Introduction to PFAS

Per- and polyfluoroalkyl substances (PFAS) are a class of more than 15,000 human-made substances that have the same portion of chemical structure. These substances are sometimes referred to as “forever chemicals” as they do not break down easily and remain in the environment for long periods of time. Due to their properties, such as the ability to repel oil and water, PFAS are used in a range of products and commercial applications, as well as in industrial sectors. (Government of Canada publishes State of Per-and Polyfluoroalkyl Substances (PFAS) Report and proposed Risk Management Approach  - Canada) 

Overview of Canada’s Section 71 Notice 

The Canadian Environmental Protection Act (CEPA) is one of Canada’s key pieces of federal environmental legislation that is “aimed at preventing pollution and protecting the environment and human health.” CEPA grants authority for Environment and Climate Change Canada (ECCC) to assess risks to the environment and human health posed by substances in commerce – with a heavy focus on understanding and managing toxic substances.


The Guidance Manual for the Notice states that “the purpose of the notice is to collect information on certain PFAS substances, either alone, in mixtures, products or manufactured items in Canadian commerce for the calendar year 2023.”

Why does Cummins need this PFAS data? 

Cummins is collecting data pertaining to the PFAS content included in components in our products that were imported into or used in Canada during the 2022-2023 calendar years (January 1, 2022 – December 21, 2023). Cummins has identified your company as a supplier that may have data necessary for Cummins to complete its reporting obligations to Canada’s Section 71 Notice. 

How do I submit my Company's PFAS data to Cummins? 

  • If the products your company supplies to Cummins do not contain any PFAS, please complete this form reflecting that your parts are PFAS-free. 
  • If your Company is currently using IMDS, CDX, or Anthesis Spreadsheets to send supplier data to Cummins: 
    • Please review your Company’s submittals as it concerns any mixtures, products, or manufactured items sold/supplied to Cummins and ensure that your data is current and reflects any knowledge that you have, of PFAS content in your products.  Please complete the following actions, as appropriate: 
      • If updates ARE NOT required and data is current and complete, as it concerns PFAS content, please verify your review of the data by completing the form. 
      • If updates ARE required to existing data submissions that have been previously provided by Cummins, update those to reflect your current knowledge of PFAS content. Please complete this form indicating your plan to make the updates. 
      • If no data has ever been submitted to Cummins, please provide PFAS data in the appropriate supplier reporting tool for your company. Please complete this form indicating your plan to submit the data.
  • If your Company DOES NOT utilize any of these data collection tools noted above, please verify by emailing the following information to [email protected]. Please complete this form indicating your plan to submit your PFAS data via email.
    • Confirm any mixtures, products, or manufactured items that contain PFAS content that were sold to Cummins during calendar years 2022 and 2023 and include the Cummins Part Number of what was sold/supplied to Cummins. 
    • The CAS #s or CAN # (Confidential Accession Number) of PFAS contained in your product.
    • The percent of each PFAS in the materials contained in your product.  
    • The weight (grams) of each PFAS in the product. 
       

Response Due Date 

Please fill out this form no later than June 1, 2025. 
 

Where can I fill out the form stating I have reviewed, updated, and submitted my PFAS data to Cummins? 

Link to Adobe Sign Form for PFAS Confirmation 
Please fill out the form by no later than June 1, 2025.
 

References/Resources: