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Consultation Document on Phase 1 of the Risk Management of Per- and Polyfluoroalkyl Substances (PFAS), Excluding Fluoropolymers: Prohibition of the Use of PFAS, not Currently Regulated, in Firefighting Foams

Executive summary

The State of Per- and Polyfluoroalkyl Substances (PFAS) Report concluded that the class of PFAS, excluding fluoropolymers as defined in the State of PFAS Report, meets one or more of the criteria set out in section 64 of the Canadian Environmental Protection Act, 1999 (CEPA).

Perfluorooctane sulfonate (PFOS), perfluorooctanoic acid (PFOA), and long-chain perfluorocarboxylic acids (LC-PFCAs), along with their salts and their precursors, were previously assessed and are regulated under the Prohibition of Certain Toxic Substances Regulations, 2012. Substances within the scope of this consultation document are therefore, referred to as “PFAS, not currently regulated.”

Based on the conclusions of the State of PFAS Report, the Government published a Risk Management Approach for PFAS excluding fluoropolymers. This proposed a three-phase prohibition approach under CEPA. This consultation document focuses on Phase 1. Consultations on subsequent phases will follow, with consultations on Phase 2 anticipated in 2027.

The main purpose of this consultation document is to inform interested parties and solicit comments on the proposed regulatory approach to prohibit the manufacture, import, use and sale of PFAS in firefighting foams for those PFAS that are not already regulated. It also aims to invite comments about concentration thresholds for the incidental presence of PFAS in Class B firefighting foams being sold and those contaminated by PFAS that originate from and are present in firefighting systems that have undergone decontamination. Comments will be considered in the development of proposed regulations.

1. Background

Per- and polyfluoroalkyl substances (PFAS) are a class of thousands of human-made substances. The common chemical structure of PFAS is their perfluoroalkyl moiety, which is extremely stable in the environment. PFAS are used in many industrial sectors and in a wide range of products, including certain firefighting foams.

On March 8, 2025, the State of PFAS Report published by Environment and Climate Change Canada (ECCC) and Health Canada (HC) concluded that the class of PFAS, excluding fluoropolymers as defined in the report, meets the criterion under paragraph 64(a) of CEPA as these substances are entering or may enter the environment in a quantity or concentration or under conditions that have or may have immediate or long-term harmful effects on the environment or its biological diversity. The Report also concluded that these substances meet the criterion under paragraph 64(c) of CEPA as these substances are entering or may enter the environment in a quantity or concentration or under conditions that constitute or may constitute a danger in Canada to human life or health (ECCC, HC 2025a).

The State of PFAS Report uses the Organisation for Economic Co-operation and Development (OECD) (2021) definition of the class of PFAS, which is “fluorinated substances that contain at least 1 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–).” Fluoropolymers are defined in the State of PFAS Report as polymers made by polymerization or copolymerization of olefinic monomers (at least one of which contains fluorine bonded to one or both of the olefinic carbon atoms) to form a carbon-only polymer backbone with fluorine atoms directly bonded to it. Fluoropolymers as defined in the State of PFAS Report are, therefore, referred to as “fluoropolymers” in this document.

On March 8, 2025, a Notice indicating the measures that the Minister of the Environment and the Minister of Health (the Ministers) propose to take and summarizing the scientific considerations of the State of PFAS Report (the Notice) was published under subsection 77(6) of CEPA (Canada 2025a). The Notice communicates the Ministers’ intention to recommend that the class of PFAS, excluding fluoropolymers, be added to Part 2 of Schedule 1 to CEPA. It also explains the Ministers’ proposal to use a phased approach to regulate the class of PFAS, excluding fluoropolymers, under CEPA, to prohibit the use of PFAS, not currently regulated, in firefighting foams and other uses and sectors.

Also on March 8, 2025, the proposed Order adding the class of PFAS, excluding fluoropolymers, to Part 2 of Schedule 1 to CEPA (the proposed Order) was published for a 60-day public comment period that ended on May 7, 2025 (Canada 2025b). All comments received during the public comment period on the proposed Order will be taken into consideration in finalizing the Order.

Adding a substance to Schedule 1 does not, in itself, restrict the use, manufacture or import of the substance. Rather, it enables the Ministers to develop risk management instruments under CEPA. Risk management on the class of PFAS would only be put in place if the Order is finalized.

CEPA requires that a risk management instrument be proposed within a specific timeline. Once a substance is proposed for addition to Schedule 1, the Ministers must: 

As such, a Risk Management Approach for per- and polyfluoroalkyl substances (PFAS), excluding fluoropolymers, (ECCC, HC 2025b) was also published on March 8, 2025, for a 60-day public comment period that ended on May 7, 2025. It outlines the three-phased approach being considered (see section 3.2). Consultations are planned throughout the development of risk management actions in each phase, starting with this consultation document on Phase 1.

Under Phase 1 of the proposed risk management actions, the Government of Canada is proposing to prohibit the manufacture, use, sale and import of PFAS, not currently regulated under CEPA, in firefighting foams, such as C6 AFFF, through new regulations. This consultation document outlines that proposal and seeks comments to inform the development of a risk management instrument.

The design of proposed risk management instruments will strive to minimize administrative burden while protecting human health and the environment. This includes aligning requirement with other key jurisdictions wherever possible, keeping reporting requirements to those that are essential for effective administration, ensuring decision-making and processes are clear and streamlined, enabling innovation and alternative methods where feasible, and leveraging modern tools and innovative process solutions.

1.1 PFAS-containing firefighting foams

PFAS-containing firefighting foams are designed to extinguish Class B firesFootnote 1  during emergencies. Class B fires are those involving flammable and combustible liquids, petroleum greases, tars, oils and gasoline, solvents, and alcohols. PFAS surfactants in these foams help to cut off the oxygen from the fire by contributing to the formation of a foam blanket and, more notably, a water film that glides over the surface of the burning liquid.

Aqueous film-forming foams (AFFF) are the most widely used and available of these foams and, for this reason, PFAS-containing firefighting foams are often interchangeably referred to as AFFF, including in this document. There are, however, other types of PFAS-containing firefighting foams with slightly different compositions used in specialized applications, such as alcohol-resistant AFFF (AR-AFFF) for polar solvents, or film-forming fluoroprotein foam (FFFP) and fluoroprotein foam (FP) for an added burn back resistance for deeper pool fires.

AFFF are frequently divided into three general categories depending on the type of compounds and/or composition profile in PFAS surfactants they contain (ITRC 2023, ECHA 2022), including in this document:

It is not always easy to determine the type of PFAS an AFFF contains. PFAS may be listed as a proprietary ingredient or a trade secret on safety data sheets (SDS). For example, a 2018 Eurofeu survey among five foam manufacturers representing 60%-70% of the European Union (EU) market found that three non-polymeric PFAS compounds that accounted for an 87% share of the EU firefighting foam concentrate market were not known due to confidentiality claims (Wood-Ramboll-Cowi 2020). PFAS may also be present in concentrations too low to meet the SDS reporting requirements. Some details on AFFF surfactant structures, suppliers and product names, as well as some Chemical Abstracts Service Registry Numbers (CAS RNs), can be found in the literature.Footnote 3 Foam manufacturers can be contacted to determine the type of PFAS an AFFF contains.

AFFF are not known to be manufactured in Canada but are imported. Most major firefighting foam manufacturers in the United States of America (U.S.) and Europe stopped producing C8 AFFF by 2016 in response to voluntary actions on long-chain PFAS compounds in Canada and the U.S. (U.S. EPA 2010, ECCC 2010). Most of them have also either stopped production of C6 AFFF or are in the process of stopping due to growing concerns associated with the class of PFAS (Chubb 2023).

1.2 Use context of Class B firefighting foams

Storing, handling and processing hazardous products invariably carries a risk of fire―or, in certain cases, explosion―with threats to life, the environment, assets or business continuity. It is therefore crucial that those involved with these products have access to firefighting tools with adequate performance to manage those risks.

For decades, AFFF have been the gold standard for extinguishing hazardous liquid fuel fires (ITRC 2023). They are mainly used in civil and military aviation and in the chemical and petroleum industries. They are also used to respond to fires aboard ships, at shore facilities and in other industrial settings that use hazardous products. Some municipal fire services may also use this type of firefighting foam when helping to put out fires at facilities in the previously mentioned sectors.

Depending on the use context and firefighting system design, releases of firefighting foams can be containable or uncontainable (OECD 2021). Containment capacities significantly impact the magnitude of PFAS released into the environment associated with the use, storage and environmentally sound disposal of PFAS-containing firefighting foams and wastes associated with their uses. In the past, AFFF were widely used for training purposes in settings where they were uncontainable, but they are progressively being replaced by training foams that do not contain PFAS surfactants (DND 2023, ITRC 2023). Some applications of AFFF are periodically tested to ensure they will operate correctly in emergencies. These tests may release PFAS into the environment if appropriate containment and disposal practices are not implemented.

Fluorine-free alternatives, such as fluorine-free foams (F3) (occasionally referred to as synthetic fluorine-free foam [SFFF]), are currently available for many uses. Despite this, substitution is not occurring or is limited in some cases with some citing a combination of barriers, such as being mandated to use PFAS-containing firefighting foam by many international and domestic organizations (further details are provided in the following subsections), not knowing the type of firefighting foams that they are being sold, the long shelf life of these foams, concerns associated with the current effectiveness of fluorine-free alternatives, and the cost and technical challenges of implementing a transition (ECHA 2022). In other cases, the substitution to fluorine-free alternatives has been gaining momentum as more effective foam formulations are becoming available. In explaining their adoption of or desire to adopt these alternatives, some cite a combination of fluorine-free alternatives being suitable for their needs, having lower maintenance costs, the divestment of firefighting foam manufacturers from PFAS and not having to handle substances with known environmental and human health hazard concerns (ECHA 2023, Secord 2022). Despite the slow adoption of fluorine-free alternatives, various international and domestic organizations have been advancing the adoption of fluorine-free alternatives over the past few years.

1.2.1 Aviation

PFAS-containing firefighting foams are mostly used in aviation aircraft rescue firefighting (ARFF) operations on mobile firefighting trucks (airport crash trucks) and in fixed fire suppression systems within aircraft hangars.

In civil aviation, the Canadian Aviation Regulations (CARs) require airports, aerodromes, and heliports to use extinguishing agents that meet certain performance specifications. For example, paragraph 323.08(1)(a) of Standard 323 to CARs (Transport Canada 2007a) requires that the firefighting foams being used in aircraft firefighting at airports and aerodromes meet the latest performance specifications of the Underwriters Laboratory of Canada (ULC) CAN/ULC-S560 or CAN/ULC-S563 on the date acquired. Paragraph 325.47(2)(a) of Standard 325 of CARs (Transport Canada 2007b) similarly requires that the firefighting foams at heliports comply with the performance specifications of CAN/ULC-S560.

Since 2019, Transport Canada has issued a series of time-limited exemptions to the above provisions of the CARs to allow Canadian airports and heliports to elect transitioning to an F3 that is currently available on the market, such as those that meet the performance specifications of the International Civil Aviation Organization (ICAO)Footnote 4  (Transport Canada 2025). In 2021, Billy Bishop Toronto City Airport was the first airport operator in North America to transition to F3 (Hubert et al. 2021).

In addition, ULC developed in 2022 the standard CAN/ULC-563:2022 for high-performance and aviation synthetic F3 liquid concentrates (ULC 2022) used in aircraft firefighting at airports and aerodromes. As of the publication of this document, no fluorine-free product has been certified as per this standard (UL 2025).

1.2.2 Military

In the military, AFFF are used by the Department of National Defence (DND) in aviation for ARFF operations on crash trucks and in hangars, as well as aboard ships (such as engine rooms and helicopter decks). Since 2020, DND has been voluntarily working on transitioning from all PFAS-containing firefighting foams towards PFAS-free alternatives that are approved for military applications (DND 2024). Alternatives need to meet multiple requirements to allow for this transition. These requirements include departmental, national and international standards for the military, which are in place to help ensure interoperability with Canada’s allies (Van Tine 2022).

In military aviation, the requirements for firefighting foams used in aviation aircraft rescue firefighting that DND must adhere to are standardized by the U.S. Department of Defense (U.S. DoD) Military Standard (MIL-SPEC). The U.S. DoD published the MIL-PRF-32725 military specifications in early 2023 to enable the development of F3 liquid concentrates that meet DoD’s fire extinguishing performance standards for land-based and freshwater applications (U.S. DoD 2024a). Qualified products under these specifications are not intended for use on polar solvents or on-board military ships. A few F3 have been tested by the U.S. DoD, and five of them are currently listed on the qualified products list for these specifications (QLP-32725) as of the publication of this document (U.S. DoD 2025a).

1.2.3 Shipboard and shore facilities

AFFF are also used aboard civilian ships, as well as at port authorities. Typical civilian marine shipboard applications for AFFF include oil and chemical tankers and specialized firefighting vessels which might be, for example, support vessels for offshore operations (such as the coast guard) or tugboats at ports handling flammable and combustible liquids. The requirements for such applications tend to be driven by prescriptive international rules and practices, including from the International Maritime Organization (IMO) and Oil Companies International Marine Forum (OCIMF) (ACAP 2023). It is usually impractical to try and contain the foam discharge in marine application and so they are often released immediately into the environment.

1.2.4 High-hazard industries

Some industrial applications often involve the use, storage, handling, processing and production of sufficiently large quantities of highly combustible and flammable or explosive hazardous products to constitute a significant risk of Class B fire (LASTFire 2025). Fires at high-hazard facilities have the potential to cause a serious risk to human life, public safety or property. Some examples of industries that deal with large quantities of these substances at numerous steps along their supply chains include the petroleum industry―for example, in fuel storage facilities (such as large atmospheric storage tanks (LAST) and tank farms), refineries, oil production facilities (such as oil wells), shore facilities (such as oil port terminals), offshore facilities (such as oil rigs) and oil and gas transportation (such as oil tankers and shuttle tankers)―and the chemical industry―for example, in chemical production and chemical storage facilities. Other industries may also use large quantities of these substances in one or a few processes in their supply chain—for example, the use of hexane in the oilseed processing industry (NOPA 2023).

The National Fire Code of Canada (NFCC) is a national model code that establishes minimum acceptable measures in terms of fire safety, health and fire protection of buildings and facilities, including acceptable solutions to manage the risk of flammable and combustible liquids in buildings and structures (NRC 2020). These can be adopted, expanded and implemented by provincial and territorial governments as part of their respective fire safety legislation. The NFCC contains a few non-Canadian standards that have been reviewed by the relevant standing committees and found to be acceptable, including those in the U.S. National Fire Protection Association (NFPA) such as NFPA 11 - Standard for Low-, Medium-, and High-Expansion Foam, and NFPA 30 - Flammable and Combustible Liquids Code. These NFPA standards that address foam suppression focus mainly on hardware and do not stipulate which type of foams can or should be used. As such, little has changed so far in these relevant standards in relation to the transition to F3, other than adding information about the new foams in its annex (Roman 2022). In addition, to date, nothing has been identified to suggest that F3 cannot be made to work for all required scenarios that have been conventionally managed by AFFF but there is still work to be done to optimize their performance (FRI 2023).

1.2.5 Municipal fire services

Municipal fire services are known to primarily use AFFF as part of mutual aid agreements. These agreements allow emergency responders to lend assistance across their jurisdictional boundaries. For example, municipalities or townships neighbouring an airport may agree to provide personnel and other resources, such as firefighting foams, during emergencies at airports or at fuel storage facilities.

1.3 Considerations for the reuse of firefighting systems

PFAS can be found as contaminants left over in firefighting suppression systems because of past uses of foams containing these substances, even after thorough cleaning. These contaminants are known to be slowly released from the surfaces of equipment over time. This type of contamination is known as "rebound." While rebound is difficult to eliminate, it is important to limit it by using a suitable decontamination method that only leaves trace levels of PFAS to limit the quantities of these substances that are released in the environment.

2. Relevant international risk management

Controls and bans of AFFF are increasing in multiple jurisdictions globally, in particular in the U.S. and in a number of countries, like Canada, that are Parties to the Stockholm Convention on Persistent Organic Pollutants (POPs) (Stockholm Convention), such as the United Kingdom, Australia, New Zealand and member states of the EU.Footnote 5

2.1 Stockholm Convention on Persistent Organic Pollutants (POPs)

The Stockholm Convention aims to protect human health and the environment from substances that are of global concern. POPs listed to the Stockholm Convention are persistent, bioaccumulative, undergo long-range transport, and lead to significant adverse human health and/or environmental effects. The Stockholm Convention requires Parties to eliminate or severely restrict the production, use, import, and export of intentionally produced POPs and to implement measures to reduce unintentionally produced POPs. In addition, stockpiles and wastes containing POPs must be managed and disposed of in an environmentally sound manner.

The Stockholm Convention has assessed and listed four subgroups of PFAS POPs, which are PFOS, its salts, and perfluorooctane sulfonyl fluoride (PFOSF) in 2009; perfluorooctanoic acid (PFOA), its salts, and PFOA-related compounds in 2019; perfluorohexanesulfonic acid (PFHxS)Footnote 6 , its salts, and PFHxS-related compounds in 2022; and long-chain perfluorocarboxylic acids (LC-PFCAs), their salts and related compounds in 2025.

The listing of PFOA, its salts, and PFOA-related compounds contains a specific exemption for the use of firefighting foams containing these substances for liquid fuel vapour suppression and liquid fuel fires (Class B fires) in installed systems, including both mobile and fixed systems, under certain conditions. This listing is an important driver for the phase-out of the use of C8 AFFF in countries that are Parties to the Stockholm Convention. The listing requires to avoid the use of these firefighting foams for training purposes, or for testing, unless all releases are contained. It also includes language for Parties to the Stockholm Convention to restrict the use of firefighting foams that contain or may contain these substances to sites where all releases can be contained.

2.2 European Union

Restrictions are currently in place in the EU for PFOS, PFOA and PFHxS, their salts and related compounds under the EU POPs regulation (European Commission 2019). In addition, since February 2023, the EU has restrictions under the EU Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH) regulation (European Commission 2006) on perfluorocarboxylic acids (PFCAs) (C9-C14), their salts and their related compounds (European Commission 2021) and will start restricting undecafluorohexanoic acid (PFHxA) (C6)Footnote 7 , its salts and PFHxA-related substances under the same regulation starting in April 2026 (ECHA 2024). In addition, the restrictions in place in the EU for these subgroups of PFAS include concentration limits when present in other substances, mixtures or articles below which they are considered unintentional trace contaminants, and the restrictions do not apply (see section 2.2.3).

In October 2020, the European Commission published a plan entitled “Chemical Strategy for Sustainability Towards a Toxic-Free Environment” (European Commission 2020), which outlined their intent to ban the class of PFAS in firefighting foams as well as in other uses, allowing their use only where they are essential for society. This objective is based upon the large number of cases of contamination of soil and water, including drinking water, the unacceptable risks to both the environment and human health, and the related societal and economic costs.

The EU REACH regulation allows EU member states exemptions from this regulation in specific cases where necessary in the interests of defence. There is no similar provision in the EU POPs regulation.

2.2.1 AFFF containing PFHxA, its salts and PFHxA-related substances

In September 2024, the European Commission amended the EU REACH regulation to regulate PFHxA, its salts and PFHxA-related substances in phases.

Starting on April 10, 2026, the EU REACH regulation will ban the placing on the market and use of PFHxA, its salts and PFHxA-related substances in firefighting foams and concentrates above certain concentration limits:

Starting on October 10, 2029, the EU REACH regulation will ban the placing on the market and use of these substances in firefighting foams and firefighting foam concentrates for civil aviation (including in civilian airports).

2.2.2 Class-based approach for other PFASFootnote 8 in AFFF

In November 2024, the European Commission published a draft regulation amending the EU REACH regulation (European Commission 2024) to restrict the placing on the market and the use of AFFF using a class-based approach. This approach follows the recommendations provided in the European Chemicals Agency’s restriction dossier and the opinions of its scientific committees (ECHA 2023). In April 2025, EU member states have voted in favour of the European Commission’s draft regulation (European Commission 2025a, Denmark 2025), which was adopted in August 2025 following scrutiny by the European Parliament and European Council. The regulation is anticipated to be published in the Official Journal of the European Union before the end of 2025 and to enter into force twenty days after that (European Commission 2025b).

These regulatory actions would lead to a complete phase-out in the use of PFAS in firefighting foams, including of C6 AFFF. If approved, the draft regulation would ban the placing on the market and use of PFAS not currently restricted in the EU in firefighting foams above certain concentration limits for all PFAS. It includes use/sector-specific transitional periods from the entry into force, so that the transition to alternatives would not compromise fire safety.

Table 1. Transitional periods by type of use or sector that were proposed by the EU for its restriction proposal

 Use/sector Transitional period(s)
(a) Training and testing 18 months, provided that all releases are contained
(b) Public fire services and private fire services exercising the function of public fire services (e.g., municipal fire services) 18 months (There is, however, a 10-year transitional period for these fire services to intervene in industrial fires at Seveso establishments.Footnote 9 )
(c) Portable fire extinguishers
  • 12 months for the placing on the market
  • until December 31, 2030, for the use
(d) Alcohol resistant portable fire extinguishers
  • 18 months for the placing on the market
  • until December 31, 2030, for the use
(e) Other industries 5 years
(f) Civilian aviation 5 years
(g) Civilian ships already in service at the entry into force* 10 years
(h) Defence (military vessels and other applications)* 10 years
(i) Installations belonging to the offshore oil and gas industry* 10 years
(j) Seveso establishments (except civil aviation)* 10 years

* The use/sector-specific transitional periods (g) to (j) must be reviewed by the European Commission before their expiry and could be modified.

Seveso establishments under the use/sector-specific transitional period (j) are facilities covered by the EU Seveso-III Directive on major-accident hazards (European Commission 2012). For an establishment to qualify as such, a large quantity of a dangerous substance above specified thresholds (in tonnes) must be present in one or more installationsFootnote 10 . Dangerous substances are those that are either named or that are covered by a listed hazard category in Part 1 or listed in Part 2 of Annex I to the directive. The higher the risk to humans and/or the environment, the lower the qualifying threshold is. For example, the thresholds for dangerous substances under the flammable liquids hazard categoriesFootnote 11 are reduced from 5,000 to 10 tonnes correspondingly to the decrease of their flash points and boiling points, as well as the hazard associated with their conditions of uses (that is, temperature and pressure). However, petroleum products and alternative fuelsFootnote 12  are named dangerous substances with a qualifying threshold of 2,500 tonnes.

In addition, the draft regulation requires AFFF users, except users of portable fire extinguishers, to follow best practices to ensure appropriate use, to reduce emissions to the environment and direct and indirect human exposure, to ensure proper containment and disposal. To guarantee the implementation of these best practices, the draft regulation requires the establishment, within 12 months of the coming into force, of a site-specific management plan for use/sector transitional periods (e) to (j), which needs to be reviewed every year and be kept available for at least 15 years for inspection. The site-specific management plan must include:

The draft regulation also includes labelling requirements, beginning 12 months after the coming into force, for the placing on the market of AFFF, excluding PFAS-containing portable fire extinguishers, as well as on utilized AFFF, stock of not-utilized AFFF, and any PFAS-containing wastewater. The label must warn of the presence of PFAS and that they are present in a concentration equal to or greater than 1 mg/L for the sum of all PFAS.

2.2.3 Maximum concentration limits

The restrictions established in or proposed by the EU are accompanied by maximum concentration limits at or below which the restrictions do not apply.

Table 2. Summary of the maximum concentration limits established in or proposed by the EU for PFAS in firefighting foams

PFAS Maximum concentration limits
PFOS, its salts and related compoundsFootnote 13
  • 0.025 mg/kg (0.0000025 % w/w) for the sum of PFOS or any of its salts
  • 1 mg/kg (0.0001 % w/w) for the sum of PFOS-related compounds
PFHxS, its salts and related compounds
  • 0.025 mg/kg (0.0000025 % w/w) for the sum of PFHxS or any of its salts
  • 1 mg/kg (0.0001 % w/w) for the sum of PFHxS-related compounds
PFHxA, its salts and related substances
  • 25 ppb for the sum of PFHxA and its salts
  • 1,000 ppb for the sum of PFHxA-related substances
PFOA, its salts and related compounds
  • 0.025 mg/kg (0.0000025 % w/w) for the sum of PFOA or any of its salts
  • 1 mg/kg (0.0001 % w/w) for the sum of PFOA-related compounds
  • When they are present in firefighting foam for liquid fuel vapour suppression and liquid fuel fire (Class B fires) already installed in systems:
    • 1 mg/kg (0,0001 % w/w) of PFOA or any of its salts until August 3, 2028
    • 10 mg/kg (0,001 % w/w) of any individual PFOA-related compound or combination of PFOA-related compounds until August 3, 2028
  • When they are present in fluorine-free firefighting foam and originate from firefighting equipment which has undergone cleaning in accordance with the best available techniques:
    • 10 mg/kg (0,001 % w/w) for the sum of the concentration of PFOA, its salts and PFOA-related compounds
PFCAs (C9-C14), their salts and related substances
  • 25 ppb for the sum of C9-C14 PFCAs and their salts
  • 260 ppb for the sum of C9-C14 PFCA-related substances
All PFAS
  • 1 mg/L for the sum of all PFAS
  • 50 mg/L for the sum of all PFAS in fluorine-free firefighting foams originating from equipment which has undergone cleaning in accordance with best available techniques, excluding portable fire extinguishers. (This limit is accompanied by a 5-year review clause at the latest)

The EU’s class-based draft regulation for PFAS-containing firefighting foams takes into consideration that newly installed F3 in existing firefighting systems may contain PFAS residues that remain in the equipment even after cleaning in accordance with best available techniques. It sets a maximum concentration limit of 50 mg/L for the sum of all PFAS in F3 originating from such equipment which used to contain AFFF and that has undergone cleaning in accordance with best available techniques. The intent of this higher limit is to avoid the unnecessary replacement of decontaminated firefighting foam equipment only because it has previously been used with AFFF. The EU expects PFAS in the contaminated F3 to progressively disappear in their entirety with time, as the firefighting foams and/or the equipment are replaced. The draft regulation requires the European Commission to review this higher limit within 5 years from entry into force of this Regulation in view of the developments on the measurement of the rebound effect and evolving cleaning methods for the equipment.

2.2.4 Member States

2.2.4.1 Denmark

Denmark was the first member state of the EU to implement restrictions on the class of PFAS. Since January 1, 2024, Denmark has banned the import and sale of AFFF for use with mobile systems at firefighting training grounds or drill sites if they contain more than 1 mg/kg of PFAS that are not already restricted at the EU level (Denmark 2023). Afterwards, the use of these concentrates at fire training grounds was banned six months later, on July 1, 2024.

2.3 United States of America

2.3.1 Federal

At the U.S. federal level, there are no broad phased prohibitions of the use of AFFF, but certain federal government departments and agencies are either required or were directed to transition to alternatives to AFFF.

In the military, the National Defense Authorization Act for Fiscal Year 2020 (NDAA 2020) requires that the U.S. DoD discontinues use of AFFF at its installations after October 1, 2024, with two allowable 1-year waiver requests possible that can postpone the deadline until October 1, 2026, excluding for shipboard use (U.S. 2020). In February 2024, the U.S DoD reported that it anticipates needing to extend some AFFF use at U.S. DoD installations to October 1, 2026. These extensions are required primarily due to the time it takes to transition systems from AFFF to fluorine-free alternatives without compromising missions or safety (GAO 2024). On August 2, 2024, the Secretary of Defense provided Congress with certification of a waiver and the prohibition of use of AFFF at military installations is now extended to October 1, 2025 (U.S. DoD 2024b). On July 31, 2025, the second and final waiver allowed under the NDAA 2020 was invoked, extending the deadline for compliance to October 1, 2026 (U.S. DoD 2025b). In its letter to Congress, the Secretary of Defense acknowledges challenges in transitioning to PFAS-free alternatives. The letter emphasizes that the waiver is necessary to maintain “operational availability of sufficient firefighting systems” and “ensure a safe transition of the U.S. DoD’s approximately 1,000 facilities and over 6,000 mobile assets.”

The U.S. DoD must use firefighting foams that meet the military specifications (MIL-SPEC) and that are certified as such and added to the Qualified Product List (QLP). Revisions made in 2017 to the MIL-F-24385 military specifications prevent the U.S. DoD to procure AFFF that contain more than 800 ppb (0.8 mg/kg) of PFOA and 800 ppb (0.8 mg/kg) of PFOS (U.S. DoD 2017). However, since October 1, 2023, the NDAA 2020 prevents the U.S. DoD from procuring firefighting foams that contain more than 1 ppb of PFAS (0.001 mg/kg). To support this transition, the U.S. DoD has developed implementation plans, timelines, and cost estimates for replacing AFFF in all land-based mobile assets and facilities worldwide (GAO 2024). For similar purposes, U.S. DoD has established the MIL-PRF-32725 military specifications for the development of a F3 allowing for PFAS-free alternatives that meet the U.S. DoD’s fire extinguishing performance standards to be purchased. In addition, the U.S. DoD is fostering and investing in research to improve F3 formulations, including in terms of firefighting performance or use with saltwater (SERDP 2025).

In civil aviation, operators of federally regulated airports are required by the U.S. Federal Aviation Administration (FAA) to use AFFF as part of their ARFF operations, unless otherwise authorized by the FAA (U.S. 2004, FAA 2023a). In May 2023, the FAA published a plan to ensure the orderly transition from current aircraft firefighting foam to a replacement firefighting foam without PFAS, as formally directed in December 2022 by the U.S. Congress through documentation accompanying the Consolidated Appropriations Act, 2023 (FAA 2023b). The FAA considers the foams on the U.S. DoD’s QLP as acceptable for satisfying its regulatory requirements for the certification of airports (FAA 2025).

In addition, given the ongoing use of AFFF in other areas of the U.S., the U.S. Environmental Protection Agency (U.S. EPA) has been encouraging AFFF users to adopt best practices to minimize releases of PFAS to the environment. Should it be required, the U.S. EPA can enforce the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) to hold known polluters accountable for PFAS contamination. In 2024, the U.S. EPA designated PFOA and PFOS as “hazardous substances” under CERCLA, which resulted in the addition of reporting requirements and the option of recovering costs associated with remediation (U.S. EPA 2024) by shifting the burden of CERCLA response from the trust fund held by the federal government to potentially responsible parties. These requirements help to make sure that legacy AFFF, such as C8 AFFF, are properly used, stored, handled, and disposed of by AFFF users. Any discharges to public waters of AFFF that contain PFAS other than PFOA or PFOS may be considered a release of a “pollutant or contaminant” under CERCLA, and therefore subject to remediation requirements (ITRC 2023).

2.3.2 States

At the state level, many states including Alaska, Arizona, Arkansas, California, Colorado, Connecticut, Georgia, Hawaii, Illinois, Indiana, Kentucky, Louisiana, Maine, Maryland, Michigan, Minnesota, Nevada, New Hampshire, New Jersey, New York, Rhode Island, Ohio, Vermont, Virginia, Washington, West Virginia, and Wisconsin have prohibitions on the use of firefighting foams containing any type of PFAS (Safer States 2024, State of Arkansas 2021, State of Ohio 2022, Virginia 2019, West Virginia 2021). At the outset, all these states have focused on prohibiting the use of AFFF for training and/or testing purposes to ensure that releases of PFAS to the environment only occur during emergency uses. Some states have gone further by prohibiting the manufacture, use and sale of AFFF, but with some exemptions for uses required by federal law and in high-hazard industries. A few states require that discharges of AFFF be reported, and others require manufacturers selling firefighting foams and concentrates to disclose that they contain PFAS. One state requires that training on AFFF be provided to employees regarding the possible hazards, protective actions, and proper disposal. A few states are also implementing take-back programs to ensure proper disposal of AFFF (FSJA 2024).

2.3.2.1 State of Washington

In 2018, the State of Washington was the first state in the U.S. to take measures to restrict firefighting foams containing any substances of the class of PFAS that are intentionally added (Safer States 2024). These measures immediately banned the use of Class B firefighting foam that contains intentionally added PFAS chemicals for training purposes. They also provided 2-year transition periods before the entry into force of the ban on their manufacture, sale, offer for sale, distribution for sale and use, for uses required by federal law (such as federally regulated airports or the military), at fuel storage and distribution facilities (terminals), oil refineries, and chemical plants (Washington 2018). They include requirements for manufacturers to notify sellers and distributors of the banned products in writing, no less than 1 year prior to the ban. They also include requirements for manufacturers to recall the prohibited products and reimburse the retailers or any other purchasers for the product.

In 2020, the State of Washington amended these measures to include a time limit to the exemptions for uses at terminals, oil refineries, and chemical plants, to set them to end on January 1, 2024 (Washington 2020). In addition, the State of Washington chose to allow its Department of Ecology to grant eligible applicants up to two successive 2-year waivers that could extend their ability to use these foams up to January 1, 2028. To be eligible, applicants must provide:

In addition, a provision was added to confirm that an oil refinery or terminal can provide AFFF in the form of mutual aid to another refinery or terminal in the event of a Class B fire.

2.4 Other jurisdictions

2.4.1 United Kingdom

In the United Kingdom (UK), restrictions for industrial chemicals are generally evaluated and implemented under the UK REACH (HSE 2025a, UK EA 2024). In 2024, the Health and Safety Executive (HSE), the agency that administers the UK REACH, held a consultation to gather information and evidence for a restriction under the UK REACH for PFAS in firefighting foams (HSE 2024). On August 18, 2025, the HSE, in collaboration with the UK Environment Agency, published a proposed UK REACH Annex XV restriction dossier and supporting documents for a six-month public consultation period ending on February 18, 2026 (HSE 2025b). This proposal would broadly align the UK with the EU’s imminent measures and apply to Great Britain (GB; England, Scotland and Wales). As in the EU, the UK proposal includes extended transitional periods, granting a general five-year phase-out, but with specific getting shorter or longer transitions of 18 months or ten years. The HSE has announced that it will deliver its opinions on the proposed restriction within a year following publication of the proposal. The opinions will then be sent to the UK’s Department for Environment, Food and Rural Affairs (Defra), Scotland, and Wales who will decide on whether to restrict PFAS in firefighting foams.

2.4.2 Australia

Australia does not generally ban or restrict industrial chemicals at the federal level. Instead, the federal government creates, in co-operation with the states and territories, national standards by establishing framework legislation. National risk management actions can afterwards be implemented in each state and territory that has adopted the framework into their respective legislation. For example, most PFAS assessed and listed to the Stockholm Convention have been banned under the Industrial Chemicals Environmental Management Standard (IChEMS) framework since July 1, 2025, and prohibitions are effectively only implemented in the two states that have currently adopted this framework, that is Queensland and New South Wales (Australia 2024).

To date, broad phased prohibitions of the use of all AFFF have only been introduced at the state level. In 2016, Queensland was one of the first governments to ban PFAS use in firefighting foam (Queensland 2016). In 2018, South Australia banned PFAS-containing firefighting foams with a transition period, which ended in January 2020 (South Australia 2018). In 2022, New South Wales banned and restricted the use of PFAS firefighting foam in the state to reduce its impact on the environment, while still allowing its use for preventing or fighting catastrophic fires by relevant authorities and exempt entities (New South Wales 2021).

2.4.3 New Zealand

In New Zealand, the Fire Fighting Chemicals Group Standard 2021 prohibits the import, manufacture, use, storage and disposal of PFAS in firefighting foams, with some exemptions. The changes made to this group standard in 2021 require the phase-out of the use of C6 AFFF in emergencies by December 3, 2025. This phase-out date is the same as the phase-out of the use of C8 AFFF, which is currently still allowed for use in emergencies in contained firefighting systems. However, the phase-out of C6 AFFF includes permit provisions for the use of these foams after the transitional period, which may be granted on a case-by-case basis, subject to conditions ― such as the establishment of a management plan (New Zealand 2021).

3. Relevant domestic risk management for the class of PFAS, excluding fluoropolymers

3.1 Relevant existing risk management for the class of PFAS, excluding fluoropolymers

The Government of Canada has already acted on certain subgroups of PFAS that were determined to be toxic under CEPA. These include the following subgroups, which were added to Schedule 1 to CEPA and are currently regulated under the Prohibition of Certain Toxic Substances Regulations, 2012 (hereafter referred to as “PCTSR, 2012”):

These regulations are the main tool to implement Canada’s obligations for industrial chemicals under the Stockholm Convention, including for PFOA, LC-PFCAs, and PFOS, and their salts and their precursors.

In 2008, the Perfluorooctane Sulfonate and Its Salts and Certain Other Compounds Regulations (hereafter referred to as “PFOS regulations”) were published to prohibit the manufacture, import, sale, and use of PFOS, its salts and its precursors, with a limited number of exemptions to allow for the transition to alternatives. PFOS-based AFFF have been completely prohibited in Canada through the PFOS regulations since the end of 2013, although there are still a few exemptions to accommodate the presence of residual levels of PFOS that remain in firefighting systems from their prior use. PFOS, its salts and its precursors were added in 2016 to the PCTSR, 2012, which maintained the regulatory requirements of the PFOS regulations and removed certain exemptions (Canada 2016). As a result, the PFOS regulations were repealed.

C8 AFFFs are fluorotelomer-based AFFFs formulated with surfactants that include PFOA and/or LC-PFCAs, their salts and their precursors. The manufacture, use, sale, offer for sale, and import of PFOA, LC-PFCAs, their salts and their precursors, and products that contain them, have been prohibited since 2016 under the PCTSR, 2012, with a limited number of exemptions (Canada 2016). The manufacture of C8 AFFF is prohibited in Canada through the PCTSR, 2012, but its use, sale and import were exempted to accommodate the transition to alternatives.

On May 14, 2022, the Government of Canada published a draft proposed Prohibition of Certain Toxic Substances Regulations, 2022 (Canada 2022), which would repeal the current PCTSR, 2012 and would further restrict the use, sale and import of C8 AFFF and PFOS-based AFFF, by removing or providing time limits for most remaining exemptions. Comments and information were received in response to the proposed Regulations and have been taken into consideration in the development of the final Regulations. The Government of Canada is working towards publishing the final Regulations following the completion of the regulatory development process. The final Regulations would come into force six months after publication in the Canada Gazette, Part II. 

3.2 Next phases of risk management for the class of PFAS, excluding fluoropolymers

The Risk Management Approach for per- and polyfluoroalkyl substances (PFAS), excluding fluoropolymers, which was published at the same time as the State of PFAS Report, outlines the proposed environmental and human health objectives for the class of PFAS, excluding fluoropolymers, respectively, to:

The proposed risk management objective for the class of PFAS, excluding fluoropolymers, is to, over time, achieve the lowest levels of environmental and human exposure that are technically feasible, taking into consideration socio-economic factors. To address the concerns for human health and the environment from the class of PFAS, excluding fluoropolymers, the Government of Canada is proposing to take new risk management actions through phased prohibitions under CEPA.

Examples of the proposed uses to be regulated in Phase 2 and Phase 3 are provided in the risk management approach document.

The risk management actions for Phase 1 would lead to a complete phase-out of the use of PFAS in firefighting foams, including C6 AFFF. Fluoropolymers are not known to be used in firefighting foams.

4. Proposed Risk Management for Phase 1

4.1 Proposed prohibition of PFAS, excluding fluoropolymers, not currently regulated, in firefighting foams

Under this first phase of risk management action, the Government of Canada is proposing to prohibit the manufacture, use, sale and import of PFAS, excluding fluoropolymers, not currently regulated under CEPA (see section 3), in firefighting foams, such as C6 AFFF, through new regulations.

Time-limited exemptions to the prohibition are being considered only in exceptional circumstances—specifically to accommodate critical applications that cannot be immediately phased out. These decisions take into account relevant socio-economic factors, the demonstrated lack of suitable alternatives, environmental and human health risks, and the broader international and use context, including alignment with international practices where appropriate.

Should any exemptions or permit schemes be included under the new regulations, fixed time limits or specific conditions may be proposed and may be accompanied by reporting, record-keeping, monitoring, labelling, handling, storing, containment, disposal, and/or other requirements. These requirements would not apply to substances that are incidentally present at or below proposed concentration thresholds, as outlined in section 4.2.

Interested parties are encouraged to present relevant information to the Government of Canada through this consultation to inform the development of regulatory instruments. Please refer to section 6.1 for information on how to submit your comments.

4.1.1 Transitional periods

The time-limited exemptions starting from the coming into force that are outlined below are currently being considered to allow certain use/sector-specific applications in emergencies, so that the transition to alternatives would not compromise fire safety. These time-limited exemptions under consideration are intended to be in alignment with the transitional periods being established by the EU, that is, either by:

The new regulations are anticipated to come into force 6 months after their final publication in the Canada Gazette, Part ll (see section 6.2 for more information on the planned timeline for phase 1).

Table 3. Transitional periods by type of use or sector that are being proposed by the Government of Canada for its prohibition proposal

 Use/sector Transitional period(s)
(a) Portable fire extinguishers 18 months
(b) Municipal fire services 18 months
(c) Civilian aviation 3 years
(d) Other industries 3 years
(e) Civilian ships already in service at the coming into force 6 years
(f) Defence (military aviation, ships and other applications) 6 years
(g) Installations belonging to the offshore oil and gas industry 6 years
(h) Facilities in high-hazard industries 6 years

A prohibition on the use of these foams for training purposes is being considered as of the regulations' coming into force. No time-limited exemptions are also being considered for the manufacture or import of these foams. As such, these activities would be prohibited upon the regulations coming into force.

Similarly, no exemptions are being considered for their sale, except for sales between mutual aid partners.Footnote 19 The sales between mutual aid partners would only be permitted for the purpose of cost recovery following an authorized emergency use during one of the transitional periods. For example, a municipal fire service could use AFFF to assist a high-hazard industry facility during an emergency under a mutual aid agreement, for the duration of the transitional period for this facility and get reimbursed for the use of AFFF.

4.1.1.1 Facilities in high-hazard industries

The transitional period under consideration for facilities in high-hazard industries (item (h) of section 4.1.1) is intended to cover the facilities where large quantities of hazardous products are present—specifically flammable liquids,Footnote 20   chemicals under pressureFootnote 21  that are liquidsFootnote 22 , and petroleum products or alternative fuels. In other words, facilities that handle large amounts of dangerous flammable or pressurized liquids (above specific thresholds) may qualify for this transitional period.

To be covered under this transitional period, a facility must store these hazardous products at or above certain proposed qualifying thresholds outlined in table 4. The more hazardous the material, the lower the qualifying threshold for being included. These qualifying thresholds are based on the EU’s Seveso III directive, which sets standards for preventing major accidents involving hazardous substances.

If a facility does not have any one hazardous product that exceeds one of the qualifying thresholds on its own, a “weighted sum”Footnote 23 (basically a calculation combining multiple smaller quantities) will be used to determine if the facility as a whole still qualifies. The products are divided into four groups, each with its own threshold. The threshold for group 1 applies to the listed hazardous products. The thresholds for groups 2, 3 and 4 apply to flammable liquids and/or chemicals under pressure that are liquids as defined and classified in accordance with the Hazardous Products Regulations (HPR) (Canada 2015).

Table 4. Proposed qualifying thresholds for the transitional period (h) for facilities in high-hazard industries

Group Description Threshold (in metric tonnes)
1 Petroleum products and alternative fuels:
  1. Gasolines and naphthas
  2. Kerosenes (including jet fuels)
  3. Gas oils (including diesel fuels, home heating oils and gas oil blending streams)
  4. Heavy fuel oils
  5. Alternative fuels serving the same purposes and with similar properties as regard to flammability and environmental hazards as the products referred to in points (a) to (d)
 2,500
2
  • Flammable liquids in Category 1
  • Flammable liquids in Category 2 or 3 maintained at a temperature above their initial boiling points
 10
3
  • Chemicals under pressure that are liquids in Category 1
  • Chemicals under pressure that are liquids in Category 2 maintained at a temperature above their initial boiling points
 50
4
  • Flammable liquids in Category 2 or 3 not covered by the above groups
  • Chemicals under pressure that are liquids in Category 2 not covered by the above groups.
 5,000

4.1.2 Disclosure and labelling

Disclosure and labelling requirements regarding the presence of PFAS are being considered to support risk management actions by informing and warning users of their presence and to ensure that best practices are adopted where possible throughout the lifecycle to avoid releases to the environment and human exposure.

The Government is considering requiring that manufacturers and sellers of AFFF disclose in writing, to the extent possible, to anyone that has purchased an AFFF:

Manufacturers and sellers would be required to do so no later than 6 months after the coming into force of the regulations. These disclosure requirements are intended, in part, to align with those established in the State of Washington.

The Government is considering labelling requirements for AFFF in firefighting systems and in stocks, as well as any PFAS-containing wastewater and firewater.Footnote 25 These materials would be required to bear a label that warns of the presence of PFAS with a concentration equal to or greater than 1 mg/L for the sum of all PFAS, and indicate the category of AFFF27 (if applicable), no later than 18 months after the coming into force of the regulations. In addition, fluorine-free firefighting foams originating from a firefighting system which has undergone decontamination would be required to bear a label that warns of the presence of PFAS cross-contamination with a concentration equal to or lower than 50 mg/L for the sum of all PFAS. These labelling requirements are intended, in part, to be in alignment with those proposed by the EU.

4.1.3 Specific conditions, AFFF management plan and record-keeping

The Government is considering imposing specific conditions at the coming into force to ensure that PFAS in AFFF are managed appropriately through their life cycle to avoid releases to the environment and human exposure, such as requiring that:

  1. AFFF be only used during the transitional periods of section 4.1.1 for the suppression of fires involving flammable liquids (Class B fires) in an emergency or for testing firefighting systems
  2. measures be implemented to reduce emissions to the environment and direct and indirect human exposure to AFFF to as low a level as is technically and practically possible
  3. measures be implemented to ensure the collection of stock of not-utilized AFFF and containment of AFFF-related wastes (for example, PFAS-containing wastewater and firewater, and spent firefighting foam from firefighting systems testing), where technically and practically possible, and ensure their disposal in an environmentally sound manner

The Government is also considering requiring, no later than 18 months after the coming into force of the regulations, that facilities with AFFF in firefighting systems or in stock, AFFF-related waste in stock, or PFAS cross-contaminated firefighting equipment prepare a site-specific management plan that outlines relevant information and measures to prevent risk of releases to the environment and exposure to humans, including:

The Government is considering requiring that AFFF management plans and records be available on site in Canada and be ready to be provided to an enforcement officer during an inspection or provided upon written request from ECCC. The specific conditions, requirements for AFFF management plans and record keeping requirements are intended to be, in part, in alignment with those to be established by the EU.

4.1.4 Permits in specific circumstances

Time-limited permits are under consideration to allow the continued use of C6 AFFF in specific circumstances to protect human life and under specific conditions to protect the environment. Permits are being considered exclusively for large atmospheric storage tank (LAST) installations and for no longer than 4 years after the expiry of the 6-year transitional period at facilities in high-hazard industries. The permits would only allow the use of these C6 AFFF if all releases are fully contained on site and disposed of in an environmentally sound manner. They would be accompanied by specific conditions and requirements. To be eligible, it is being considered for applicants to provide, no more than 1 year prior to and at least 90 days before the expiry of the transitional period:

In addition, permits are accompanied with annual reporting requirements on the progress being made to transition to alternatives. These permits are intended to be, in part, in alignment with the ones in place in the State of Washington.

4.2 Proposed incidental presence concentration thresholds for PFAS

Through previous consultations, interested parties have generally requested that regulations on chemical substances under CEPA include measurable and feasible incidental presence maximum concentration thresholds that are harmonized with other jurisdictions. These limits help companies communicate clearly with their suppliers about what materials are acceptable and test materials more easily ― for example, when checking if old firefighting systems are clean after being decontaminated.

As such, and to align with other international jurisdictions, incidental presence thresholds, below which the prohibitions would not apply, are being considered for PFAS in firefighting foams.

The Government is considering for these incidental presence thresholds to be in alignment with those established in or proposed by the EU (see section 2.2.3). These thresholds would not apply to the physical possession or control of these substances being stored or held for final disposal.

5. Information gathering

Information was received on the transition from AFFF to alternatives in Canada as part of public comment periods, studies and stakeholder interactions which were part of the Government of Canada’s activities on the class of PFAS, as well as those under the regulatory changes to the PCTSR, 2012. The information received to date is under consideration for, and integrated into, the analysis and development of risk management actions for PFAS, not currently regulated, in firefighting foams.

In addition, in July 2024, a notice, authorized under section 71 of CEPA, with respect to certain PFAS was published in the Canada Gazette, Part l (Canada 2024). The notice gathered baseline data and will support analysis for future actions on the class of PFAS. ECCC anticipates that the relevance of the information collected will be limited for Phase 1 of the risk management actions because PFAS used in firefighting foams are often identified as proprietary ingredients or trade secrets on SDS.

In order to address remaining data gaps and understand any potential challenges faced by interested parties, ECCC is requesting, through this consultation document, the submission of information on activities related to firefighting foams that contain PFAS, excluding fluoropolymers, not currently regulated. In particular in relation to activities listed in sections 5.1, and/or 5.2 of the present document. ECCC is also requesting the submission of information on alternatives to these firefighting foams.

In addition, ECCC is also seeking feedback on proposed regulatory approach for Phase 1 outlined in section 4, and on whether to create new regulations specifically for the class of PFAS, or to add the class of PFAS to existing regulations, such as the PCTSR, 2012. Stakeholders are invited to share their views on the advantages and considerations of both options.

ECCC invites you to submit the information requested according to the procedure indicated in section 6. Next Steps.

5.1 The use and sale of Class B firefighting foams

ECCC requests information on the manufacture, import, use and/or sale of firefighting foams containing PFAS, excluding fluoropolymers, not currently regulated, (such as C6 AFFF), as well as their alternatives. Specific information is also requested by ECCC on the formulation of firefighting foams that may impact incidental presence concentration thresholds under consideration in section 4.2.

5.1.1 Information requested in relation to firefighting foams containing PFAS

The information requested includes:

5.1.2 Information requested in relation to alternatives

The information requested includes:

5.2 The reuse of decontaminated firefighting systems

ECCC requests information on the reuse of firefighting systems, in part or in whole, that contained PFAS-based firefighting foams—specifically, those firefighting systems that have undergone decontamination, but may still lead firefighting foam replacements to incidentally containFootnote 26  PFAS. Identifying appropriate incidental presence concentration thresholds would enable the reuse of firefighting systems as part of transition to alternatives, while minimizing release of PFAS into the environment to levels as low as technically and economically feasible.

5.2.1 Information requested

The information requested includes:

6. Next Steps for Phase 1

6.1 Comment Period

Comments on this consultation document or information to address data gaps must be submitted no later than November 25, 2025 to the contact information below.

Comments received will be taken into consideration in the drafting of the proposed regulations, which would be published in the Canada Gazette, Part l.

Pursuant to section 313 of CEPA, any person who provides information to the Minister of the Environment under CEPA may submit with the information a written request that it be treated as confidential. A request for confidentiality must indicate which specific information or data should be treated as confidential, and it must be submitted with reasons taking into account the criteria referred to in subsection 313(2) of CEPA.

Please address comments to the Chemicals Management Division with the subject line “Consultation Document on Phase 1 of the Risk Management of the class of PFAS.” Comments can be submitted by email (delivery method preferred) or mail.

Online:

Submit comments via ECCC’s Single Window. Once an account is created, click the Chemicals Management Plan link, then select Initiative “Chemicals Management – General”. Within the form, enter the publication name in the Submission Title field.  

By email: AFFF@ec.gc.ca

A confirmation email will be sent to those who submit their information and comments by email.
By mail:
Chemicals Management Division
Environment and Climate Change Canada
Place Vincent Massey 19th Floor
351 Saint-Joseph Boulevard
Gatineau (QC)
K1A 0H3

6.2 Planned timelines for Phase 1

The following planned timelines are subject to change and are dependent on the finalization of the proposed Order adding PFAS, excluding fluoropolymers, to Part 2 of Schedule 1 to CEPA:

Spring 2027

At the latest, 18 months after the proposed instrument

At the latest, 6 months after the publication of the final instrument

Therefore, the instrument is not anticipated to come into force before Spring 2029.

Interested parties for the risk management for PFAS as outlined in the Risk Management Approach for PFAS, excluding fluoropolymers are invited to subscribe to the risk management of the class of PFAS subscription service to be kept informed of future publications, information sessions and/or consultations.

For the most up-to-date information on the next steps for PFAS in AFFF, please consult the related section on Canada’s webpage on PFAS and AFFF used in firefighting.  

 

7. References

[ACAP] Arctic Contaminants Action Program (Arctic Council). 2023. AFFF Phase Out in the Arctic Transition Manual. By ENRg Consultants Ltd., London, United Kingdom.

Australia. 2024. Industrial Chemicals Environmental Management (Register) Act 2021: Industrial Chemicals Environmental Management (Register) Instrument 2022. (version F2025C00038 (C03)) Australian Government: Federal Register of Legislation.

Canada. 2015. Hazardous Products Act: Hazardous Products Regulations. Canada Gazette, Part Il. vol. 149, no. 3.

Canada. 2016. Canadian Environmental Protection Act, 1999: Regulations Amending the Prohibition of Certain Toxic Substances Regulations, 2012 (for the addition of 5 substances). Canada Gazette, Part lI, vol. 150, no. 20.

Canada. 2024. Canadian Environmental Protection Act, 1999: Notice with respect to certain per- and polyfluoroalkyl substances (PFAS). Canada Gazette, Part I. vol. 158, no. 30.

Canada. 2025a. Canadian Environmental Protection Act, 1999: Publication of the State of Per- and Polyfluoroalkyl Substances (PFAS) Report (section 77 of the Canadian Environmental Protection Act, 1999). Canada Gazette, Part I. vol. 159, no. 10.

Canada. 2025b. Canadian Environmental Protection Act, 1999: Proposed Order Adding a Toxic Substance to Part 2 of Schedule 1 to the Canadian Environmental Protection Act, 1999. Canada Gazette, Part I. vol. 159, no. 10.

Chubb Fire & Security Pty Ltd. 2023. Important Notice: Discontinuation of the C6 chemistry firefighting foam used in PEFS C6 vehicle fire suppression system. Rydalmere, Australia.

Denmark. 2023. Ministry to the Environment and Gender Equality. The Minister for the Environment bans PFAS in firefighting foam in Denmark. The Danish Government (available only in Danish).

Denmark. 2025. Ministry to the Environment and Gender Equality. Nu bliver PFAS i brandskum forbudt i hele EU. The Danish Government (available only in Danish).

[DND] Department of National Defence. 2020. National Defence: Defence energy and environment strategy : harnessing energy efficiency and sustainability: defence and the road to the future, 2020-2023. Ottawa (ON): Government of Canada.

[DND] Department of National Defence. 2023. National Defence: Statement from the Minister of National Defence on PFAS at CFB Bagotville. Saguenay (QC): Government of Canada.

[DND] Department of National Defence. 2024. National Defence: Greening Defence - Firefighting Foam Transition. Ottawa (ON): Government of Canada.

[ECCC] Environment and Climate Change Canada. 2010. Perfluorocarboxylic acids and their precursors : environmental performance agreement overview. Gatineau (QC): Government of Canada.

[ECCC, HC] Environment and Climate Change Canada, Health Canada. 2025a. State of Per- and polyfluoroalkyl substances (PFAS) Report. Ottawa (ON): Government of Canada.

[ECCC, HC] Environment and Climate Change Canada, Health Canada. 2025b. Risk Management Approach for Per- and polyfluoroalkyl substances (PFAS), excluding fluoropolymers. Ottawa (ON): Government of Canada.

[ECHA] European Chemicals Agency. 2022. The use of PFAS and fluorine-free alternatives in fire-fighting foams. By Wood Environment & Infrastructure Solutions UK Limited. London, United Kingdoms.

[ECHA] European Chemicals Agency. 2023. Registry of restriction intentions until outcome: Restricting the use of per- and polyfluoroalkyl substances (PFASs) in fire-fighting foams. Helsinki, Finland.

[ECHA] European Chemicals Agency. 2024. Commission Regulation (EU) 2024/2462 of 19 September 2024 amending Annex XVII to Regulation (EC) No 1907/2006 of the European Parliament and of the Council as regards undecafluorohexanoic acid (PFHxA), its salts and PFHxA-related substances. Helsinki, Finland.

European Commission. 2006. Regulation (EC) No 1907/2006 of the European Parliament and of the Council of 18 December 2006 concerning the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH), establishing a European Chemicals Agency, amending Directive 1999/45/EC and repealing Council Regulation (EEC) No 793/93 and Commission Regulation (EC) No 1488/94 as well as Council Directive 76/769/EEC and Commission Directives 91/155/EEC, 93/67/EEC, 93/105/EC and 2000/21/EC (Text with EEA relevance). Official Journal of the European Union.

European Commission. 2012. Directive 2012/18/EU of the European Parliament and of the Council of 4 July 2012 on the control of major-accident hazards involving dangerous substances, amending and subsequently repealing Council Directive 96/82/EC Text with EEA relevance. Official Journal of the European Union.

European Commission. 2019. Regulation (EU) 2019/1021 of the European Parliament and of the Council of 20 June 2019 on persistent organic pollutants (recast) (Text with EEA relevance). Official Journal of the European Union.

European Commission. 2020. Chemicals strategy for sustainability towards a toxic-free environment. Brussels, 14.10.2020. COM(2020) 667 final.

European Commission. 2021. Commission Regulation (EU) 2021/1297 of 4 August 2021 amending Annex XVII to Regulation (EC) No 1907/2006 of the European Parliament and of the Council as regards perfluorocarboxylic acids containing 9 to 14 carbon atoms in the chain (C9-C14 PFCAs), their salts and C9-C14 PFCA-related substances. Official Journal of the European Union. 282, 5.8.2021:29-32.

European Commission. 2024. Draft Commission Regulation amending Annex XVII to Regulation (EC) No 1907/2006 of the European Parliament and of the Council as regards per- and polyfluoroalkyl substances in firefighting foams. [As per notification G/TBT/N/EU/1098 to the World Trade Organization Technical Barriers to Trade]

European Commission. 2025a. Commission Regulation (EU) …/… of XXX amending Annex XVII to Regulation (EC) No 1907/2006 of the European Parliament and of the Council as regards per- and polyfluoroalkyl substances in firefighting foams. Brussels. Comitology Register. D102503/03.

European Commission. 2025b. EU Guidance for transitioning to Fluorine-Free Firefighting Foams. Brussels. Commission technical services.

[FAA] United States of America Federal Aviation Administration. 2023a. AC 150/5210-6, Aircraft Fire Extinguishing Agents. Washington (D.C.): United States of America Department of Transportation.

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