Blog by: John Jackson, Citizens’ Network on Waste Management and Fe de Leon, Canadian Environmental Law Association
John and Fe were members of the NPRI PFAS sub-group, which was created under the NPRI Work Group to provide advice to NPRI office of Environment and Climate Change Canada on a plan to report PFAS in NPRI.
This is the second blog in a series about Canada’s recent decision to add per- and polyfluoroalkyl substances (PFAS) to the National Pollutant Release Inventory (NPRI), Canada’s main pollution registry. In the first entry, we stressed why it was so important to require reporting on PFAS to the NPRI.
In this commentary, we’ll discuss the main strength of the Canadian NPRI system, i.e., the wide range of facilities that must report to NPRI. This is important because PFAS is used in a wide-range of types of facilities. We’ll also present two main weaknesses of the NPRI reporting system for PFAS that the government released in March 2025 (Canada Gazette Notice published March 8 2025).
Good: Who Must Report
Those who must report PFAS to NPRI are broadly inclusive. This is a major strength of Canada’s NPRI reporting system.
PFAS chemicals are everywhere. To support reporting on PFAS substances to the NPRI, Environment and Climate Change Canada (ECCC) prepared a Draft Guidance document in February, 2025 which outlines where ECCC expects PFAS to be found and requires reporting on them in each facility type: firefighting foams; textiles, upholstery, leather, apparel, and carpet manufacturing; manufacturing of transportation vehicles; oil and gas production; mining; paper production and recycling; wastewater facilities; and landfills.
The NPRI Draft Guidance states that the facilities who should report PFAS “include but are not limited to” the categories just stated.
The strengths and weaknesses of reporting requirements for PFAS substances in NPRI has a substantial impact on the community right to know. Additional effort is needed to expand the scope of PFAS reporting in the short term and improve the reporting thresholds that exist for these substances and the NPRI program so we can truly gather more comprehensive data that captures information from a wider range of sources.
This will be discussed in the following section of this blog as we focus on two main issues: 1) which PFAS must be reported on, and 2) the reporting criteria for PFAS to NPRI.
Not-So-Good: Which PFAS must be reported on
The government now requires the reporting of 163 PFAS substances to NPRI. Given that the class of PFAS includes over 15,000 substances, reporting on the releases and transfers of only 163 PFAS substances [approximately 1 percent of the total] represents a very modest, although important, start to Canada’s efforts to understand and help communities across the country understand who releases and transfers PFAS substances to the Canadian environment.
In the U.S., PFAS substances are reported under the Toxics Release Inventory, which is a comparable program to Canada’s NPRI, and lists 204 PFAS substances relying on a regulatory decision mechanism to automatically add PFAS substances for reporting. The U.S. has steadily added PFAS substances since reporting began in 2020. Canada’s list covers 35% of the U.S. list (72 of 204 PFAS substances will be reported in the NPRI).
NPRI does not include some key PFAS substances. One missing subgroup of PFAS are fluoropolymers, used extensively in many industrial applications. According to the government “fluoropolymers were not intentionally excluded from NPRI consideration. The four selection criteria… coincidentally screened out any fluoropolymers.” The absence of fluoropolymers under the NPRI is a significant gap in our knowledge of releases and transfer of PFAS to the Canadian environment.
This knowledge gap is likely to substantially increase because timelines for adding PFAS substances to NPRI are uncertain and the Canadian government approach will rely on reviewing initial reporting data before any consideration is given to adding more PFAS substances. As the number of PFAS substances in the Canadian market grows and shifts based on availability and regulatory measures taken on well studied PFAS, Canada will miss the opportunity to assess how new PFAS may be replacing other PFAS and their presence in Canada. Public pressure may be needed to prompt this effort. We must move to reporting on all PFAS and seeking transparency on the full class of PFAS.
Not-so-Good: Reporting Threshold for NPRI
In assessing the appropriateness of thresholds for reporting, it is essential to consider the characteristics of the substance. These characteristics were discussed in the earlier blog in this series, in the section entitled “Why do we need to know more about PFAS releases and transfers in Canada”.
The NPRI thresholds set for PFAS require that a facility must report that manufactures, processes, or otherwise uses 1 kilogram or more of that PFAS during the year at a concentration of 0.1% by weight.
While this is potentially a strong threshold, it has two serious flaws.
The threshold applies to each type of PFAS individually. This means that a facility could be using almost 1 kg for several or even many of the 163 PFAS that must be reported to NPRI and not have to report that they are releasing any PFAS. Also, the 0.1% concentration threshold means that substantial PFAS may be used over a year but none reported.
In the U.S., the concentration threshold for PFAS was eliminated because too few facilities were reporting. Canada’s threshold for manufactured, processed or otherwise used can leave a community with the seriously misleading impression that no PFAS are being used in their community, even though significant amounts may have been released.
A standard threshold in Canada’s NPRI for facilities to have to report is if “employees work at the facility for 20,000 hours per year.” This is the equivalent to 10 full-time employees. PFAS usage is very widespread among the industrial sectors and is frequently used in small facilities This means that there could be several small operations in a neighbourhood or community that are using PFAS but are exempted from reporting to NPRI because of the employee threshold. Again, a community could be misled into thinking that PFAS are not a threat to be explored in their community, when the cumulative impact of releases from several small facilities could all be ignored. To avoid this problem, the employee threshold should be removed from the PFAS NPRI requirements.
Conclusion
Reporting on PFAS substances under the NPRI adds to a community’s right-to-know but additional work will be needed if NPRI is to give us an even better understanding of how much, and where, PFAS is being released or transferred across Canada. In general, concerns respecting the use of current reporting thresholds for the majority of NPRI-listed pollutants has been raised . A substantive review on the appropriateness and rigour of thresholds for NPRI pollutants is overdue. The reporting of PFAS under NPRI is another example of why the reporting thresholds under NPRI should be reviewed.
Blog: The Good and Not-so-Good of PFAS Reporting under Canada’s Community Right to Know Pollution Inventory
Blog by: John Jackson, Citizens’ Network on Waste Management and Fe de Leon, Canadian Environmental Law Association
John and Fe were members of the NPRI PFAS sub-group, which was created under the NPRI Work Group to provide advice to NPRI office of Environment and Climate Change Canada on a plan to report PFAS in NPRI.
This is the second blog in a series about Canada’s recent decision to add per- and polyfluoroalkyl substances (PFAS) to the National Pollutant Release Inventory (NPRI), Canada’s main pollution registry. In the first entry, we stressed why it was so important to require reporting on PFAS to the NPRI.
In this commentary, we’ll discuss the main strength of the Canadian NPRI system, i.e., the wide range of facilities that must report to NPRI. This is important because PFAS is used in a wide-range of types of facilities. We’ll also present two main weaknesses of the NPRI reporting system for PFAS that the government released in March 2025 (Canada Gazette Notice published March 8 2025).
Good: Who Must Report
Those who must report PFAS to NPRI are broadly inclusive. This is a major strength of Canada’s NPRI reporting system.
PFAS chemicals are everywhere. To support reporting on PFAS substances to the NPRI, Environment and Climate Change Canada (ECCC) prepared a Draft Guidance document in February, 2025 which outlines where ECCC expects PFAS to be found and requires reporting on them in each facility type: firefighting foams; textiles, upholstery, leather, apparel, and carpet manufacturing; manufacturing of transportation vehicles; oil and gas production; mining; paper production and recycling; wastewater facilities; and landfills.
The NPRI Draft Guidance states that the facilities who should report PFAS “include but are not limited to” the categories just stated.
The strengths and weaknesses of reporting requirements for PFAS substances in NPRI has a substantial impact on the community right to know. Additional effort is needed to expand the scope of PFAS reporting in the short term and improve the reporting thresholds that exist for these substances and the NPRI program so we can truly gather more comprehensive data that captures information from a wider range of sources.
This will be discussed in the following section of this blog as we focus on two main issues: 1) which PFAS must be reported on, and 2) the reporting criteria for PFAS to NPRI.
Not-So-Good: Which PFAS must be reported on
The government now requires the reporting of 163 PFAS substances to NPRI. Given that the class of PFAS includes over 15,000 substances, reporting on the releases and transfers of only 163 PFAS substances [approximately 1 percent of the total] represents a very modest, although important, start to Canada’s efforts to understand and help communities across the country understand who releases and transfers PFAS substances to the Canadian environment.
In the U.S., PFAS substances are reported under the Toxics Release Inventory, which is a comparable program to Canada’s NPRI, and lists 204 PFAS substances relying on a regulatory decision mechanism to automatically add PFAS substances for reporting. The U.S. has steadily added PFAS substances since reporting began in 2020. Canada’s list covers 35% of the U.S. list (72 of 204 PFAS substances will be reported in the NPRI).
NPRI does not include some key PFAS substances. One missing subgroup of PFAS are fluoropolymers, used extensively in many industrial applications. According to the government “fluoropolymers were not intentionally excluded from NPRI consideration. The four selection criteria… coincidentally screened out any fluoropolymers.” The absence of fluoropolymers under the NPRI is a significant gap in our knowledge of releases and transfer of PFAS to the Canadian environment.
This knowledge gap is likely to substantially increase because timelines for adding PFAS substances to NPRI are uncertain and the Canadian government approach will rely on reviewing initial reporting data before any consideration is given to adding more PFAS substances. As the number of PFAS substances in the Canadian market grows and shifts based on availability and regulatory measures taken on well studied PFAS, Canada will miss the opportunity to assess how new PFAS may be replacing other PFAS and their presence in Canada. Public pressure may be needed to prompt this effort. We must move to reporting on all PFAS and seeking transparency on the full class of PFAS.
Not-so-Good: Reporting Threshold for NPRI
In assessing the appropriateness of thresholds for reporting, it is essential to consider the characteristics of the substance. These characteristics were discussed in the earlier blog in this series, in the section entitled “Why do we need to know more about PFAS releases and transfers in Canada”.
The NPRI thresholds set for PFAS require that a facility must report that manufactures, processes, or otherwise uses 1 kilogram or more of that PFAS during the year at a concentration of 0.1% by weight.
While this is potentially a strong threshold, it has two serious flaws.
The threshold applies to each type of PFAS individually. This means that a facility could be using almost 1 kg for several or even many of the 163 PFAS that must be reported to NPRI and not have to report that they are releasing any PFAS. Also, the 0.1% concentration threshold means that substantial PFAS may be used over a year but none reported.
In the U.S., the concentration threshold for PFAS was eliminated because too few facilities were reporting. Canada’s threshold for manufactured, processed or otherwise used can leave a community with the seriously misleading impression that no PFAS are being used in their community, even though significant amounts may have been released.
A standard threshold in Canada’s NPRI for facilities to have to report is if “employees work at the facility for 20,000 hours per year.” This is the equivalent to 10 full-time employees. PFAS usage is very widespread among the industrial sectors and is frequently used in small facilities This means that there could be several small operations in a neighbourhood or community that are using PFAS but are exempted from reporting to NPRI because of the employee threshold. Again, a community could be misled into thinking that PFAS are not a threat to be explored in their community, when the cumulative impact of releases from several small facilities could all be ignored. To avoid this problem, the employee threshold should be removed from the PFAS NPRI requirements.
Conclusion
Reporting on PFAS substances under the NPRI adds to a community’s right-to-know but additional work will be needed if NPRI is to give us an even better understanding of how much, and where, PFAS is being released or transferred across Canada. In general, concerns respecting the use of current reporting thresholds for the majority of NPRI-listed pollutants has been raised . A substantive review on the appropriateness and rigour of thresholds for NPRI pollutants is overdue. The reporting of PFAS under NPRI is another example of why the reporting thresholds under NPRI should be reviewed.
Share: