What changed
On 29 August 2026 the Government of Canada published two notices under section 71 of the Canadian Environmental Protection Act, 1999 in the Canada Gazette, Part I:
- Phase 1 — 184 substances. Responses may be submitted from 29 August 2026 and are due no later than 3 March 2027.
- Phase 2 — 16 substances. The reporting window runs 4 March 2027 to 8 September 2027.
Both notices ask for information on 2025 calendar-year activities and are submitted through Environment and Climate Change Canada's Single Window system. A response — including a "no activity" declaration where the notice requires one — is a legal obligation, not a voluntary survey.
This is a data-gathering step under the Chemicals Management Plan. It is not a hazard reclassification and not a prohibition. It is, however, the evidence base for later risk assessment and possible risk-management action.
Who is affected
- Anyone who manufactured, imported or used a listed substance in 2025 above the notice threshold
- Companies that imported the substance inside a mixture, product or manufactured item — the obligation follows the substance, not the SDS
- Downstream users who may hold use and release data the manufacturer cannot see
Why this matters
The reporting form looks administrative; meeting it is a company-wide data-reconstruction project. It typically requires:
- Substance matching (CAS / DSL) against both notice lists, including substances present only as impurities or in imported articles
- 2025 quantities for manufacture, import (by concentration and product type), industrial use and export
- Facility-level release data to air, water and land
- Product and end-use descriptions, including consumer and children's-product use
- Retrieval of unpublished studies and other data in the company's possession
- Handling of supplier blind submissions, where a supplier reports directly to ECCC to protect confidential composition
Recommended actions
- Screen your substance inventory — including imported products and articles — against the Phase 1 and Phase 2 lists immediately.
- Assign an owner for each match and open a 2025 data file per substance now, while the source records are still accessible.
- Confirm whether any supplier intends a blind submission, and document the arrangement.
- Preserve the underlying evidence (calculations, shipment records, studies) in case of a follow-up request or verification.
- Diarise 3 March 2027 for Phase 1 and 8 September 2027 for Phase 2; do not leave either to the final weeks.
Reviewed by CHEMREG Regulatory Team · Last reviewed 10 Sept 2026