[Public Comment] Prohibition of the use of per- and polyfluoroalkyl substances, excluding fluoropolymers, in firefighting foams in Canada

November 25, 2025

The Government of Canada published a Consultation Document on September 26, 2025. A 60-day comment period ending on November 25, 2025, follows this publication.

Comments received on the Risk Management Scope, the Revised Risk Management Scope and the Risk Management Approach for per- and polyfluoroalkyl substances (PFAS) will be considered during the development of risk management activities and do not need to be resubmitted.

Firefighting foams containing PFAS are designed to extinguish Class B fires during emergencies. These fires include those involving flammable and combustible liquids, petroleum greases, tars, oils and gasoline, solvents, and alcohols. PFAS-based surfactants help to cut off the oxygen from the fire. It does that by contributing to form a foam blanket and a water film that glides over the surface of the burning liquid.

Aqueous film-forming foam (AFFF) is the most used and available of these foams. For this reason, PFAS-containing firefighting foams are often referred to as AFFF.

Canada regulates two of the three categories of AFFF, “PFOS-based AFFF” and “C8 AFFF,” with some exemptions. The last remaining category of AFFF is "C6 AFFF.” It refers to foams that are based on subgroups of PFAS that are not yet regulated.

On March 8, 2025, the Government of Canada published the State of PFAS Report. This Report concluded that the class of PFAS, excluding fluoropolymers, is toxic under the Canadian Environmental Protection Act, 1999 (CEPA). The Government also published an associated Risk Management Approach for PFAS, excluding fluoropolymers. It outlines the proposed risk management actions under consideration through phased prohibitions.

The consultation document on Phase 1 intends to:

inform interested parties and solicit comments on the proposed regulatory approach. The approach is to prohibit the manufacture, import, use and sale of PFAS, excluding fluoropolymers, not currently regulated in firefighting foams. The Government is considering transitional periods.
solicit comments regarding concentration thresholds for the incidental presence of PFAS in Class B firefighting foams. The Government is considering different thresholds for foams contaminated by firefighting systems that have undergone cleaning.

The development of proposed regulatory instruments will consider comments received.

Join in: How to participate

You are invited to review and submit your comments on the consultation document.

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

Send an email with your ideas or comments to make yourself heard using the contact information below.

Please include “Consultation Document on Phase 1 of the Risk Management of PFAS” in the subject line of your email.

By mail

Send a letter with your ideas and input to the address in the contact information below.

Please include “Consultation Document on Phase 1 of the Risk Management of PFAS” in the subject line of your letter.