Siloxane Import Conditions and Phenol SNAc

Summary#

The Canada Gazette (Part I) published two Environment notices on April 18, 2026. One is Ministerial Condition No. 22468, which allows the manufacture or import of siloxanes and silicones, di‑Me, Me 3,3,4,4,5,5,6,6,6‑nonafluorohexyl, Me stearyl (CAS 915223‑67‑5) but sets conditions. The other is Significant New Activity Notice No. 22295, which applies the Significant New Activity rules under the Canadian Environmental Protection Act, 1999 to phenol, 2-(2H-benzotriazol-2-yl)-4-methyl-6-[2-methyl-3-[1,3,3,3-tetramethyl-1-[(trimethylsilyl)oxy]-1-disiloxanyl]propyl]- (CAS 155633‑54‑8) and requires advance information for certain new uses.

What it does#

• Ministerial Condition No. 22468 (siloxane substance, CAS 915223‑67‑5)

  • Allows the notifier (the company or person who submitted information to the government on February 3, 2026) to manufacture or import the substance, but only if they follow the listed conditions.
  • Requires immediate action if the substance is released to the environment: stop further release, limit spread, and notify an enforcement officer or the regional 24‑hour emergency line as soon as possible.
  • Before transferring physical possession, the notifier must inform the recipient in writing about these conditions and get written confirmation that the recipient agrees to follow them.
  • Requires record-keeping of uses, quantities, transfers, and confirmations; records must be kept at the notifier’s main Canadian business address for at least five years and be available in English or French.
  • Comes into force on March 30, 2026.

• Significant New Activity Notice No. 22295 (phenol substance, CAS 155633‑54‑8)

  • Declares certain new uses a “significant new activity.” That means people must tell the government before they start those uses.
  • Uses that trigger the requirement:
    • Manufacture or distribution for sale of the substance in a consumer product or a cosmetic, except a face cream where the substance is at or below 6.5% by weight.
  • Exemptions:
    • Use as a research and development substance, a site‑limited intermediate, or in products made for export only.
  • Information and timing:
    • Anyone planning a significant new activity must provide detailed information (including exposure, product details, and safety data) to the Minister of the Environment at least 90 days before starting the activity.
    • The ministers will assess the submission within 90 days of receiving it.
    • Studies required for reproduction toxicity must follow OECD Guidelines and good laboratory practice.
  • Transitional rule:
    • Between publication and April 18, 2027, a use counts as a significant new activity only if it involves more than 100 kg of the substance in a year.

Who's affected#

• The notifier named in the ministerial condition (the person or company that provided information to the government on February 3, 2026).
• Manufacturers and importers of the two named chemicals.
• Companies that make or sell consumer products or cosmetics that might include the phenol substance (including formulators and brand owners).
• Distributors and downstream recipients who take physical possession of these substances or products (they must be told about the ministerial conditions).
• Laboratories and testing organizations that would carry out required studies (e.g., two‑generation reproduction toxicity tests).
• It is unclear from the notice which specific companies or products already in Canada are affected; impacted parties need to check if these CAS numbers match chemicals they handle.

Why it matters#

• The ministerial condition lets one siloxane substance be made or brought into Canada, but with rules meant to reduce accidental releases and to track where it goes. That affects safety practices and record-keeping for the company involved and anyone they supply.
• The Significant New Activity Notice means companies cannot start using the phenol substance in many consumer products or cosmetics without giving regulators time and data to assess risks. That can delay product launches, require new testing, and change supply‑chain plans.
• The transitional threshold (100 kg until April 18, 2027) gives some short‑term leeway for small volumes, but larger uses already need pre‑notification and supporting studies.
• Overall, these measures aim to give regulators more information before potentially risky uses expand, which can affect manufacturers, retailers, and ultimately consumers who might be exposed to these chemicals.