Conditions for cyclohexanecarboxamide sodium salt

Summary#

The Government has issued Ministerial Condition No. 22460 under the Canadian Environmental Protection Act, 1999 that allows the substance cyclohexanecarboxamide, N-[2-[(ethylsulfonyl)amino]-5-(trifluoromethyl)-3-pyridinyl]-, sodium salt (CAS RN 141284-73-3) to be manufactured or imported, but only under specific conditions. The ministers involved say they suspect the substance may be toxic, and the conditions focus on advance notice, controls, incident reporting and record-keeping. The conditions come into force on June 30, 2026.

What it does#

• Allows the person who provided required information to the minister on June 22, 2026 (the “notifier”) to manufacture or import the substance, but only if they follow these conditions.
• Requires the notifier to tell the minister at least 120 days before starting manufacture in Canada and to provide:
  • the anticipated annual quantity to be made;
  • the manufacturing facility address in Canada;
  • exposure information, including transportation and storage modes, container types, likely environmental receivers, expected releases to municipal wastewater, recommended disposal or destruction methods, past and likely uses, and any factors that limit environmental exposure;
  • basic manufacturing details, including precursors, reaction stoichiometry, whether the process is batch or continuous, scale, a process flow diagram, and descriptions of major steps and release-prevention measures;
  • a summary of all other information and test data the notifier has about hazards and exposure.
• If any release to the environment or a waste containing the substance occurs, the notifier must immediately stop further release, limit its spread, and notify either an enforcement officer or the province/territory’s 24-hour emergency telephone service as soon as possible.
• Before transferring physical possession or control of the substance to anyone, the notifier must:
  • give that person the written terms of these ministerial conditions; and
  • get written confirmation that the person was informed and agrees to comply.
• Keeps record rules:
  • keep records of use and quantities manufactured, imported, purchased, distributed, sold and used, and the names and addresses of people who received the substance, plus the written confirmations noted above;
  • create records within 30 days after the information becomes available and update recipient address changes within 30 days of learning them;
  • 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 format.

Who's affected#

• Primarily the specific notifier (the person who supplied information on June 22, 2026) — they are explicitly allowed to manufacture or import the substance but must follow the conditions.
• Any company or person who would receive the substance from the notifier, because they must be told about the conditions and agree in writing to follow them.
• Manufacturing facilities that might produce the substance in Canada (they will need to supply advance notices and process information).
• Local emergency responders and wastewater operators could be involved if a release occurs and must be notified.
• It is unclear from the notice whether other parties besides the named notifier will be allowed to manufacture or import under these same conditions.

Why it matters#

• The government is allowing controlled manufacture or import even though it suspects the substance may be harmful. The conditions are designed to limit environmental and public exposure before wider use happens.
• Advance notice, manufacturing details and record-keeping make it easier for regulators to track where the substance is made, who holds it, and how it is handled. That helps with oversight and potential emergency response.
• The requirement to notify emergency services immediately if a release occurs aims to reduce harm to people and the environment.