SNAc Proposal for Cyclohexylamine

Summary#

This is a notice of intent from Environment and Health to change the Domestic Substances List under the Canadian Environmental Protection Act, 1999 so that new or expanded uses of the chemical cyclohexylamine (CAS 108-91-8) would trigger a formal pre‑use notification. The change is a proposal (not yet in force) and invites public comment for 60 days from April 9, 2022.

What it does#

• Marks the substance cyclohexylamine (CAS 108-91-8) so the Significant New Activity (SNAc) rules under subsection 81(3) of the Act would apply to certain new uses.
• Requires anyone planning one of the flagged “significant new activities” to file a Significant New Activity Notification (SNAN) with the Minister at least 90 days before starting the activity. The government will assess the information within 90 days of receiving it.
• The kinds of new uses that would trigger a SNAN include using the substance in the manufacture of:
  • consumer products covered by the Canada Consumer Product Safety Act when the substance is present at 0.1% by weight or more (with higher concentration thresholds allowed for specific products: up to 0.3% in firespace gel fuel canisters and up to 0.7% in stains/paints/coatings); and
  • cosmetics as defined in the Food and Drugs Act at 0.1% by weight or more (except aerosol hairsprays).
• Also triggers notification for any activity that uses more than 10 kg in a calendar year in such products when the substance concentration is 0.1% by weight or greater.
• Exemptions: research and development, site-limited intermediates, and products made only for export would not require a SNAN. Uses already regulated under certain other federal Acts (for example, pesticides or fertilizers) are also outside this proposed order.

Who's affected#

• Manufacturers, importers, formulators and distributors of consumer products and cosmetics that contain cyclohexylamine or use it in production.
• Businesses that would start or scale up uses that meet the concentration or annual-quantity thresholds (for example, companies adding the substance at or above 0.1% by weight, or using more than 10 kg per year).
• The notice applies to “any person” (individual or corporation) who proposes a covered new activity — not to consumers directly, although consumers could be affected if companies change product formulations or market plans.
• It is not always clear from the notice which small suppliers or downstream users might be caught; companies should check concentrations and annual use amounts against the thresholds.

Why it matters#

• The government’s screening assessment found that cyclohexylamine does not currently meet the Act’s test for immediate action, but there are human‑health concerns if exposure increases or new kinds of use appear. The SNAc rule is meant to catch those new uses early.
• If adopted, the rule would mean companies must tell the government before introducing certain new products or large new uses. That gives regulators time to decide if restrictions or other controls are needed before the public is exposed.
• For businesses, the requirement could add lead time (the SNAN must be filed 90 days before starting the activity) and extra paperwork. It could also affect product design choices (formulations, concentrations, or decisions to export only).
• For consumers, this is a preventive step intended to limit new sources of exposure to a chemical that the government identified as having potential health concerns if used differently or more widely than before.

Key facts: notice published April 9, 2022; public comments accepted within 60 days of that date; SNANs would be required 90 days before the proposed new activity begins.