On July 19, 2025, the Government of Canada published 3 pivotal final publications that will direct Canada’s CMP activities for the years to come. These long-awaited publications respond to several related technical consultations undertaken over the past couple of years, with the Modernization of CEPA under Bill S-5: Strengthening Environmental Protection for a Healthier Canada Act.
Establishing Canada’s Strategic Framework to Advance, Enable and Promote the Refine, Reduce, and Replace Vertebrate Animal Testing under CEPA:
This Strategic Framework provides an important policy backdrop for advancing and accelerating regulatory adoption of New Assessment Methods (NAMs) and Next Generation Risk Assessment (NGRA) approaches to drive and support regulatory decision-making with minimal (and ultimately without) dependence on vertebrate animal testing in the future. This Framework is especially critical for the cosmetic and personal care industry, given Canada’s Cosmetics Animal Testing Ban, in December 2023.
This final publication reflects stakeholder input (including submissions made by CA Canada, a number of our Trade Association partners from around the world, and the International Collaboration on Cosmetic Safety (ICCS) representing the global cosmetic and personal care industry’s research collaborative on NAMs and NGRA) received in response to the corresponding draft strategy as published for consultation by Health Canada and Environment and Climate Change Canada (ECCC), in September 2024. Feedback on the proposed five key elements of the strategy (identifying NAMs, advancing research, promoting harmonization, communicating, and implementing NAMs) included suggestions for prioritizing new approach methods, accelerating long-term goals, and building capacity through training. Additional considerations raised by the public and other stakeholders emphasized the crucial need for federal funding for NAMs development, the importance of transparently tracking and reporting progress with clear metrics and timelines, and the potential for Canada to lead internationally in this area. We are pleased that this final publication integrates and reflects the key input that our industry collectively submitted and provides for the foundational policy basis that our global industry needs to both drive and foster the requisite changing regulatory paradigm to advance regulatory acceptance of non-animal testing and risk assessment approaches moving forward.
As a strategic framework document, this publication is a topline document, focused on providing high-level principles that will guide regulatory policy development moving forward. In this regard, this document is light on practical details. Nonetheless, with this publication now finalized, it provides for an important new tool to contemplate when looking to leverage NAMs and NGRAs to support future new substance notifications and existing substance assessments. CA Canada looks forward to continuing to work with officials as they develop concrete plans and details to advance this regulatory framework in practice.
Lots more to come – suffice to say that this publication is but a first pivotal step to moving Canada’s 3R ambitions forward, and a most welcomed development.
Charting the Next Policy Development Priorities, Risk Assessment and Risk Management Priorities Under Canada’s CMP:
To promote greater openness and transparency, and most importantly to enable more effective stakeholder engagement and planning, the Government of Canada committed to publish and maintain a “Plan of Priorities” outlining anticipated risk assessment, risk management, and policy consultation activities to be undertaken under the CMP, per Section 73(1) of CEPA. This “Plan of Priorities” should serve as a key tool to help members understand, plan and prepare for emerging priorities of interest, under this program. CA Canada has long supported engagement opportunities to help stakeholders navigate the CMP, and we are pleased to see this evolution of this important planning tool moving forward.
To help members navigate this publication, the “Plan” is organized into 3 Main Sections:
- Substances Prioritised For Assessment: Indicating substances or groups of substances that have been identified for risk assessment over the 4 years.This Section is divided into 3 tabs:
- List of substances or groups of substances prioritised for assessment
- Rationale for prioritisation
- Link to detailed workplan and anticipated timelines for the commencement of risk assessment activities (excel spreadsheet)
Select priorities (listed alphabetically) that may potentially implicate the cosmetic/personal care include (but is not necessarily limited to):
- HCCB (CASRN: 1222-05-5)
- Alkybenzene Sulfonates and Derivatives
- Alkylphenols
- Apigenin (CASRN: 520-36-5)
- Coumarins
- Fluoropolymers
- Hydoxybenzophenones
- Nano Titanium Dioxide (TiO2)
- Nano Silver (CASRN: 7440-22-4)
- Nano Zinc Oxide (ZnO, CASRN: 1314-13-2)
- Octocrylene (CASRN: 6197-30-4)
- Pharmaceutical Substances
- Quaternary Ammonium Compounds
- Salicylates
- Terpenes of Concern
- Risk Management Priorities: Outlining new and existing risk management priorities
- Link to existing Risk Management Action Table (summarizing CEPA risk management actions, presently current to December 2024)
- Overview of planned risk-management consultations, select priorities of potential interest:
- Discussion document outlining criteria for CMR and Substances of Highest Risk (SHR)
- Permitting regime for certain existing ‘toxic substances’ supporting restricted uses of designated substances, where no feasible alternatives exist
- Amendments to the Prohibition of Certain Toxic Substances Regulation (PCTS)
- Disclosure of substances in products
- Research, monitoring and surveillance activities
- Integrated Chemical Mixture Project
- Information Gathering Priorities: Identifying continuing information gathering initiatives to support CMP activities new and existing risk management priorities
- Link to Information Gathering Initiatives highlighting existing and past mandatory and voluntary initiatives.
- Evolving to include new initiatives (functionality not yet enabled).
- Surveys, especially large-scale mandatory information gathering activities (e.g., annual inventory update surveys) are very resource intensive, requiring significant time to complete; CA Canada together with other Trade Associations continue to work with officials to narrow the focus, coordinate, and streamline these types of initiatives, to ensure most efficient use of resources, whilst balancing critical data needs
In addition to these 3 Sections, the Plan also reflects 2 additional sections, highlighting important supplemental details related to:
- 3R Framework addressing strategic engagement with NAMs and NGRA, as previously summarized; and
- Plans for amending this “Plan” from time to time, including commitments for integrating an “Implementation of Plan” Report as part of the Government’s CEPA Annual Report.
Members are encouraged to familiarize themselves with this “Plan” and identify substances (or groups of substances) of interest for which risk assessment or risk management activities ‘coming down the pipe’, in addition to identifying upcoming consultation opportunities around critical policy considerations that will shape future program direction and policy priorities.
Finally, CA Canada will be engaging with select key priorities, as confirmed by expressed interest as shared by our membership. Members are encouraged to share their respective priorities of interest with CA Canada, to facilitate engagement on key priorities, moving forward. Engagement on these priorities will be facilitated through our Risk Assessment and Ingredient Safety Committee (RAIS), so if you are interested in contributing to CA Canada’s engagement on any of these priorities of interest, we welcome your engagement (if you are not already a member) with this CA Canada Technical Committee moving forward. To confirm interest in participating in this committee please email regulatory@cosmeticsalliance.ca.
Codifying Right to a Healthy Environment:
In June 2023, the Canadian Environmental Protection Act (CEPA) was amended to formally recognize the right of every individual in Canada to a healthy environment. To guide this recognition, an Implementation Framework was published on July 19, 2025, developed with public input. This framework provides guidance for Environment and Climate Change Canada (ECCC) and Health Canada on how to consider this Right in their decision-making under CEPA, acknowledging that it is subject to reasonable limits. The framework will be updated as implementation progresses, with annual reports on its progress.
The “Right to a Healthy Environment” under CEPA encompasses both substantive elements and procedural elements. Substantively, it means the right to live in an environment protected from harmful substances, pollutants, and waste, contributing to clean air and water, a sustainable climate, and healthy ecosystems. Procedural elements, already integrated into CEPA, include access to information to make informed decisions and participation in decision-making processes.
To protect this Right, the Framework offers guiding considerations for ECCC and HC, along with various existing CEPA mechanisms. It also elaborates on key principles, including environmental justice (fair protection and participation for all, especially vulnerable populations), intergenerational equity (meeting present needs without compromising future generations), and non-regression (preventing reduced environmental and human health protection). The framework emphasizes respecting Indigenous Rights and Knowledge, promoting the bridging and weaving of Indigenous knowledge with Western science, and developing guidance for this integration.
Decision-making under CEPA will also consider various relevant factors: scientific, environmental, health, social, and economic, to interpret and apply the right and determine its reasonable limits. To enhance accountability and transparency, a new Right to a Healthy Environment Portal has been established on the CEPA Registry, providing information on CEPA decisions, participation opportunities, and relevant resources.
CA Canada will continue to monitor developments related to this codification of the Right to a Healthy Environment, including any insights gained as new case law that may be pertinent to the cosmetic and personal care industry, as this Right gets integrated into legal practice.
Report Out From 2024 CMP Multi-Stakeholder Consultation
In conjunction with these 3 publications, the Government of Canada also released their Summary Report highlighting stakeholder input shared during the “CMP Multi-Stakeholder and Partner Workshop held in October 2024. This report was issued as supplemental, background information, in support of these final publications and largely affirms all of the important the key considerations that were clearly taken into account in the finalization of these documents, as already reviewed, above.
We would note, that one of the key observations of significant interest, is the need to affirm the overall intent, purpose, definition and implementation approach regarding the designation of the ‘Watch List’. As reviewed above, this will be an important priority to keep tabs on, especially as it will add yet another ‘list’ to consider for members to take into account from a regulatory compliance perspective; but perhaps more critically, to proactively manage how the implementation of such an administrative list could potentially be taken out of context, if the policy imperative is unclear or misunderstood.
PLEASE NOTE: CA is also in the planning process for our Environmental Symposium on September 25, and we are pleased to share that we have secured a commitment from our government colleagues to speak to these publications and the details.
Register here!
