Chemical Import Limits and Ivory Gull Habitat Protection

Summary#

• The Canada Gazette published two Environment notices on July 12, 2025.
• One is Ministerial Condition No. 22106 under the Canadian Environmental Protection Act, 1999, which allows a specific chemical (CAS 2410511-02-1) to be made or imported but only under strict conditions. The other applies protections for the Ivory Gull (Pagophila eburnea) under the Species at Risk Act to critical habitat inside the Naujavaat Bird Sanctuary starting 90 days after publication.

What it does#

• Ministerial Condition No. 22106 (chemical)

  • Allows the notifier (the company or person who provided information on January 29, 2025) to manufacture or import the substance 2410511-02-1, but only under the listed conditions.
  • Prohibits importing or manufacturing the substance if it is present in an uncured form in a consumer product.
  • Permits import or manufacture for consumer products only if the substance is chemically reacted into a stable matrix and cured during manufacture.
  • Requires the notifier to inform, in writing, anyone they transfer the substance to about the conditions and to get written confirmation that recipients will not use it to make consumer products unless cured.
  • Requires detailed record-keeping about uses, quantities, transfers and confirmations; records must be created within 30 days, kept at the notifier’s principal place of business in Canada, and retained for 5 years.
  • These conditions came into force on June 23, 2025.

• Ivory Gull critical habitat (species protection)

  • Declares that the critical habitat identified in the recovery strategy for the Ivory Gull (Pagophila eburnea) and located within the Naujavaat Bird Sanctuary will be subject to subsection 58(1) of the Species at Risk Act.
  • That protection takes effect 90 days after the Gazette notice (published July 12, 2025). The notice does not list specific activity bans here — it applies the legal protection to the mapped critical habitat inside the sanctuary.

Who's affected#

• Chemical notice

  • The notifier who submitted information and any businesses that import, sell, transfer or plan to use the specific chemical (CAS 2410511-02-1).
  • Manufacturers of consumer products who might otherwise use the substance in uncured form.
  • Downstream recipients who will have to confirm in writing they understand and will follow the conditions.

• Ivory Gull / habitat notice

  • People and organizations that carry out activities inside the Naujavaat Bird Sanctuary in Nunavut — for example, federal managers of the sanctuary, researchers, and any commercial or local users operating in that area.
  • The notice does not name specific companies or communities and does not list the exact activities that will be restricted in the critical habitat.

Why it matters#

• Chemical notice

  • It lets one party continue to import or make a potentially harmful chemical while forcing steps to reduce the chance it ends up uncured in consumer products. The added record-keeping and transfer rules make it easier for regulators to track where the substance goes.

• Ivory Gull / habitat notice

  • Extending legal protection to critical breeding habitat inside the Naujavaat Bird Sanctuary strengthens measures to help the endangered Ivory Gull, which breeds only in Nunavut and needs predator-free breeding sites. For people working or travelling in the sanctuary, this can mean new legal limits or consultation requirements aimed at protecting that habitat.