Restrictions on substance CAS 691400-36-9

Summary#

The Department of the Environment published a ministerial condition under the Canadian Environmental Protection Act, 1999 that allows the manufacture or import of the chemical 1-propanaminium, N-(3-aminopropyl)-2-hydroxy-N,N-dimethyl-3-sulfo-, N-(C12-18 and C18-unsatd. acyl) derivs., inner salts (CAS 691400-36-9) but only under strict limits and record-keeping. The ministers say they suspect the substance may be harmful, so the permission comes with limits on impurities, use in cosmetics, and paperwork. The conditions took effect on May 29, 2026.

What it does#

• Allows only the person who provided information on May 22, 2026 (the “notifier”) to manufacture or import the substance, and only if the conditions are met.
• Limits impurities:
  • the contaminant 1,3-propanediamine, N,N-dimethyl- (CAS 109-55-7) must be less than 0.01% by weight.
  • fatty acid amidopropyl dimethylamine (amidoamine) impurities must be ≤ 1.5% by weight.
• Stops use in certain cosmetics:
  • the substance cannot be used by the notifier to make a leave-on cosmetic if it would be present at more than 0.6% by weight.
  • the notifier may not import the substance when it is in a leave-on cosmetic at more than 0.6% by weight.
• Controls transfers:
  • before giving the substance to another person, the notifier must inform them in writing of the conditions and get written confirmation (at first transfer) that they will not use it in leave-on cosmetics above 0.6%.
• Record-keeping rules for the notifier:
  • keep records of uses, product concentrations, impurity levels, quantities made/imported/distributed, and recipient names/addresses.
  • create records within 30 days after the information becomes available and update address changes within 30 days.
  • keep records for at least five years at the notifier’s principal place of business in Canada.
• The ministerial conditions came into force on May 29, 2026.

Also included in the notice: an administrative order that removes CAS 12027-96-2 from Part I of the Non‑domestic Substances List. That change takes effect when a related order comes into force (the Gazette item does not give that later date).

Who's affected#

• The main affected party is the notifier — the company or person who submitted the information on May 22, 2026 and is the only one allowed to manufacture or import this substance under these conditions.
• Cosmetic makers and importers who use this ingredient in leave-on products (like lotions, serums, or makeup) will be affected because the substance is limited to 0.6% in leave-on cosmetics.
• Distributors, formulators, and downstream users who would receive the substance must be told the conditions and may be required to confirm they will not use it above the allowed levels.
• Regulators and inspectors may use the required records to check compliance.
• It is unclear from the notice whether other companies (besides the notifier) may later be permitted under different terms.

Why it matters#

• The ministers suspect the chemical could be harmful. The conditions let one company keep making or importing it while reducing potential risks through limits and tracking.
• Limits on impurities and on use in leave-on cosmetics reduce the chance that consumers will be exposed to higher levels in products they apply to skin.
• The record-keeping and transfer rules create a paper trail. That helps regulators check who had the substance and how it was used.
• For consumers, the most direct effect is that some leave-on cosmetics may not legally contain this ingredient above 0.6% if linked to this notifier. For businesses, the rules mean tighter quality control and paperwork if they handle the substance.