Limits on cosmetic ingredient CAS 691400-36-9

Summary#

The federal government has allowed the manufacture and import of a specific chemical under the Canadian Environmental Protection Act, 1999, but only under a set of conditions. Those conditions limit certain impurities, restrict use in leave-on cosmetics to 0.6% or less, require written warnings to buyers, and mandate record-keeping. The conditions come into force on May 29, 2026.

What it does#

• Permits the notifier (the person who provided required information to the government on May 22, 2026) to manufacture or import the substance named in Ministerial Condition No. 22545, but only while the conditions are met.
• Sets impurity limits:
  • the impurity 1,3-propanediamine, N,N-dimethyl- (CAS 109-55-7) must be less than 0.01% by weight; and
  • fatty acid amidopropyl dimethylamine (amidoamine) impurities must be ≤ 1.5% by weight.
• Restricts cosmetic use:
  • the substance cannot be manufactured or imported for use in a leave-on cosmetic where it is present above 0.6% by weight; and
  • the substance cannot be imported when it is already present in a leave-on cosmetic above 0.6% by weight.
• Requires the notifier, before handing the substance to anyone, to:
  • inform that person in writing about these conditions; and
  • obtain written confirmation (on the first transfer) that the recipient agrees not to use the substance in leave-on cosmetics above 0.6%.
    (This requirement does not apply when the substance is transferred while already contained in a final product.)
• Requires record-keeping:
  • keep records showing uses, concentrations in products, impurity levels, quantities manufactured/imported/distributed, and the names and addresses of recipients;
  • create records within 30 days of when information becomes available, update address changes within 30 days, and keep records for at least five years at the notifier’s principal place of business in Canada; and
  • electronic records must be in an electronically readable format and can be in English, French, or both.
• Comes into force on May 29, 2026.

Who's affected#

• The notifier named in the ministerial conditions — the company or person who filed the required information on May 22, 2026. The conditions explicitly allow that notifier to manufacture or import the substance under the listed rules.
• Manufacturers and importers of the substance or products containing it, especially those involved with cosmetics.
• Makers, importers and sellers of leave-on cosmetics (for example, moisturizers, makeup, baby creams, perfumes) — they cannot use or import products with the substance over 0.6% by weight.
• Distributors and downstream recipients who will be asked in writing to confirm they will not use the substance in leave-on cosmetics above the limit.
• Regulators and enforcement staff who will check records and compliance.

If it is unclear whether parties other than the notifier may be allowed to manufacture or import under different arrangements, the notice itself does not clearly say so.

Why it matters#

• The conditions aim to limit consumer exposure by capping the substance’s amount in leave-on cosmetics at 0.6% and by limiting certain impurities to very low levels (0.01% and 1.5%).
• Businesses that make, import, distribute or use the substance will need to adjust sourcing, labeling, contracts, and record-keeping to meet the rules.
• The written-notice and five-year record requirements create a paper trail that helps regulators monitor and enforce the restrictions.
• For most consumers, the immediate effect is reduced risk of higher concentrations of this chemical in leave-on personal-care products.