Per- and polyfluoroalkyl substances (PFAS), excluding fluoropolymers, have been determined to meet the criteria outlined in paragraphs 64(a) and 64(c) of the Canadian Environmental Protection Act, 1999 (CEPA). This conclusion is based on evidence that these substances are entering, or may enter, the environment in quantities, concentrations, or conditions that could cause immediate or long-term harm to the environment or its biodiversity, and that may pose a risk to human health in Canada.
As part of its risk management strategy, CEPA has launched data collection efforts and implemented reporting requirements to gather further information on the PFAS class, including the following:

• Mandatory Data Collection: Notice under section 71 of CEPA, published on July 27, 2024, required reporting on certain PFAS by January 29, 2025. Extensions were available on request. (Is your Facility Prepared for federal PFAS Reporting in 2025?)
• NPRI Reporting: A final decision regarding the proposal to add 131 PFAS substances to the National Pollutant Release Inventory (NPRI) was made on March 8, 2025, pursuant to “Canada Gazette, Part I, Volume 159, Number 10: Supplement”.
• The other reporting requirements include, fume suppressants reporting, food monitoring, product surveillance, pesticide review and contaminated sites tracking.

Impact on NPRI Reporting:

ECCC has added 131 PFAS substances to the NPRI by creating a new group called Group C under Part 1 of the inventory. These substances were selected based on the following criteria, established in consultation with stakeholders:

• PFAS for which Canadian or international guidelines exist;
• PFAS that have been detected in Canadian biomonitoring by Health Canada (HC) or in the Canadian environment by ECCC;
• PFAS that have been reported to the US Toxic Release Inventory (TRI); and 
• PFAS that have been identified by stakeholders as being a priority.

The list includes both polymeric and non-polymeric PFAS, including substances like PFOS, PFOA, and certain long-chain PFCAs that are already regulated in Canada. Of the 131 substances, 30 appear on the Domestic Substances List (DSL), 11 on the Non-Domestic Substances List (NDSL), and 42 are partially restricted under the Prohibition of Certain Toxic Substances Regulations (PCTSR). Additionally, 18 are included in the mandatory PFAS survey under section 71 of CEPA (July 2024), and 34 have associated Canadian or international guidelines or standards.

Reporting Requirements and Threshold:

PFAS are known to be used in small quantities at small concentrations and given the health and environmental concerns associated with PFAS, ECCC is proposing low manufacture, process or otherwise use (MPO) thresholds:

• 1 kg manufactured, processed or otherwise used, which applies to each PFAS individually. This will be the lowest MPO threshold of any substance listed on NPRI with MPO thresholds;
• 0.1% concentration by weight. The concentration threshold does not apply to substances that are incidentally manufactured, processed, or otherwise used (i.e., by-products)
• The current employee threshold of 20,000 hours or more, or 10 full-time employees equivalent is still applicable.

If the above-mentioned thresholds apply, then the facility will be required to report quantities of that PFAS that are released, disposed of and recycled.
Some examples of few exceptions include processing or otherwise using manufacturing items (articles) containing NPRI substances where no release of the substance occurs; wholesale or retail sale of the substance or articles that contain the substance; and exploration of oil or gas or drilling of oil and gas wells.
The NPRI reporting requirements for PFAS could affect facilities across all sectors in Canada. PFAS are widely used in various industries and found in many everyday products, such as firefighting foams (like AFFF), textiles (carpets, clothing, furniture), cosmetics, and food packaging. They also serve as solvents, processing aids, oil- and water-repellents, and additives in paints, inks, adhesives, and refrigerants. PFAS releases from landfills, incinerators, composting of packaging, and wastewater treatment systems—including biosolids sent off-site—may also need to be reported.
Below are examples of substances found across the lists mentioned above.DSL: Acetic acid, trifluoro- (CAS # 76-05-1), Alcohols, C8-14, γ-ω-perfluoro (CAS RN # 68391-08-2)NDSL: Perfluorobutanoate (CAS # 45048-62-2), Perfluoropentanoic acid (CAS # 2706-90-3)PCTSR: Methyl perfluorooctanoate (CAS # 376-27-2), Perfluorodecanoic acid (CAS # 335-76-2)s71: Acetic acid, trifluoro- (CAS # 76-05-1), Phosphinic acid, bis(perfluoro-C6 12-alkyl) derivs. (CAS RN 68412-69-1)

What does this mean for me?

Let’s consider an industry that uses PFAS-containing solvents for degreasing operations in 2025. If the NPRI mass threshold for manufactured, processed, or otherwise used (MPO) PFAS is met, the facility must report releases to air, water, and land as applicable, along with details on on-site and off-site recycling and/or disposal.
In this scenario, the PFAS substance is used as an ancillary material, not as part of the core chemical processing.

Given the NPRI reporting requirements, facilities should begin gathering information on how PFAS is used within their processes, for example, whether it is used as a reactant, a formulation component, or for other functions. It is equally important to determine the end-of-life treatment of the MPO PFAS, such as whether it is disposed of, treated, or sent for recycling. Gathering this information proactively rather than delaying until the next reporting cycle can help ensure compliance and avoid data gaps. In other words, even though the PFAS NPRI reporting is only due in June 2026, subject facilities should be putting a data collection mechanism in place now in 2025, so they are better prepared to handle this reporting next year. 

Please reach out to Varshini Padmanabhan in Trinity’s Toronto office or call 416.391.2527 for assistance with reporting PFAS under NPRI for the 2025 reporting year.