Listing proposed for four triarylmethane dyes

Summary#

This is a proposed Order Adding Toxic Substances to Schedule 1 to the Canadian Environmental Protection Act, 1999 published April 2, 2022. It would add four dye chemicals to the law’s list of “toxic substances,” which would allow the federal ministers (Environment and Health) to develop risk-management actions later. The order itself would not create new rules right away. The public had 60 days to comment after publication.

What it does#

• Adds four non‑sulfonated triarylmethane dyes to Schedule 1 of the Canadian Environmental Protection Act, 1999:
  • Malachite Green
  • Basic Violet 3
  • Basic Violet 4
  • Basic Blue 7
• Records the assessment finding that all four meet the law’s ecological test for being “toxic,” and that Malachite Green also meets the law’s human‑health test.
• Does not itself ban or restrict these substances. Instead, it gives Environment and Climate Change Canada and Health Canada the authority to propose specific risk‑management measures (which would be consulted on separately).
• Notes industry reporting that each of these substances was imported to Canada in the range of 1,000 kg to 100,000 kg in a single year (no domestic manufacture above the 100 kg reporting threshold was reported).

Who's affected#

• Companies that import, formulate or use these dyes, such as:
  • pulp and paper mills (dyeing and deinking)
  • ink, toner and colourant manufacturers
  • formulators of consumer products and industrial products
  • manufacturers and importers of cosmetics, hair dyes and some medical/lab products
  • suppliers of aquarium fish treatments
• Businesses that make or handle food packaging where one dye may be used (noting most are not permitted food additives).
• Consumers who buy products that may contain these dyes (cosmetics, hair dyes, aquarium products, some printed materials).
• Governments and regulators, if they choose to propose specific controls later.
• It is unclear exactly which firms or product lines will be targeted until specific risk‑management measures are proposed.

Why it matters#

• The environmental assessment found these dyes can harm aquatic life at low concentrations and tend to persist in water and sediment. That matters for rivers, lakes and the animals that live there.
• The human‑health assessment found Malachite Green may pose a risk from skin contact (dermal exposure). The other three dyes were not found to pose current human‑health risks at reported levels, but could be of concern if exposure increased.
• If the government follows up with controls, businesses could face new limits, product changes, testing or labelling requirements. Consumers could see some products changed or removed.
• Adding a substance to Schedule 1 is a key step that enables formal regulation; it signals that the government may act to reduce environmental and health risks from these dyes.