December 8, 2025 – Minnesota publishes their final rule for PFAS reporting. The state has officially adopted the final administrative rules for PFAS reporting, confirming that the deadline for mandatory reporting is July 1, 2026.

Key Takeaways for Manufacturers

Deadline: July 1, 2026

One-Time Reporting: The obligation is confirmed as a single, one-time report per product.

Flat Reporting Fee: A one-time flat fee of $800 per manufacturer

Product Grouping: As Claigan has previously stated, Minnesota will allow PFAS reporting by product type or grouping.

Reporting System: Minnesota’s PRISM system is to be open for submission in January of 2026.

For more information or support in Minnesota PFAS reporting – please contact Claigan at info@claigan.com

On November 14, 2025, the Department of the Interior, alongside the U.S. Geological Survey, published a revised list of critical minerals. The list includes the addition of ten new minerals: boron, copper, lead, metallurgical coal, phosphate, potash, rhenium, silicon, silver, and uranium. 

This is the third revision of the critical minerals list. The update comes after a reevaluation of how disruptions in different mineral supply chains would affect the U.S economy and security. Notably, the list includes all of the rare earth elements (REEs), of which a supply chain disruption would impact the United States the most.

Curious how critical minerals play a role in your supply chain? Wondering what supply chain disruptions would be most impactful to your company? Please  contact us.

BPS Thermal Paper Enforcement Spike: An Average of 200 Monthly Enforcement Actions Exposes a Critical Warning Flaw

OTTAWA, ON – November 21, 2025 – California’s Proposition 65 (Prop 65) enforcement has entered a new and disruptive phase. Data reveals a significant spike in 60-Day Notices targeting Bisphenol S (BPS) in thermal paper. Now estimated to be averaging roughly 200 per month.

This tidal wave of regulatory action is overwhelmingly focused on ubiquitous items: thermal labels, receipts, and stickers used by manufacturers, retailers, restaurants, and other businesses across the state.

Prop 65 requires businesses to provide a “clear and reasonable” warning prior to a person being knowingly exposed to a listed chemical. However, with BPS-containing thermal paper, the exposure is immediate and before the warning is read.

BPS: The Next Regulatory Battleground 

BPS, an endocrine-disrupting replacement for the earlier, also-restricted Bisphenol A (BPA), was added to the Prop 65 list for reproductive toxicity. The lack of an established “safe harbor” level for many BPS exposures means that even trace amounts found by plaintiff-side testing laboratories are leading to legal action.

Claigan Environmental specializes in Prop 65 defence, offering comprehensive support to companies dealing with 60-Day Notices and subsequent legal proceedings.

• July 1 2026 reporting deadline is unchanged.
• The MPCA (Minnesota Pollution Control Agency) is currently focusing efforts on guidance to support industry meeting reporting requirements.
• Although the legislative deadline for the MPCA to respond to current deficiencies in their reporting rule is February 24, 2026, the agency is expected to issue its final response ahead of that date.
• The MPCA is expected to release a public announcement soon detailing its plans for PFAS Reporting on their website.
• Companies are strongly recommended to continue their PFAS reporting work to meet the deadline.

What does this all mean? Stop Waiting, Start Working!

For further information on PFAS regulations, please contact us.

On September 8th 2025, the prominent Canadian magazine Electronic Products & Technology (EP&T) published the article Banned Chemicals ( www.ept.ca/features/banned-chemicals/)

Claigan Environmental Inc., a leader in restricted materials testing and consulting, issued a warning to manufacturers and brands worldwide regarding the complex and rapidly approaching global bans on two critical chemicals: the flame retardant Dechlorane Plus and the UV stabilizer UV-328.

The restrictions stem from the UN Stockholm Convention on Persistent Organic Pollutants (POPs) and are already being implemented through a fragmented, country-by-country approach.

“The haphazard nature of the country to country regulation of POP substances will cause confusion for companies,” says Bruce Calder, VP Consulting Services. He continues, “In the near term, manufacturers/brands are encouraged to investigate any polyester tape (for dechlorane plus) and LCD screen (for UV-328) products in order to plan an effective path forward in the face of these new restrictions.”

For further information on Dechlorane Plus and UV-328, please contact us.

Claigan Environmental Inc. is issuing an alert regarding an upcoming change to the European Union’s REACH (Registration, Evaluation, Authorisation and Restriction of Chemicals) Regulation.

The European Chemicals Agency (ECHA) Member State Committee (MSC) has unanimously agreed to identify 1,1′-(ethane-1,2-diyl)bis[pentabromobenzene] (DBDPE) as a Substance of Very High Concern (SVHC).

This substance, a widely used brominated flame retardant, is set to be officially published and added to the SVHC Candidate List in November 2025.

DBDPE is often found in plastics, cables, electrical and electronic components, adhesives, and textiles, commonly used as a replacement for DecaBDE.

For further help on DBDPE or REACH SVHC, please contact us.

Australia’s Industrial Chemicals Environmental Management (IChEMS) chemical restriction includes an ‘REACH SVHC-like’ disclosure requirement

Substances such as PFOA, Dechlorane Plus, and UV-328 are being banned in the EU with certain exemptions for essential uses such as UV-328 in polarizers in LCD screens.

However, even if the uses is exempted under essential use, importers must determine and provide information on the concentration by weight of the chemical in an article to the supply chain.

Importers and users must keep the following information up-to-date and must produce this information if requested by a relevant agency:

• information on the identity of the chemical, and articles it is used in; and
• where feasible, the concentration by weight and estimate of the total annual introduction volume of the chemical imported by the importer; and
• a justification for the use.

For further information on Australia SVHC & Restrictions, please contact us.

On June 25th, 2025, the European Chemicals Agency (ECHA) added three hazardous chemicals to the Substances of Very High Concern (SVHCs) list.

• M3T (1,1,1,3,5,5,5-heptamethyl-3-[(trimethylsilyl)oxy]trisiloxane)
• L4 (Decamethyltetrasiloxane)
• Reactive Brown 51 (Tetra(sodium/potassium) 7-[(E)-{2-acetamido-4-[(E)-(4-{[4-chloro-6-({2-[(4-fluoro-6-{[4-(vinylsulfonyl)phenyl]amino}-1,3,5-triazine-2-yl)amino]propyl}amino)-1,3,5-triazine-2-yl]amino}-5-sulfonato-1-naphthyl)diazenyl]-5-methoxyphenyl}diazenyl]-1,3,6-naphthalenetrisulfonate)

The SVHC list now contain 250 total entries.

If you’re struggling to keep up with the constant REACH updates, please contact us. Our team has multiple services to keep you up to date and informed.

Claigan tested a wide variety of products easily available on the Canadian market from some of the country’s biggest retailers. The goal was to demonstrate the pervasiveness of phthalates (e.g. DEHP) and heavy metals (e.g. Lead, Cadmium) in plastics. 

Claigan’s research determined that men, women, and children of all ages can be exposed to these toxic substances that are known to cause cancer, reproductive harm, and cause ADHD, by buying products readily available on the Canadian market. Claigan’s data was also published in a paper published by  Environmental Defence.

The Canadian Government is planning to release the highly anticipated guidance for the Federal Plastics Registry. 

On top of products and packaging – Industrial, Commercial, or Institutional (ICI) waste is also in scope. Starting in 2026, persons part of the ICI Waste Stream will be required to report quantity of plastic waste generated at their facilities.

ICI Facilities are considered non-residential sites. This includes schools, hospitals, government facilities, senior homes, universities, shopping centres, restaurants, offices, manufacturing, primary and secondary industries.

For those seeking further insights, we welcome you to check out our Canadian Plastics Registry webpage for additional information or reach out to us directly.

On September 5th 2024, the US Environmental Protection Agency (EPA) amended the period for Perfluoroalkyl and Polyfluoroalkyl Substances (PFAS) data reporting through the Central Data Exchange (CDX). The EPA sighted technical challenges and funding issues. 

The submission period will commence July 11, 2025. Large entities will have six months to report with a deadline of January 11, 2026. Smaller manufacturers will have 12 months to report with a deadline of July 11, 2026.

The deadline extension may delay CDX reporting, however companies will still need to test and identify PFAS uses. Canada CEPA Section 71 will require companies to file PFAS reports sooner. The deadline for CEPA reporting is January 29, 2025.

For more details, see the EPA Change to Submission Period and Technical Correctio.

Claigan is a PFAS expert and has extensive knowledge on testing complex articles. We offer multiple options that saves time and money.

On July 27th 2024, the Canadian government published a notice for per- and polyfluoroalkyl substances (PFAS) under the Section 71 of the Canadian Environmental Protection Act, 1999 (CEPA). Companies will be required to file reports by January 29, 2025.

Importers and manufacturers must disclose the use of 312 substances. The PFAS reporting includes most PFAS polymers, elastomers, fluids, and salts in chemical mixtures and in physical products. Unlike the US TSCA PFAS reporting requirements, medical devices and pharmaceuticals (along with other FDA / Health Canada regulated products) are included in the scope of the Canadian requirements.

For those seeking further insights into CEPA Section 71 PFAS, please reach out for additional information.

On April 29th 2024, the United Nations published a draft recommendation for further evaluating information on long-chain perfluorocarboxylic acids, their salts, and related compounds (advance). Claigan Environmental contributed PFAS testing data, which was included in the UNEP/POPS/POPRC.20/4 working document.

The findings indicate that low concentrations of PFOA and LC-PFCA resulting from the irradiation of fluoropolymers (such as PTFE), PFA polymer bond cleavage, and fluoroacrylates are classified as unintentional contaminants and are thus exempted.

For more details, see the report here.

For help with PFAS, please reach out for additional information.

On May 16th 2024, Environmental Defence released an article that included test results showing children’s and youth gloves that contain water soluble per- and poly-fluoroalkyl substances. These are the family of PFAS substances that are found in humans and drinking water. These gloves were purchased from numerous Canadian retailers and tested. 8 of 11 (73%) of the gloves tested were found to contain water soluble PFAS, likely from fluoroacrylic coatings.

The Environmental Defence news story and Claigan’s test report can be viewed here.

For those seeking further insights into PFAS, we welcome you to reach out for additional information.

On April 20, the Canadian government published the requirements for the Canadian Plastics Registry. This initiative mandates that importers and manufacturers of electronics and packaged products report their 2024 plastics volumes by September 2025.

Importers and manufacturers will be required to disclose the types and volumes of plastics in their electronic products, single use plastics, and product packaging. This reporting obligation applies to all relevant products and packaging imported into or manufactured in Canada in 2024. The registry’s scope encompasses a wide range of electronic products, including medical devices and laboratory equipment.

For those seeking further insights into Canadian Plastics Registry, we welcome you to reach out for additional information.

Promoting education has always been an important part of Claigan’s mission, so we were thrilled at the recent opportunity to sponsor the local Robotics team at Earl of March Secondary School. Claigan’s contribution enables the students to buy necessary materials to craft their robots, as well as attend competitions across the province. 

By helping students fulfill their aspirations, we help spur on the next generation of scientific thinkers. Well done to the students this year, and we can’t wait to see their creative inventions next year!

On February 29, 2023, Claigan Environmental took a significant step forward by submitting PFAS CUU (Currently Unavoidable Uses) proposals to the States of Maine and Minnesota. Additionally, they submitted PFOA/LC-PFAC exemption requests to the Canadian and Australian Governments, and to the United Nations (Stockholm Convention – POPRC-19/2).

This collaborative effort involved over 50 companies spanning diverse industries such as consumer goods, IT, and healthcare. The submissions were supported by extensive laboratory data collected from 2022 to 2024, obtained through testing thousands of products for PFAS and PFAS salts.

It’s important to note the absence of any comparable comprehensive listing, explanation, and justification of PFAS uses elsewhere. These documents offer an extensive compilation of CUU and PFAS/LC-PFAC applications in physical products, accompanied by detailed justifications and alternative comparisons. They serve as invaluable references for PFAS regulators navigating this complex landscape.

For those seeking further insights into PFAS, we welcome you to reach out for additional information.

On December 12, 2023, the Australian Government took significant steps by incorporating various substances into their Industrial Chemicals Environmental Management (IChEMS) Register. Notably, adjustments were made to schedules 6 & 7, aimed at phasing out substances such as PBDE, HBCDD, PFOA, and SCCPs. These amendments entail strict prohibitions on importing, exporting, and manufacturing, with some essential use exemptions.

The implemented prohibitions closely mirror the restrictions outlined in the EU POP and EU RoHS regulations, with some nuanced differences. Effective dates for these restrictions vary, with the next milestone set for July 1, 2024.

For further insights on Australia’s POP regulations, please feel free to reach out for additional information.

As of December 18, 2023, the Minnesota Pollution Control Agency is requesting comments and Currently Unavoidable Uses (CUU) for PFAS. 

As of January 10, 2024, the Maine Department of Environmental Protection is also accepting proposals for CUU of PFAS. 

The deadline for submission in both states is March 1, 2024. 

These proposals are to form the foundation for PFAS use exemptions, shaping the regulatory landscape for PFAS restrictions in each state. Approvals granted in Maine and Minnesota are expected to enhance the likelihood of obtaining parallel exemptions in other states with similar PFAS legislation, such as California and New York.

Similar to Claigan’s very successful EU PFAS derogation submission project, Claigan is inviting companies to participate in the Maine/Minnesota PFAS exemption project. This campaign will provide companies with the opportunity to ensure their uses are subjected to thorough review. Leveraging extensive information from the EU derogation process, Claigan’s Maine/Minnesota submission project aims to compile a comprehensive and well-supported list of common uses within the demanding deadline of March 1, 2024.

For further insights on Australia’s POP regulations, please feel free to reach out for additional information.

On December 30, 2023, the Government of Canada initiated a consultation period for the Federal Plastics Registry, which is set to conclude on February 13, 2024.

The Canadian government is actively developing a registry dedicated to the comprehensive reporting of plastics in the realms of electronics and packaging. This requirement specifically applies to individuals identified as producers of plastic products, encompassing brand owners residing in Canada or the initial resident responsible for manufacturing or importing a plastic product into the country.

This reporting obligation is slated to be an annual process, with the first report due by September 29, 2025. This initial submission will pertain to the 2024 calendar year, necessitating the identification of the resin used in product manufacturing, the resin’s source, the category and subcategory of plastic products, and the total quantity (measured in tonnes) introduced to the Canadian market. In subsequent years, additional details, such as the percentage of plastics collected at the end of their life cycle, those diverted to recycling, re-processed, incinerated, and composted, will be expected.

For more comprehensive information on the Canadian Plastics Registry, please do not hesitate to reach out. Additionally, feel free to explore Claigan’s latest webinar on the Canadian Plastics Registry for additional insights.

On Wednesday, January 3, 2024, Claigan Environmental is announcing their consulting services for Russian Iron and Steel. The European Union (EU) and the United Kingdom (UK) have imposed sanctions on iron and steel originating from Russia, effective since September 30, 2023.

The EU and UK are actively seizing shipments of iron and steel lacking proper documentation, leading to supply chain disruptions and leaving companies vulnerable.

Claigan simplifies the process. Our experts can quickly identify high risk suppliers, collect mil-certificates, and provide declarations for your direct customers or customs official.

For more information,  get in touch.

On December 20, 2023, the Canadian Government released new information about reporting requirements for Forced Labor and Child Labor for businesses operating or selling goods in Canada. 

Companies must submit their first report to the Minister of Public Safety Canada by May 31, 2024. These reports should outline the steps taken in the previous financial year to prevent and reduce the risk of forced labor or child labor in supply chains.

For more information,  get in touch.

In California, cookware manufacturers have been mandated to disclose the chemicals in their products on their websites since January 1, 2023. As of January 1, 2024, new labeling requirements for products will come into effect.

The AB1200 declarable chemicals are a very wide range of chemicals including most metals (ex – iron, copper, nickel), PFAS, phthalates, regulated flame retardants (such as TBBPA), and most other substances regulated in the US (including Prop 65) and the EU.

Claigan, with its proactive approach, has been actively testing and guiding companies through these regulatory shifts. Recognizing the challenges and time constraints in relying on supply chains to declare hazardous chemicals, Claigan offers an efficient solution to test your products, ensuring compliance with labeling obligations.

For more information,  get in touch.

On December 14th, 2023, the Member State Committee (MSC) unanimously approved five (5) new Substances of Very High Concern (SVHCs) and on update to a sixth substance.

New SVHCs
UV-326
UV-329
2,4,6-TTBP
OAPP
2-(dimethylamino)-2-[(4-methylphenyl)methyl]-1-[4-(morpholin-4-yl)phenyl]butan-1-one

Additional property – DBP (endocrine disruptor environment)

The new SVHCs are expected to be officially listed January 23 2024.

On Thursday September 21st, 2023, Claigan Environmental submitted the PFAS submission project to ECHA. The project consisted of 5 different submissions (1) PFAS in articles, (2) PFOA in articles, (3) PFAS in drinking water, (4) Comparison of alternatives, and (5) Derogations requested. This project was the culmination of input provided by over 30 companies and included 53 derogations. 

The goal was to provide a multi-industry response to ECHA that accounted for a wide range of necessary PFAS uses and request the respective derogations.

Through Claigan’s expertise and experience, companies across multiple industries ensured that their varied, necessary uses of PFAS were covered by derogations and could continue being used. Companies that did not submit their requests for derogations could find themselves having to make costly material changes to their products to keep selling in the EU.

Ottawa, 3 January 2023 – Claigan Environmental Inc. is announcing their Uyghur Forced Labor Prevention Act (UFLPA) services. Building from our Conflict Minerals due diligence work, Claigan has identified numerous gold refineries that source from Xinjiang province.

Under UFLPA, US Customs and Border Protection can stop and hold your products if they believe the materials originated from Xinjiang province. To release your products from customs, you need to show due diligence that your products did not benefit from forced labour.

Claigan’s approach to due diligence is proactive and follows the U.S. Customs and Border Protection Operational Guidance for Importers. Claigan’s process is a step wise approach to assessing the risk of each supplier and related due diligence requirements. From that risk assessment and due diligence, Claigan produces an evidence package for each supplier that can be provided to US Customs and Border Protection, or as reference to inquiring customers.

The Uyghur Forced Labor Prevention Act is a United States federal law that changes U.S. policy on China’s Xinjiang Uyghur Autonomous Region with the goal of ensuring that American entities are not funding forced labor among ethnic minorities in the region.

For more information on UFLPA,  get in touch.

Also feel free to watch Claigan most recent webinar on UFLPA here.

Ottawa, 20 December 2022 – Claigan Environmental Inc. announcing their perfluoroalkyl substances (PFAS) compliance services. To comply with global PFAS reporting and restriction requirements, Claigan, an ISO 17025 accredited laboratory, has developed a comprehensive and practical approach to PFAS compliance for products. The process was developed to comply with the PFAS reporting requirements for the State of Maine, the PFOA related restrictions in the EU and California, and other emerging requirements in the US, Canada, EU, and Asia.

Fluoropolymers are ubiquitous in consumer, professional, and medical products. Fluoropolymers such as PTFE and FKM provide significant performance advantages in many different applications. Due to political pressures related to some of the residual perfluoroalkyl substances (such as PFOA) in fluoropolymer and fluoro-coatings, an increasing amount of jurisdictions are implementing regulations related to PFAS. Some of these regulations are restrictions. Many are far reaching, mandatory data reporting requirements.

Claigan’s approach consists of practical testing for fluorine by using WDXRF. For products with fluorine, further testing is applied to identify the type of fluoropolymer and and restricted PFAS (such as PFOA). The process relies on the concept: if there’s no fluorine present, then there’s no fluoroalkyl present. If fluorine is present, more refined testing can be conducted to identify the polymer present and test for unintentional residual chemicals such as PFOA (down to 25 ppb).

Claigan’s process is very practical and can be applied on a part by part basis, or used in a survey type approach to create a sufficient enough picture for PFAS reporting.

For more information on PFAS compliance, get in touch.

Also feel free to watch Claigan most recent webinar on PFAS compliance at here.