Non‑domestic Substances List Updates and SAR Rules

Summary#

Two government notices were published in the Canada Gazette on September 6, 2025. The Department of the Environment issued several orders that add or remove specific chemicals from the Non‑domestic Substances List under the Canadian Environmental Protection Act, 1999, and Innovation, Science and Economic Development Canada released updated technical procedures for measuring and simulating Specific Absorption Rate (SAR) for wireless devices.

What it does#

• Order 2025-66-04-02 Amending the Non‑domestic Substances List (signed August 27, 2025) adds the substance listed as 19739-7 Alkanediol, polymer with substituted-(substitutedalkyl)-trialkylcarbomonocycle, and N-[(3-trimethoxysilyl)propyl]carbamate to Part II of the Non‑domestic Substances List.
• Order 2025-87-04-02 Amending the Non‑domestic Substances List deletes 27026-61-5 from Part I of the Non‑domestic Substances List. This order comes into force when the related Domestic List order comes into force.
• Order 2025-87-06-02 Amending the Non‑domestic Substances List deletes 14802-03-0 and 1204391-75-2 from Part I. This order takes effect when the linked Domestic List order comes into force.
• Order 2025-87-07-02 Amending the Non‑domestic Substances List deletes 19045-79-5 and 68442-85-3 from Part I. This order also takes effect when its corresponding Domestic List order comes into force.
• Innovation, Science and Economic Development Canada published two documents:
  • RSS-102.SAR.MEAS, issue 2 — measurement procedure for assessing SAR compliance.
  • RSS-102.SAR.SIM, issue 1 — simulation procedure for assessing SAR compliance.
  • Both cover equipment operating in the 100 kHz to 6 GHz frequency range. The ISED notice is dated August 15, 2025. The documents are now official and available on ISED’s Spectrum management and telecommunications website. Comments can be submitted via the Standard Change Request form.

Who's affected#

• Companies that make, import, sell or use the specific chemicals named by their identifiers (for example, 19739-7, 27026-61-5, 14802-03-0, 1204391-75-2, 19045-79-5, 68442-85-3). The notices do not spell out which products or industries use these substances, so affected businesses may need to check their material inventories.
• Chemical suppliers, customs brokers, and environmental consultants who track regulatory listings for compliance and reporting.
• Manufacturers, test labs, and certification bodies for wireless and cellular equipment. The new RSS-102.SAR.MEAS and RSS-102.SAR.SIM documents affect how SAR testing and simulations should be done for devices that operate between 100 kHz and 6 GHz.

Why it matters#

• Changes to the Non‑domestic Substances List alter which chemicals the government tracks as non‑domestic or removes from that list. That can affect reporting duties, risk assessment follow-up, and whether importers or manufacturers need to take regulatory steps. The practical impact depends on which products actually contain these substances.
• The new SAR measurement and simulation procedures set the technical rules for proving that wireless devices meet human-exposure limits. Device makers and testing labs will use these procedures when certifying products, so the update can influence testing methods, lab workflows, and product clearance for the Canadian market.