Pre-notification rule for three naphthalene sulfonates

Summary#

This is a notice of intent under the Canadian Environmental Protection Act, 1999 to change the Domestic Substances List so that special pre-notification rules apply to three chemicals. If adopted, people proposing certain new or larger uses of these chemicals would have to tell the government and provide information before starting.

What it does#

• Adds a "significant new activity" requirement (often called Significant New Activity (SNAc)) for these three substances on the Domestic Substances List:
  • Naphthalenesulfonic acid, dinonyl- (DNNSA), CAS 25322‑17‑2
  • Naphthalenesulfonic acid, dinonyl-, barium salt (BaDNNSA), CAS 25619‑56‑1
  • Naphthalenesulfonic acid, dinonyl-, calcium salt (CaDNNSA), CAS 57855‑77‑3
• Triggers the requirement to submit a notification at least 90 days before beginning a covered new activity.
• Sets the notification thresholds that would trigger a requirement:
  • manufacture of a substance at or above 5,000 kg in a calendar year;
  • use of a substance at or above 5,000 kg in a calendar year (including as a site‑limited intermediate or as a substance intended only for export);
  • use of a substance in metalworking fluids or for research and development at or above 1,000 kg in a calendar year.
• Specifies the kind of information the notifier would have to provide, for example:
  • a description of the proposed activity and the anticipated annual quantity;
  • if known, the top sites in Canada where it will be made or used and quantities by site;
  • test data, process flow diagrams, estimates of releases and proposed waste‑management measures.
• Opens a public comment period of 60 days from the notice’s publication. Comments can be submitted through Environment and Climate Change Canada’s online Single Window, by mail to the Program Development and Engagement Division, or by email to substances@ec.gc.ca.

Who's affected#

• Any person or company (manufacturers, importers, users) planning to start or expand activities with DNNSA, BaDNNSA, or CaDNNSA that meet the thresholds above.
• Businesses that formulate products containing these chemicals (for example lubricants, paints, or industrial fluids), and firms that use them in metalworking or R&D at scale.
• Suppliers who transfer physical control of these substances — they may need to notify customers about the obligations.
• The notice says the requirement applies to “any person,” so individuals and corporations proposing covered activities would be affected.

Why it matters#

• The rule is an early-warning step. It forces companies to tell the government about new or larger uses before those uses happen.
• That lets the government assess whether a proposed use could increase environmental or health risks, and act before exposure levels grow.
• For businesses, it means extra steps (planning, data gathering and a waiting period) before scaling up or changing how they use these chemicals.
• For the public and local communities, it aims to reduce the chance of unexpected pollutant releases and supports safer decision-making about new industrial uses.