Canada Plans to Ban PFAS in Cosmetics

Background

Canada follows the OECD (2021) definition of PFAS, which refers to “fluorinated substances containing at least one fully fluorinated methyl or methylene carbon atom (without any attached H/Cl/Br/I atoms).”In other words, with a few specific exceptions, any chemical that includes a perfluorinated methyl group (–CF3) or a perfluorinated methylene group (–CF2–) is classified as a PFAS.

In Canada, three PFAS subgroups—PFOS, PFOA, and LC-PFCAs, along with their salts and precursors—are regulated under the Prohibition of Certain Toxic Substances Regulations, 2012 (PCTSR). The manufacture, use, sale, offering for sale, and import of these substances, as well as products containing them, are banned, with only a few exemptions. Cosmetics are not included in these exemptions, meaning the use of these three PFAS subgroups in cosmetics is prohibited. As for other PFAS, there are currently no specific regulations governing their use in the Canadian cosmetics industry.

In March 2025, Environment and Climate Change Canada (ECCC) and Health Canada jointly released the State of Per- and Polyfluoroalkyl Substances (PFAS) Report and the PFAS Risk Management Approach.

Under the Approach, Canada plans to classify most PFAS as toxic substances and implement phased restrictions across multiple industries. Companies and individuals are encouraged to provide information to support scientific decision-making.

The phased restrictions are outlined in the table below. Among them, Phase 2 specifically targets a ban on PFAS (excluding fluoropolymers) in cosmetics and natural health products, etc.

Table 1: Proposed phases of prohibition for the class of PFAS, excluding fluoropolymers, with example of uses/products that would be managed

Phase	Estimated Dates for Risk Management Actions	Target	Product Examples
Phase 1	Consultation: Summer/Fall 2025 Proposed Regulation: Spring 2027	Prohibition of the use of PFAS (excluding fluoropolymers) not currently regulated in firefighting foams	PFAS-containing firefighting foams and PFAS fire-suppressing agents
Phase 2	Consultation to follow the publication of proposed Phase 1 Regulations: 2027	Prohibition of the uses of PFAS (excluding fluoropolymers) not needed for the protection of health, safety or the environment, with a particular focus on consumer applications where alternatives are known to exist	Cosmetics Natural health products and non-prescription drugs Food packaging materials, food additives, non-industrial food contact products such as paper plates, bowls and cups Paint and coating, adhesive and sealant and other building materials available to consumers Consumer mixtures such as cleaning products, waxes and polishes Textile uses (including in personal protective equipment such as firefighting turnout gear) Ski waxes
Phase 3	To be determined	Prohibition of the uses of PFAS (excluding fluoropolymers) for which currently there may not be feasible alternatives and requiring further evaluation of the role of PFAS	Fluorinated gas applications such as spray-foam insulation and refrigeration Prescription drugs (human and veterinary) Medical devices Industrial food contact materials Industrial sectors such as mining and petroleum Transport and military applications

ChemLinked Comments

ChemLinked recommends that stakeholders:

Assess product compliance: Immediately determine whether their products contain PFAS and confirm their applicability under Canada’s new PFAS regulations;
Explore alternatives: Identify and prepare substitutes, especially for high-risk applications, to ensure compliance in advance;
Engage in policy discussions: Actively participate in public consultations and provide relevant data to support informed regulatory decisions.

Webinar Recommendation

ChemLinked invited an experienced regulatory affairs consultant, Marina Bishop from CE.way, to explain requirements on exporting OTC cosmetic products to the USA and Canada. This session will cover essential regulatory requirements, market insights, and other vital considerations. By the end of this webinar, regulatory professionals and organisations will have a better understanding of the regulatory landscape surrounding OTC products in both USA and Canada and will gain valuable insights into how to export OTC cosmetic products successfully.

Canada Plans to Ban PFAS in Cosmetics

Background

ChemLinked Comments

Further Reading

Webinar Recommendation