On March 25, 2026, the Government of Canada published Order 2026-87-20-01 in the Canada Gazette, Part II, introducing significant changes to the Domestic Substances List (DSL) under the Canadian Environmental Protection Act (CEPA).
SNAc provisions are a risk management tool utilized when an activity conducted with a substance in a different quantity, concentration or in different circumstances could impact the environmental or human exposure to the substance.
The published Order applies new Significant New Activity (SNAc) requirements to 54 existing substances and modifies the conditions for 161 others, impacting a total of 223 substances.
The update also introduces structural changes to Part 2: Chemicals and polymers subject to significant new activity requirements, of the DSL. This change adds Division 1: Substances for which the significant new activity requirements are applied individually and Division 2: Substances for which the significant new activity requirements are applied in respect of groups of substances. A new Schedule 1: Significant new activity requirements in respect of chemicals and polymers that standardizes information requirements for SNAc notifications has also been added.
A quick review of the order indicates that many of these changes specifically implicate consumer product and cosmetic uses. Some of the product concentration triggers are low (0.1% or 1%).
Members should be aware that these changes have the potential to immediately impact compliance as the trigger volume for some are set below the NSN trigger, at 10-kg/year. SNAc provisions require that any significant new activity must be reported through a Significant New Activity Notice (SNAN) before the activity begins. This means that companies operating under NSN triggers but above the SNAN trigger could face instant non-compliance.
Regrettably, Cosmetics Alliance Canada and other industry association partners were not provided advance notice of this publication. Consequently, there has not been any opportunity for stakeholders to engage with these proposals – the implications of which are potentially very far-reaching, and potentially immediate. This is a significant departure from the open and transparent approaches that we have come to expect under the Chemicals Management Plan (CMP). As a result, we are undertaking the following actions immediately:
- Following up with the government to address the process concern and seek greater transparency and engagement going forward.
- Reviewing the impacted substances against the INCI Dictionary with the intent to help members identify impacted substances.
- Work with our technical committees to identify any areas of concern.
It is critical that members do their own review of these substances as soon as possible to understand potential implications of these changes and to ensure continued regulatory compliance.
Please contact your CA regulatory team at regulatory@cosmeticsalliance.ca with any concerns raised by this publication. You can also contact the Substances Management Information Line by email at substances@ec.gc.ca or by telephone at 1-800-567-1999 (within Canada) or 819-938-3232 (international).
