Under the Canadian Environmental Protection Act, 1999 (CEPA), the Government of Canada prepared a qualitative assessment report of the fate, sources, occurrence, and potential impacts of per- and polyfluoroalkyl substances (PFAS) on the environment and human health to inform decision-making on PFAS in Canada.
The Draft State of PFAS Report was published in May 2023. Based on comments received and information submitted in response to the Draft State of PFAS Report, along with other information suggesting that fluoropolymers may have significantly different exposure and hazard profiles when compared with other PFAS, it was determined that additional work on fluoropolymers is warranted. As a result of this change, an Updated Draft State of PFAS Report has been published. PFAS meeting the definition of fluoropolymers, as defined in the updated report, are not addressed within the Updated Draft State of PFAS Report.
Fluoropolymers are planned for consideration in a separate assessment and their exclusion from the Updated Draft State of PFAS Report should not be interpreted as meaning that they are of low concern.
This page provides some key information from the Updated Draft State of PFAS Report and the Revised Risk Management Scope document.
On the basis of what is known about well-studied PFAS and the potential for other PFAS to behave similarly, and on the expectation that combined exposures to multiple PFAS increase the likelihood of detrimental impacts, the Government is proposing that the class of PFAS (excluding fluoropolymers as defined in the Updated Draft State of PFAS Report) is entering or may enter the environment at levels that are harmful or may be harmful to the environment and to human health.
Risk management options for the class of PFAS (excluding fluoropolymers as defined in the report) are proposed in the Revised Risk Management Scope document, including regulatory instruments.
About these substances
PFAS are a class of thousands of human-made substances. The common chemical characteristic of PFAS is their perfluoroalkyl moiety, which is extremely stable in the environment. New PFAS are continually being developed and notified to the Government of Canada.
The Updated Draft State of PFAS report uses the Organisation for Economic Co-operation and Development (OECD) 2021 definition for PFAS as follows: fluorinated substances that contain at least one fully fluorinated methyl or methylene carbon atom (without any H/Cl/Br/I atom attached to it), that is with a few noted exceptions, any chemical with at least a perfluorinated methyl group (–CF3) or a perfluorinated methylene group (–CF2–) is a PFAS. The class of PFAS is comprised of substances meeting this definition.
Based on available information, fluoropolymers may have different exposure and hazard profiles compared with other PFAS. Given information suggesting their differences from other PFAS, additional work on fluoropolymers is warranted. PFAS meeting the definition of fluoropolymers, as defined in the report, are not addressed within the report and will be considered in a separate assessment.
PFAS have a wide range of uses in products available to consumers, industrial applications, and specialized applications. Some typical uses of PFAS include use as surfactants, lubricants, and repellents (for dirt, water, and grease). PFAS can also be found in certain firefighting foams (for example, aqueous film-forming foams [AFFF]), food packaging, drugs, cosmetics, sunscreens, pesticides, textiles (for example, carpets, furniture, and clothing), non-stick cookware, vehicles, and electronics.
PFAS are extremely persistent in the environment and are often termed "forever chemicals" as a result of this stability. Certain PFAS are prone to accumulation, are mobile, are able to migrate locally and over long distances, and are commonly detected in the environment and humans. Experience with contaminated sites management indicates that PFAS are very challenging to remove from environmental media (for example, soil) and it's not possible to remove them from the broader environment.
Class approach
CEPA defines a class of substances as any two or more substances that: (a) contain the same portion of chemical structure; (b) have similar physical-chemical or toxicological properties; or (c) have similar types of use. Substances included under the OECD definition of PFAS, which is used in the Updated Draft State of PFAS Report, meet the definition of class under CEPA as they contain the same portion of chemical structure.
Addressing the large number of PFAS using a class-based approach is appropriate given the growing body of scientific evidence suggesting that concerns for health and the environment identified for well-studied PFAS are more broadly applicable to other PFAS, and the expectation that combined exposures to multiple PFAS will increase the likelihood of harmful impacts.
Risk managing the class of PFAS, as opposed to using a substance-by-substance approach, addresses potential cumulative effects of co-exposure to multiple PFAS and reduces the chance of regrettable substitution; that is, substituting regulated PFAS with unregulated PFAS that potentially possess similar hazardous properties. A phased approach to risk management is being considered as outlined in the Preventive actions and risk reduction section below.
Some other jurisdictions around the world are exploring various approaches to addressing PFAS as a class, including the European Union and some states within the United States.
Human and ecological exposures
People living in Canada can be exposed to PFAS from various sources such as food and food packaging, cosmetics, products available to consumers, ambient air, indoor air and dust, and drinking water.
PFAS is found nearly everywhere in the environment, including in air, surface and groundwater, oceans and soils as well as in wastewater, landfill leachate, sewage sludge and contaminated sites worldwide. Some PFAS and their precursors can be transported long distances either in the air or in water.
PFAS contamination is present throughout Canada, including in remote areas such as the Arctic, and is not limited to a few sources and areas.
Certain contaminated sites have elevated concentrations of PFAS, including those associated with the use of AFFFs through fighting hydrocarbon fuel fires, training activities and maintenance of firefighting equipment.
Key health and ecological effects (hazard)
Exposure to PFAS can affect multiple human organs and systems. The main targets include the liver, kidney, thyroid, immune system, nervous system, metabolism and bodyweight, and reproduction and development. Effects on these organs and systems have been observed in both laboratory and human epidemiological studies with well-studied PFAS.
In the environment, effects of PFAS on wildlife include toxicity to the immune and nervous systems, and general effects on growth, reproduction and development. Several well-studied PFAS have been found to bioaccumulate in living organisms. PFAS have been reported to significantly biomagnify (accumulate to increasingly higher levels up the food chain) in air-breathing organisms (for example, mammals, birds), which may increase the likelihood of adverse effects being seen. Certain PFAS have also been shown to have hazardous effects on plants.
Humans and the environment are exposed to multiple PFAS at the same time. This cumulative exposure could increase the potential for adverse effects.
Consideration of subpopulations who may have greater susceptibility or greater exposure
There are groups of individuals within the Canadian population who, due to greater susceptibility or greater exposure, may be more vulnerable to experiencing adverse health effects from exposure to substances.
A number of subpopulations were identified as having a potential for greater exposure to PFAS. Some Northern Indigenous communities (as measured in adults, including pregnant women), Indigenous youth and children in other parts of Canada, and firefighters internationally were found to have higher levels of certain PFAS in blood than in national biomonitoring surveys. Canadian firefighters and people living near sites contaminated with PFAS (for example, sites associated with the use of AFFFs for firefighting) may also be disproportionately exposed to higher levels of PFAS.
Report findings
The Updated Draft State of PFAS Report focuses on information to support a proposed conclusion on whether the substances are harmful to human health or the environment under CEPA. This was done by examining scientific information, including information, if available, on subpopulations who may have greater susceptibility or greater exposure, and cumulative effects, and by incorporating a weight of evidence approach and precaution.
The broad use of PFAS, their ability to move locally and over long ranges, and their presence throughout the environment have resulted in continuous environmental and human exposure to multiple PFAS. Exposure to PFAS has the potential to cause effects on multiple systems and organs in both humans and wildlife.
It has been shown that certain PFAS may bioaccumulate and biomagnify in food webs to an extent that can cause adverse effects in biota, even at low environmental concentrations.
Recent information on well-studied PFAS, particularly perfluorooctanoic acid (PFOA) and perfluorooctane sulfonate (PFOS), shows negative effects on human health at lower levels than indicated by previous studies.
Environmental concentrations and uptake by biota will increase in the absence of intervention due to the extreme persistence of PFAS, their potential for bioaccumulation in organisms and biomagnification through the food chain, and the impossibility of their removal from the broader environment.
The potential for cumulative exposure and effects are important considerations as most wildlife and human exposures involve an unknown mixture of PFAS.
Proposed conclusions
Owing to the extreme persistence of PFAS and their potential for adverse effects, impacts on the environment are expected to increase if entry to the environment continues.
Despite uncertainties, owing to the widespread use of PFAS along with their presence throughout the environment, humans are continuously exposed to multiple PFAS, which have the potential to cause adverse effects of concern.
On the basis of what is known about well-studied PFAS and the potential for other PFAS to behave similarly, and on the expectation that combined exposures to multiple PFAS increase the likelihood of harmful impacts:
the Government is proposing to conclude that the class of PFAS, excluding fluoropolymers as defined in the Updated Draft State of PFAS Report, is entering or may enter the environment at levels that are harmful or may be harmful to the environment, and
the Government is also proposing to conclude that the class of PFAS, excluding fluoropolymers as defined in the Updated Draft State of PFAS Report, is entering or may enter the environment at levels that are harmful or may be harmful to human health.
Well-studied PFAS meet the persistence criteria as set out in the Persistence and Bioaccumulation Regulations of CEPA. Based on available information and structural similarities, it is expected that other substances within the class of PFAS are also highly persistent or transform to persistent PFAS. It is therefore proposed that the class of PFAS meets the persistence criteria as set out in the Persistence and Bioaccumulation Regulations of CEPA.
There is a high concern identified for the biomagnification and trophic magnification potential of well-studied PFAS in air-breathing organisms. However, the numeric criteria for bioaccumulation, outlined in the Persistence and Bioaccumulation Regulations, are based on bioaccumulation data for freshwater aquatic species, which do not account for biomagnification potential. Therefore, application of the criteria would not reflect the concern for dietary-based biomagnification, the primary route of foodweb exposure identified for well-studied PFAS. It is therefore proposed that the bioaccumulation potential of PFAS cannot reasonably be determined according to the regulatory criteria set out in the Persistence and Bioaccumulation Regulations of CEPA.
Existing risk management
Several PFAS are subject to risk management controls in Canada, including the following:
As a result of previous assessments under CEPA and conclusions of harm to the environment, PFOS and its salts and precursors, PFOA and its salts and precursors, and long-chain perfluorocarboxylic acids (LC-PFCAs) and their salts and precursors are listed on Schedule 1 to CEPA.
Other domestic activities that target certain PFAS include:
In 2024, Health Canada published the Objective for Canadian drinking water quality – Per- and polyfluoroalkyl substances that recommends a single treatment-based value for a group of PFAS in Canadian drinking water. The objective, based on the sum of 25 specific PFAS, serves to reduce potential exposure to PFAS through drinking water while the reassessment of the guidelines and screening values is being completed.
Federal Environmental Quality Guidelines for PFOS in surface water for the protection of aquatic life, fish tissue, wildlife diet for mammalian and avian consumers of aquatic biota, and in bird eggs. The development of guidelines for PFOA is currently underway.
In May 2023, the Canadian Food Inspection Agency (CFIA) proposed an interim standard for PFAS in biosolids as part of the Government's coordinated suite of risk mitigation measures intended to minimize human and environmental exposure to PFAS. The CFIA will continue to engage with the provinces, municipalities, and the biosolids industry to implement the interim standard for PFAS in biosolids imported or sold in Canada as fertilizers.
The Government of Canada works with other governments internationally on initiatives that address PFAS, including through the OECD and the Stockholm Convention on Persistent Organic Pollutants. Canada has successfully nominated LC-PFCAs, their salts and related compounds for addition to the Stockholm Convention.
Preventive actions and risk reduction
If the proposed conclusions are confirmed in the final State of PFAS Report, the Government will consider proposing to add the class of PFAS, excluding fluoropolymers as defined in the Updated Draft State of PFAS Report, to Part 2 of Schedule 1 to CEPA. Adding a substance to Schedule 1 does not, in itself, restrict its use, manufacture or import. Rather, it enables the Government to take enforceable risk management actions under CEPA.
Toxic substances that pose the highest risk (that is, meet certain criteria) are added to Part 1 of Schedule 1. These are prioritized for total, partial or conditional prohibition.
Other toxic substances are added to Part 2 of Schedule 1 and are prioritized for pollution prevention.
Regulations specifying criteria for the classification of substances that pose the highest risk or that are carcinogenic, mutagenic or toxic to reproduction will be developed. When criteria are available, some substances considered for addition to Part 2 of Schedule 1 may instead be considered for addition to Part 1 of Schedule 1.
Publication of the Revised Risk Management Scope aims to inform interested parties of proposed risk management options and initiate discussion about their development. To address the potential concerns for human health and the environment from the class of PFAS, excluding fluoropolymers as defined in the Updated Draft State of PFAS report, the Government is considering:
As a first step, a regulatory instrument under CEPA to restrict PFAS not currently regulated in firefighting foams; and
Additional regulatory instrument(s) under CEPA to prohibit other uses or sectors in relation to PFAS. Prioritization for prohibition may be based on factors such as socio-economic considerations, the availability of feasible alternatives, and the potential for human and environmental exposure.
In addition, other ongoing actions on PFAS will continue, such as the development of drinking water guidelines and environmental quality guidelines, the management of contaminated sites, and the continued administration of existing risk management actions outlined above. Furthermore, voluntary risk management actions are also being considered as described in the Revised Risk Management Scope document.
The development of risk management instruments will be informed by information gathering and will take into consideration international alignment, availability of potential alternatives, and the potential need for exemptions.
Risk management options may evolve through consideration of assessments and risk management options or actions published for other substances. This is to ensure effective, coordinated, and consistent risk management decision-making.
Use the Substances Search tool to find substances that are referenced in certain legislative or regulatory instruments or on Government of Canada websites.
In May 2023, Environment and Climate Change Canada published the 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 (C4 – C7) Perfluorocarboxylic Acids (SC-PFCAs); Short-chain (C4 – C7) Perfluorosulfonic Acids (SC-PFSAs); and Long-chain (C9 – C20) Perfluorosulfonic Acids (LC-PFSAs). Some of these substances are being used as substitutes for previously assessed PFAS that are now subject to restrictions.
Assessments conducted under CEPA focus on risks of exposure of the general population. Hazards related to chemicals used in the workplace are defined within the Workplace Hazardous Materials Information System (WHMIS). If a substance is harmful to the general population, it could also be of concern for individuals in situations where a higher volume of the substance is used or where the substance is used for a longer duration (for example, the workplace). The Government of Canada recognizes that it is the responsibility of the federal, provincial and territorial occupational health and safety organizations to coordinate legislation for the safe use of chemicals in the workplace. We are working to support this role by integrating the information, tools, and/or technical expertise of the CMP and Health Canada's Workplace Hazardous Products Program.
