Limits on use of new chemical (CAS 2410511-02-1)

Summary#

The government published Ministerial Condition No. 22106 under the Canadian Environmental Protection Act, 1999 that allows one company (the notifier) to manufacture or import a specific chemical — bicyclo[2.2.1]hept-5-ene-2-carboxylic acid, 2-[[[[[(isocyanatophenyl)methyl]phenyl]amino]carbonyl]oxy]ethyl ester, CAS RN 2410511-02-1 — only if it follows strict conditions. The rules ban its presence in uncured form in consumer products, require written notices and confirmations before transfers, and set record-keeping obligations. The conditions came into force on June 23, 2025.

What it does#

• Limits who can make or bring the chemical into Canada: only the person who submitted information to the government on January 29, 2025 (the “notifier”) may manufacture or import it under these conditions.
• Stops the notifier from importing the substance if it is present in an uncured form in a consumer product.
• Stops the notifier from manufacturing the substance for use in a consumer product unless the substance is chemically reacted into a stable matrix and cured during the product’s manufacture.
• Requires the notifier to inform, in writing, anyone they transfer the substance to about these conditions, and to get written confirmation that the recipient agrees not to use it in an uncured form in consumer products (before the first transfer).
• Requires the notifier to keep records showing:
  • how the substance is used;
  • quantities manufactured, imported, purchased, distributed, sold and used;
  • the name and address of each transferee; and
  • the written confirmations from transferees.
• Sets timing and storage rules for records:
  • create or update records within 30 days of the information becoming available (and update transferee addresses within 30 days of learning of a change);
  • keep records in English, French, or both at the notifier’s principal place of business in Canada for at least five years;
  • electronic records must be in a readable electronic format.

Who's affected#

• Primarily the named notifier (the person who filed information on January 29, 2025) — they are the only party explicitly allowed to manufacture or import the substance under these conditions.
• Any person or company that receives the substance from the notifier. They must be told about the ministerial conditions and provide written confirmation before the first transfer.
• Potential manufacturers or importers of consumer products who might otherwise use this chemical in uncured form — they are effectively barred from doing so under these conditions.
• The notice does not name specific brands, companies, or product types beyond “consumer product,” so it is unclear from the notice exactly which products or industries use this chemical.

Why it matters#

• The ministers suspect this chemical may be harmful; these conditions are meant to limit how it enters the market and reduce the chance that people will be exposed to it in consumer goods.
• Requiring written notices, confirmations, and detailed records gives regulators a way to track quantities, who has the substance, and how it is used.
• For businesses, the rules restrict how the substance can be handled and passed down the supply chain. For consumers, the rules aim to prevent the chemical from being present in uncured form inside consumer products.