New Canadian Chemical Reporting Requirements Apply Broadly

On August 29, 2026, Environment and Climate Change Canada (ECCC) published two notices under section 71 of the Canadian Environmental Protection Act, 1999 (CEPA) requiring certain businesses that manufactured, imported or used listed substances during the 2025 calendar year to submit information to ECCC. The notices cover 200 substances and may apply to businesses across a broad range of industrial, commercial and consumer-facing sectors, not just chemical manufacturers.

Specifically, any business that manufactured, imported or used a listed substance in a manufacturing process in 2025 may be subject to the reporting requirements, even where the substance was contained in an imported mixture or product, or was used to manufacture a good but is not present in the final product.

This bulletin provides an overview of the reporting requirements, including who may be required to report, the applicable thresholds and deadlines, and the information businesses may need to submit to ECCC.

Overview of the Mandatory Reporting Requirements

Section 71 of CEPA empowers the Minister of Environment, Climate Change and Nature (Canada) to require businesses to submit information for assessing whether substances are or may become toxic and warrant controls. Businesses subject to the notices must submit specified information in their possession or to which they may reasonably be expected to have access.

The reporting initiative is divided into two notices:

• The Notice with respect to certain substances under the Chemicals Management Plan – 2026 Phase 1 covers 184 substances. Information may be submitted beginning August 29, 2026, with responses due by March 3, 2027.
• The Notice with respect to certain substances under the Chemicals Management Plan – 2026 Phase 2 covers 16 substances. Information may be submitted beginning March 4, 2027, with responses due by September 8, 2027.

For both notices, the relevant reporting year is the 2025 calendar year. A separate response must be submitted for each notice through ECCC’s Single Window reporting system. While reports are due by the dates listed above, entities that may have reporting obligations can request an extension by sending a written request containing certain required information to ECCC before the relevant deadline. 

Who May Be Required to Report?

The notices generally apply where a business exceeded a specified quantity threshold (typically more than 100 kilograms (kg) or 1,000 kg, depending on the substance) during the 2025 calendar year by:

• Manufacturing a listed substance
• Importing a listed substance, whether alone or in mixtures, products or certain manufactured items
• Using a listed substance in the manufacture of a mixture, product or manufactured item
• For certain listed substances, using the substance in other activities

The importing trigger is particularly broad. A business may be required to report where it imported a listed substance alone, in a mixture or product, or in certain categories of manufactured items. For several listed substances, ten categories of manufactured items trigger reporting, including:

• Items intended for use by or for children under 14
• Items intended to contact an individual’s mucous membranes, such as the mouth, nose or lips (other than eyes)
• Items intended to release the substance so it may be inhaled or contact an individual’s skin
• Cookware or cooking/serving utensils intended to contact heated food or beverages
• Food packaging materials (including single-use bowls, plates, cups, food cans and lid liners)
• Reusable food or beverage containers
• Clothing or footwear
• Bedding, sleeping bags or towels
• Residential furniture, mattresses, cushions or pillows (where the substance is in foam, leather or textiles)
• Residential carpet, vinyl or laminate flooring, or foam underlay

When Is Reporting Required?

The reporting criteria depend on the substance, the activity and, in some cases, the type of good in which the substance was contained.

The principal quantity thresholds are more than 100 kg or more than 1,000 kg, depending on which part of the schedule lists the substance of concern. For imports and certain uses, a concentration threshold of at least 0.1% by weight may also apply to substances present in products and manufactured items. 

Businesses may need to determine:

• The total quantity of the substance manufactured, imported or used during 2025
• Whether the substance was alone or contained in a mixture, product or manufactured item
• The concentration of the substance
• The type and intended use of any manufactured item containing the substance
• For certain substances, whether the substance or good falls within a specified application or use (e.g., degreasers, paint strippers or brake fluid)

This assessment may require a review of purchasing, customs, manufacturing and product-composition records, together with information obtained from suppliers or other participants in the supply chain.

ECCC has published guidance, examples and flowcharts to assist businesses in determining whether they are required to report and what information must be submitted. 

What Information Must Be Reported?

Once a business meets the reporting criteria, the notices may require additional information, including:

• Total quantities manufactured, imported, used in manufacturing, exported, or used in another activity
• Information concerning goods sold that contained the substance, including their concentrations, applications and the functions performed by the substance
• Descriptions and common or generic names of goods
• Whether goods were intended for commercial or consumer use, or for use by or for children
• Facility names, addresses and applicable North American Industry Classification System codes
• Quantities manufactured or used at individual facilities
• Whether releases to air, water or land were monitored
• The titles of certain unpublished data or studies relating to the substance

Key Takeaways

The notices apply well beyond traditional chemical manufacturers. As such, organizations that import goods containing any of substances listed in the notices, use listed substances in manufacturing processes, or sell products containing listed substances should assess whether they meet the reporting criteria.

Importers should pay particular attention to the ten categories of manufactured items that trigger reporting, while also examining any mixtures and other products brought into Canada that may contain one or more listed substances. Determining whether goods contain listed substances and fall within the prescribed manufactured item categories may require composition and concentration information from foreign suppliers.

Because the notices look back at 2025 activities, relevant information may be spread across procurement, customs, operations, environmental, product stewardship and supply-chain records. An early assessment can help identify gaps and provide time to gather the required information before the applicable reporting deadline.

For more information or for assistance in responding to the notices, please contact the authors or any other member of our Environmental group.