette, Part I: Vol. 157, No. 20 – May 20, 2023. The consultation is open until July 19, 2023. This will be of importance to retailers as PFAS are prevalent in a range of product categories including packaging, textiles, appliances, cosmetics, electronics and more to make materials water-repellant, non-stick, stain resistant and/or grease-proof.

The report provides the basis for a class-based approach to inform decision-making on PFAS in Canada. The report also proposes to conclude that PFAS as a class are harmful to human health and the environment and be added to Schedule 1 of the Canadian Environmental Protection Act (CEPA). A Risk Management Scope for Per- and Polyfluoroalkyl Substances (PFAS) was also published on May 20, 2023 for a 60-day public comment period.

Environment and Climate Change Canada also published a Supporting Document: Ecological State of the Science Report on Short-chain PFCAs, Short-chain PFSAs, and Long-chain PFSAs that provides a summary of environmental data that has become available on 3 subgroups of PFAS: short-chain perfluorocarboxylic acids (SC-PFCAs), short-chain perfluorosulfonic acids (SC-PFSAs), and long-chain perfluorosulfonic acids (LC-PFSAs). Some of these substances are being used as substitutes for regulated PFOS, PFOA, and LC-PFCAs.