"PFAS-free" is appearing on more Canadian retail procurement checklists every quarter — often before buyers can point to a law that actually requires it. That gap creates confusion: is PFAS banned in Canadian food packaging, or not? The honest answer is that a federal ban is coming in stages and is not yet in force for packaging — but PFAS-free has already become a buying gate, driven by retailers, US regulation, and Canada's tightened greenwashing rules. Here's what procurement needs to verify now, and why waiting for the regulation is the wrong move.
Is PFAS banned in Canadian food packaging? The honest answer
Not yet — but the direction is set. In March 2025, Environment and Climate Change Canada and Health Canada published the final State of PFAS Report and a proposed approach to add PFAS (excluding fluoropolymers) to Schedule 1 of the Canadian Environmental Protection Act (CEPA), effectively declaring the class toxic. The plan is phased:
- Phase 1 — PFAS in firefighting foams.
- Phase 2 — PFAS in consumer products where alternatives exist, explicitly including food packaging materials, cosmetics, and textiles.
- Phase 3 — further sectors requiring assessment.
Crucially for packaging buyers: binding implementing regulations are expected to be developed beginning around 2027, and a proposed regulation would then carry a 60-day comment period followed by final publication roughly 18 months later. So there is no blanket food-packaging PFAS ban in force today — but food packaging is named in Phase 2, and the regulatory machinery is moving.
(A separate instrument, the Prohibition of Certain Toxic Substances Regulations, 2025 — in force June 30, 2026 — tightens restrictions on specific PFAS subgroups such as PFOS and PFOA carried over from earlier rules. It is not a general food-packaging ban, and shouldn't be described as one.)
Why PFAS-free is already a buying gate — regardless of the timeline
Retailers don't wait for the slowest regulator. They set supplier requirements to the strictest market they sell into, because reformulating packaging twice is more expensive than requiring PFAS-free from the start. Three forces have already moved the market ahead of Canada's federal timeline:
- US FDA, January 2025 — grease-proofing PFAS in paper and paperboard food packaging has been voluntarily phased out, with 35 food-contact notifications declared no longer effective. North American paper-packaging supply chains have already shifted away from PFAS coatings.
- US states — a growing number have banned intentionally added PFAS in food packaging on staggered timelines.
- Retail and ESG policy — major chains increasingly write PFAS-free into supplier codes and ESG commitments, independent of any single country's law.
The practical result: for a supplier selling into North American retail, PFAS-free documentation is a gate now , not a 2027 problem.
The greenwashing-law angle: a claim needs a test, not a label
This is where the procurement risk sharpens. Bill C-59 amended Canada's Competition Act in June 2024 so that environmental claims about a product must be supported by adequate and proper testing — with the burden of proof on the party making the claim. As of June 20, 2025, private parties can bring greenwashing actions directly to the Competition Tribunal.
In that context, an unsupported "PFAS-free" label is a liability for both the brand and the retailer carrying it. The claim is only as strong as the test report behind it.
What procurement should verify on "PFAS-free"
Don't accept a generic supplier statement. Verify:
1. A fluorine test on the actual product — total fluorine or total organic fluorine screening on the bag and its coating, not a blanket factory declaration.
2. The test report details — the laboratory, the method, the date, and which component was tested (the substrate, the coating, the ink).
3. The threshold — "PFAS-free" should mean no intentionally added PFAS and total fluorine below a stated detection limit. Ask the supplier to state the number.
4. Whether your existing certification covers it — BPI and BNQ testing addresses regulated substances and toxins, but PFAS-specific documentation is a separate, explicit ask. (See our breakdown of [BPI vs BNQ certification](/blogs/news/bpi-vs-bnq-compostable-certification-canada).)
The bottom line
Until Canada's federal rules land, the burden of proof sits with the party making the claim — and PFAS-free is the claim buyers are checking first. The suppliers who win shelf approval aren't the ones promising PFAS-free; they're the ones who hand over the test report that proves it.
See how Guarden documents PFAS-free status alongside BPI and BNQ certification for retail procurement → [Certifications & Compliance](/pages/about-us)
Ask for our PFAS-free test documentation as part of the compliance pack — the report, the method, and the threshold, ready for your vendor file.
- Environment and Climate Change Canada — Risk management approach for PFAS (excluding fluoropolymers): https://www.canada.ca/en/environment-climate-change/services/evaluating-existing-substances/risk-management-approach-per-polyfluoroalkyl-substances.html
- Food Packaging Forum — Government of Canada proposes action on PFAS (phased approach): https://foodpackagingforum.org/news/government-of-canada-proposes-action-on-pfas
- Marten Law — Canada proposes phasing out PFAS (implementing regulations from 2027): https://martenlaw.com/news/canada-proposes-phasing-out-pfas
- McMillan LLP — Prohibition of Certain Toxic Substances Regulations, 2025 (in force June 30, 2026): https://mcmillan.ca/insights/publications/canada-enacts-new-prohibitions-of-certain-pfas-and-other-chemicals-under-canadian-environmental-protection-act-1999/
- BLG — Bill C-59 greenwashing, reverse onus, private right of action: https://www.blg.com/en/insights/2024/07/false-advertising-and-greenwashing-bill-c-59-changes-to-competition-act
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BPI vs BNQ: Which Compostable Certification Do Canadian Retail Buyers Actually Require?