Environment Canada Enforcement Actions – You Need to Read This!

Posted Date: 26-May-2022

If your company has any products that contains INCI Name:  Perfluorononyl Dimethicone (INCI Monograph ID 12795) with the CASRN:  882878-48-0, you may be (or may have already been) contacted by enforcement officials from Environment and Climate Change Canada (ECCC). They appear to be conducting an enforcement blitz with respect to this and other substances potentially classified as Per- or Polyfluorninated alkyl substances (PFAS).

 

PFASs are a very large subset of substances, covering 1000+ chemistries that are presently under scrutiny over concerns that some may be considered as ‘forever chemicals’ (due to the fact that some may not readily breakdown through natural processes in the environment).

 

Cosmetics Alliance has already been contacted by several member companies who have been approached by ECCC.  From the information gathered to date, it may be that the origins of the issue go back some years and involve the conveyance (or lack thereof) of information within an international supply chain and ECCC.

 

As it is likely that more member companies may be in the same or similar situation, it would be most helpful if you would contact your CA Team if you have this substance in any of your products or have already been contacted by ECCC.  The more information we have to better understand this situation, the better will be our ability to seek an appropriate resolution for impacted member companies.

 

We would ask that you notify CA Canada in confidence (if you have not already done so) of your direct engagement in this matter by messaging regulatory@cosmeticsalliance.ca [Use Subject Line:  ECCC PFAS Activity].

 

Please indicate if you have either:
  1. Already been in contact with ECCC on this front; OR
  2. Have not yet been contacted by ECCC, but have potentially implicated products containing this ingredient; AND
  3. Furthermore, regardless of your specific interests in this ingredient, please confirm if you have been visited by ECCC officers regarding other potential PFASs.  If so, we would appreciate it if you could share the specific PFASs and INCI names that ECCC may have expressed interest in.

 

If your company is affected by this issue, your urgent attention to this request would be appreciated.