The Canadian Recreational Vehicle Association (CRVA) issued the following letter with an update from CRVA, Recreation Vehicle Dealers Association (RVDA) of Canada and RV Industry Association (RVIA) on Canadian reporting requirements of per- and polyfluoroalkyl substances (PFAS).
The Canadian Recreational Vehicle Association (CRVA) is committed to keeping you informed about regulatory changes impacting our industry.
As announced by the Canadian Federal Government in 2024, any entity involved in manufacturing in Canada, importing into Canada (importers of record) or using PFAS listed in Schedule 1 during the 2023 calendar year must submit a report on their activities by Jan. 29.
Specifically, reporting is mandatory for those who in 2023 met the following thresholds:
- Manufactured (in Canada) more than 1,000 grams of listed PFAS.
- Imported into Canada more than 10 grams of certain listed PFAS in Part 1, or more than 100 kilograms in Part 2 or Part 3.
- Used (in Canada) more than 10 grams of listed PFAS in a manufacturing process.
Over the past several weeks, CRVA, RVDA of Canada and RVIA have been engaging in conversations with the Ministry of Climate Change and Environment to advocate for approval of a delay in reporting requirements until 2026 to allow for the Canadian RV manufacturers and dealers (importers of record) to properly review and gauge levels of PFAS materials that they manufacturer and/or import into Canada.
With nearly 400 RVDA of Canada members, completing individual submissions before the deadline would have been an exceptionally challenging task, especially given the lack of PFAS visibility.
We are pleased to advise you, that in a compromise, the Environment and Climate Change Canada (ECCC) and Health Canada (HC) approved a special pilot program allowing for a joint amalgamated report to be submitted, and on Jan. 22, a request for an extension to July 29 was submitted by the RVDA of Canada on behalf of their members to the agency.
This amalgamated submission would apply to their import activities under sections 2(2)(c) and 2(3) of the notice, including the import of recreational vehicles, parts and accessories to satisfy RVDA of Canada member reporting requirements.
CRVA would like to remind Canadian RV manufacturers sourcing and importing components directly from the U.S., and any non-RVDA of Canada members, that they are still required to submit their individual reports or request an extension for their activities such as manufacturing or importing substances, mixtures or products as requested in the release prior to the Jan. 29 deadline.
Reports must be submitted through Environment and Climate Change Canada’s Single Window online system. Failure to comply may result in fines, supply chain disruptions and legal liabilities.
Together with RVDA of Canada and RVIA, we would like to thank the Ministry of Climate Change and Environment for their special consideration of our industry.
We remain committed to supporting our respective members through these regulatory changes while advocating for practical compliance solutions.
For questions or further support, please contact CRVA or the RVDA of Canada.
