Canada Launches Extensive Substance Survey

Identifying Applicability: Who Will Be Affected by the Reporting Mandate? 

Under the Canadian Environmental Protection Act (CEPA), the Canadian government has published two Section 71 Notices requiring companies to report information on specified substances. Reporting obligations apply to companies that manufacture, import, or use certain substances in their products and exceed defined reporting thresholds. 

The first phase covers 184 substances with a reporting deadline of March 3, 2027, while the second phase includes 16 additional substances with a deadline of September 8, 2027. The requested information relates to activities conducted during the 2025 calendar year.

The substance list includes numerous chemicals that are already under regulatory scrutiny in other jurisdictions. These include, among others, PPD derivatives used in the tire and rubber industry, chromium compounds, certain solvents such as N-Methyl-2-pyrrolidone (NMP) and 1-bromopropane (1-BP), organophosphate flame retardants, azo dyes, and other substance groups used in consumer products and industrial processes. 

Importantly, the reporting requirements do not apply solely to chemical manufacturers. Companies that use these substances in mixtures, articles, or imported products may also be subject to reporting obligations. An initial applicability assessment should therefore cover the entire product portfolio, including all relevant supply chains.

What Information Must Be Reported?

Companies subject to the reporting requirements must provide extensive information. This includes, among other things, manufacturing, import, and use volumes, concentrations of substances in products, and information regarding potential releases to air, water, or soil. For certain substance groups, additional details on applications and uses are also required.

In practice, the primary challenge is often not the submission itself but the collection and consolidation of the necessary data. Information frequently needs to be gathered from multiple internal departments or obtained throughout the supply chain. In particular, determining relevant substance concentrations and volumes in complex products and international supply chains can require significant resources.

At the same time, non-compliance can result in substantial penalties. For a first conviction, fines may reach CAD 25,000 for individuals and up to CAD 500,000 for large companies. In cases of repeated violations, the maximum penalties may be doubled.

Taking Early Action to Reduce Compliance Risks 

The current information-gathering initiative also provides an indication of which substances Canadian authorities may prioritize for future assessment and potential regulatory action. Companies should therefore view the initiative not merely as a reporting obligation, but also as an early signal of possible future developments in chemicals regulation.

We support you in systematically assessing whether your business is affected, identifying relevant substances and product groups, and compiling the required information.  
Related to this topic: In our “GHS in the USA and Canada” training course, you will gain a practical overview of the current requirements for hazard communication and the regulatory specificities of both markets.

In addition, we can assist with interpreting the requirements, communicating throughout the supply chain, and preparing the submission. An early assessment increases transparency regarding existing obligations and helps companies plan and manage implementation efforts more effectively.

For more information, please contact us at  sales@kft.de or use our contact form.

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