The final version of the Watch List Approach was published April 28, 2026 on the CEPA Registry.
The purpose of the Watch List is to identify substances that have not met the criteria for Schedule 1 of CEPA but that the Ministers have reason to suspect could become toxic if conditions change. Addition to the Watch List could result in a Significant New Activity (SNAc) provision, consideration for environmental monitoring or biomonitoring or follow up through a Section 71 survey.
The content of the final publication is largely unchanged, which is in keeping with our expectations. Some context has been added with respect to The Right to a Healthy Environment. Disproportionately impacted populations were added to the list of possible considerations for determining if the risk profile of the substance could change. The other criteria remain mostly the same.
The text does emphasize that the list is an administrative tool. It will not add any additional regulatory burden, and substances will be assessed through the usual risk assessment/management process. The publication notice for these assessments will serve as the consultation period for substances being recommended for Watch List additions. Additions will be published regularly on the CEPA Registry.
Once a substance is placed on the Watch List it MUST be removed if the substance is added to Schedule 1 of CEPA or if the Ministers no longer have reason to suspect that the substance is capable of becoming toxic.
Overall, the publication is good news, we will need to see the process utilized before we can be fully certain of the implications. At this point, the list itself is not available. We are expecting an update shortly. It is expected to contain very few substances. The departments are not going back to add substances with existing risk management measures, but they have reserved the right to do so.
We will provide further information as it becomes available. In the meantime, if you have any questions or concerns, please reach out to your CA regulatory team at regulatory@cosmeticsalliance.ca. Questions can also be directed to the Substances Management Information Line at substances@ec.gc.ca.
