SNAc proposals for rosin and TMTD

Summary#

This Canada Gazette notice (Part I, 23 July 2022) from the Department of the Environment bundles several environment-related actions. It (1) issues an interim order correcting how auto makers earn greenhouse‑gas credits for advanced vehicles, (2) announces proposed changes to the Domestic Substances List that would trigger notification rules for several rosin‑related substances and for TMTD (a rubber chemical), and (3) publishes the screening results for 12 “Resins and Rosins” substances, flagging crude tall oil for follow‑up. These items affect vehicle manufacturers, chemical makers and users, and anyone concerned about environmental releases of these substances.

What it does#

• Interim Order Modifying the Operation of the Passenger Automobile and Light Truck Greenhouse Gas Emission Regulations

  • Fixes an error in how credits and deficits are calculated so companies get the intended number of CO2‑equivalent credits for advanced‑technology vehicles (electric, plug‑in hybrids, fuel cell vehicles) for model years 2017–2022.
  • Applies to end‑of‑model‑year reports and allows affected credits to be claimed when the 2022 report is submitted.
  • The order was made by Steven Guilbeault (Minister of the Environment) on July 4, 2022 and is temporary (it will stop having effect after one year unless turned into a permanent change sooner).

• Notice of intent to amend the Domestic Substances List for five rosin‑related substances

  • Targets these DSL entries: rosin (CAS RN 8050‑09‑7); tall‑oil rosin (CAS RN 8052‑10‑6); resin acids and rosin acids (CAS RN 73138‑82‑6); resin acids and rosin acids, sodium salts (CAS RN 61790‑51‑0); and resin acids and rosin acids, calcium salts (CAS RN 9007‑13‑0).
  • Would add “significant new activity” (SNAc) rules so that people must notify Environment and Health Canada before undertaking certain new manufacturing activities.
  • Notification thresholds proposed: manufacture in a calendar year greater than 1,000 kg for four of the substances, and greater than 100,000 kg for the calcium salt (CAS RN 9007‑13‑0).
  • For these SNAc proposals, the government asks that a Standard New Activity Notification be provided 90 days before starting the activity.
  • The public may comment on the proposal for 60 days after publication (July 23, 2022).

• Notice of intent to amend the Domestic Substances List for thioperoxydicarbonic diamide, tetramethyl (TMTD)

  • TMTD (CAS RN 137‑26‑8) would be subject to SNAc rules because of concerns in its screening assessment.
  • Proposed trigger: any manufacture or use related to making liquid rubber (latex) involving more than 100 kg in a calendar year.
  • Required notification would be at least 180 days before the planned activity.
  • The public may comment for 60 days after publication (July 23, 2022).

• Final screening assessment for the Resins and Rosins Group (12 substances)

  • Concludes that tall oil (CAS RN 8002‑26‑4) — in particular crude tall oil (CTO) — meets the test for concern under the Canadian Environmental Protection Act, 1999 and the government proposes adding crude tall oil to Schedule 1 (which starts risk‑management work).
  • The other 11 substances in the group were not found to meet the Act’s criteria at this time.
  • A proposed risk‑management approach for crude tall oil has been posted and is open for comment for 60 days after publication.

Who's affected#

• Auto companies and fleet manufacturers that sell passenger cars and light trucks in Canada. They will see a near‑term correction in how greenhouse‑gas credits for advanced vehicles are calculated.
• Chemical manufacturers, importers, formulators and industrial users of rosin‑related substances (paints, adhesives, rubber compounding, concrete, cosmetics, electronics, etc.). If they plan to start new or larger‑scale manufacturing activities, they may need to file advance notifications.
• Companies that manufacture or use TMTD or make liquid rubber (latex) products — especially if planned annual amounts exceed 100 kg.
• Environmental and public health groups, and communities near industrial sites that handle these substances, because the government is collecting more information and may propose controls for crude tall oil and other activities.
• General public and stakeholders who want to comment: the notices set public comment periods (60 days) after the Gazette publication (July 23, 2022).

If it’s unclear who exactly will be covered by a future order (for example, whether certain uses or mixtures are excluded), the notice says the government will provide details and that some common exemptions (like small quantities, certain regulated uses, or R&D) may apply.

Why it matters#

• For vehicle buyers and climate policy: fixing the credit calculation affects how much credit auto makers receive for selling electric and other advanced vehicles. That influences compliance costs and could indirectly affect vehicle availability and pricing.
• For businesses: the proposed SNAc listings mean companies must plan earlier. If you plan to start or scale up manufacturing or new uses of the named substances, you may have to notify regulators well in advance (from 90 to 180 days) and supply data. That can affect investment, supply chains and timelines.
• For the environment and communities: the government singled out crude tall oil as a potential environmental risk. That can lead to risk‑management measures (limits, controls, or reporting) aimed at reducing harmful releases to water and sediment.
• For public engagement: the government is asking for comments. Interested people and organizations have a real chance to provide information that could shape any future requirements.