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The Government of Canada has taken a significant step toward addressing the risks posed by per- and polyfluoroalkyl substances (PFAS), commonly known as “forever chemicals.” On September 26, 2025, Environment and Climate Change Canada launched a consultation on Phase 1 of its PFAS Risk Management Plan. This phase focuses on firefighting foams that remain one of the largest sources of contamination.

Why PFAS Are a Concern

PFAS are synthetic chemicals valued for their resistance to heat, oil, and water. However, these same properties make them extremely persistent in the environment. Exposure to PFAS has been linked to negative health impacts, including liver and kidney damage, thyroid dysfunction, immune suppression, and developmental issues. In wildlife, PFAS have been shown to harm reproduction, growth, and immune functions, threatening ecosystems and biodiversity.

Phase 1: Focus on Firefighting Foams

The first phase of the government’s action plan specifically targets aqueous film-forming foams (AFFFs), which are widely used in civil and military aviation, shipping, and the petroleum and chemical sectors. While these foams are highly effective at extinguishing flammable liquid fires, they are also a major source of PFAS pollution in drinking water and soil. Canada’s proposed measures aim to eliminate the remaining unregulated uses of these foams while promoting the adoption of safer alternatives.

A Multi-Phase Risk Management Strategy

Canada is implementing a three-phase approach to reduce PFAS risks.

●      Phase 1: Address PFAS in firefighting foams not yet covered by regulations.

●      Phase 2: Restrict PFAS in non-essential uses, particularly in consumer products.

●      Phase 3: Assess critical uses of PFAS where no viable alternatives exist, with the goal of identifying safe substitutes in the long term.

This class-based approach ensures that one harmful PFAS is not simply replaced by another with similar toxic properties.

Regulatory Framework Under CEPA

The risk management measures are being developed under the Canadian Environmental Protection Act, 1999 (CEPA). By adding PFAS (excluding fluoropolymers) to Schedule 1, Part 2, the government can regulate the entire class of chemicals. Canada already restricts several PFAS through the Prohibition of Certain Toxic Substances Regulations, and new updates proposed in 2022 aim to further tighten controls, including the phase-out of C8 AFFF foams with limited exemptions for critical applications.

Government Position

According to Julie Dabrusin, the Minister of Environment and Climate Change, the proposed phase-out will prevent future contamination and drive the transition to effective alternatives. Marjorie Michel, the Minister of Health, emphasized that these actions are necessary to protect Canadians today and for future generations.

Public Consultation and Next Steps

The consultation on Phase 1 is open until November 25, 2025. Feedback from industry, civil society, and the public will guide the development of new regulations. Once finalized, these measures will significantly reduce PFAS releases into the environment and encourage the shift toward safer firefighting technologies.

zThe Government of Canada has released an update on the Phosphoric Acid Derivatives Group, a set of substances assessed under the Chemicals Management Plan (CMP). The latest publication provides the final conclusions for three priority substances, outlining their potential health and environmental impacts, as well as the regulatory actions being taken under the Canadian Environmental Protection Act, 1999 (CEPA).

The Phosphoric Acid Derivatives assessment forms part of the third phase of the CMP, a federal program designed to systematically evaluate substances on the Domestic Substances List (DSL). While some substances from this group were determined to have minimal exposure and low risk, the targeted regulatory action on trixylyl phosphate ensures that future increases in exposure will be carefully managed.

Substances Under Review

The group includes six substances, with three undergoing a full screening assessment:

• Trixylyl phosphate (CAS RN 25155-23-1)
• Oleyl phosphate (CAS RN 37310-83-1)
• Phosphorous trichloride reaction products with 1,1-biphenyl and 2,4-bis(1,1-dimethylethyl)phenol (CAS RN 119345-01-6)

Regulatory Action on Trixylyl Phosphate

Although trixylyl phosphate is not currently considered harmful at existing exposure levels. However, it has been associated with potential reproductive system effects. Due to this concern, the government has taken a precautionary step by applying the Significant New Activity (SNAc) provisions of CEPA. This means that any proposed new manufacture, import, or use of trixylyl phosphate must be reported and evaluated by regulators before it can proceed.

Substances of Lower Concern

The assessment concluded that no immediate regulatory action is required for oleyl phosphate and the phosphorous trichloride reaction products. These substances are not expected to pose significant risks to health or the environment at current levels of use.

Timeline of Key Milestones

• July 13, 2019: Draft screening assessment published for public comment.
• December 19, 2020: The final screening assessment was released and the government announced its intent to apply SNAc provisions to trixylyl phosphate.
• March 26, 2025: The Canada Gazette publication officially amended the Domestic Substances List (DSL) to apply SNAc provisions to trixylyl phosphate.