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CEPA
Canada has launched a far-reaching information-gathering initiative under its chemical management framework, introducing new reporting obligations for companies across the supply chain. The requirements do not only affect chemical manufacturers but also importers, producers of mixtures and articles, and companies using certain substances in their products. Businesses active on the Canadian market should now assess whether they are subject to the new reporting requirements.
Background: Canada Is Collecting Data on 200 Substances
The Government of Canada has published two information-gathering notices under Section 71 of the Canadian Environmental Protection Act, 1999 (CEPA) as part of the Chemicals Management Plan (CMP). The objective is to obtain information that can support prioritization, risk assessment, and potential future risk management measures for the substances concerned.
The initiative is divided into two phases:
- Phase 1: 184 substances, reporting deadline March 3, 2027
- Phase 2: 16 additional substances, reporting deadline September 8, 2027
The information requested relates to activities carried out during the 2025 calendar year.
Who Is Affected?
The notices apply to companies that manufacture, import, or use the listed substances above specified reporting thresholds. Importantly, the scope extends well beyond traditional chemical manufacturers.
Companies may have reporting obligations if the substances are present in:
- Mixtures
- Products
- Manufactured articles
- Packaging materials
- Consumer goods
- Imported finished products
Depending on the substance, reporting thresholds can be as low as 100 kg per year, while higher thresholds apply to certain substance groups. The requirements may also apply to substances contained in imported articles above specified concentration limits.
Industries that may be particularly affected include:
- Automotive
- Electronics
- Consumer products
- Packaging
- Furniture and textiles
- Chemicals and plastics processing
Which Substances Are in Scope?
The list includes substances that are already receiving regulatory attention in various jurisdictions around the world. Examples include:
- PPD derivatives used in the tire and rubber industry
- Chromium compounds
- N-Methyl-2-pyrrolidone (NMP)
- 1-Bromopropane (1-BP)
- Organophosphate flame retardants
- Certain azo dyes
- Additional substances used in consumer products and industrial applications
These substances have been selected to support further evaluation of their potential impacts on human health and the environment and may become the focus of future regulatory action in Canada.
What Information Must Be Reported?
Companies subject to the notice may be required to provide detailed information, including:
- Manufacturing, import, and use volumes
- Substance concentrations in products and articles
- Applications and end uses
- Export quantities
- Information on potential releases to air, water, or land
- Facility and activity data
- Relevant unpublished studies or data, where available
Responses must be submitted through the electronic reporting system provided by Environment and Climate Change Canada.
The Biggest Challenge: Supply Chain Data Collection
For many companies, the greatest challenge will not be the reporting process itself but gathering the necessary information. Data often has to be consolidated from multiple departments and obtained from suppliers throughout complex international supply chains.
To facilitate compliance, Canadian authorities have published guidance documents and even provide template letters that companies can use to request information from overseas suppliers.
For businesses managing large product portfolios or complex supply networks, identifying relevant substance content, concentrations, and volumes can require significant time and resources. Early preparation is therefore strongly recommended.
More Than a Reporting Exercise
Companies should view this initiative as more than a one-time reporting obligation. Information-gathering notices under CEPA are frequently used to build the knowledge base for future risk assessments and regulatory decision-making.
As a result, the substances included in the current survey could face increased scrutiny and potential regulatory measures in the coming years. The initiative therefore provides valuable insight into the substances currently attracting the attention of Canadian regulators.
Conducting an early impact assessment can help companies understand their exposure, improve supply-chain transparency, and prepare for possible future compliance and substitution requirements.
Conclusion
Canada’s new substance information request represents one of the most significant chemical data collection initiatives in recent years. Because the requirements extend beyond chemical manufacturers and may also affect imported products and articles, companies should assess their obligations as early as possible.
Organizations that gain visibility into the substances present in their products and supply chains today will be better positioned to reduce compliance risks and respond efficiently to future regulatory developments in Canada.
Practical tip: If your company exports products to Canada, now is the time to verify whether any of the 200 listed substances are present in your products, mixtures, or articles and whether the relevant reporting thresholds may be exceeded.
How We Can Support You
Our “North American Material Compliance” training course (No. 6282) will prepare you for TSCA, CEPA, and CP65. You can find the upcoming training dates here.
We’d be happy to help you analyze your compliance status and products. Simply schedule an appointment for a free solution check.
Sources:
Canada Gazette, Part 1, Volume 160, Number 35: GOVERNMENT NOTICES