145 Polymers to Receive P Flag

Summary#

Environment and Climate Change Canada published a notice proposing to add the letter "P" to the identifiers of 145 polymers on the Domestic Substances List. The change would mark those polymers as having met the reduced regulatory requirement (RRR) criteria; any non‑RRR forms would need a separate review before being imported or manufactured in Canada. The notice was published on September 16, 2023 and invites comments for 120 days.

What it does#

• Adds the letter "P" next to the identifiers of 145 polymers already on the Domestic Substances List to show the assessed forms meet the reduced regulatory requirement (RRR) polymer criteria.
• Clarifies that only the RRR forms are treated as listed on the Domestic Substances List. Forms that do not meet the RRR criteria would be treated as new for regulatory purposes and would trigger notification requirements under the New Substances Notification Regulations (Chemicals and Polymers).
• Provides the list of affected substances by Chemical Abstracts Service registry numbers and confidential substance identity numbers in the proposed order.
• This is a proposal (a notice of intent), not a final rule. Comments are being accepted for 120 days and any final order would be published later in the Canada Gazette, Part II.

Who's affected#

• Companies that manufacture or import polymers into Canada, especially those that make or bring in forms that do not meet the RRR criteria.
• Manufacturers and product formulators that use these specific polymers in paints, coatings, adhesives, plastics, or other goods.
• Regulators and compliance staff who manage chemical notifications and assessments.
• It is unclear from the notice which specific downstream products will be affected without checking the substance list (the proposed order includes the identifiers).

Why it matters#

• The change makes regulatory status clearer. Businesses will know that only the RRR forms are exempt from full notification — other forms will need pre‑market reporting and assessment.
• That means some polymer forms that have been imported or made without notification might require review before they can be brought into Canada in the future.
• For the public, it increases the chance that non‑RRR polymer forms will be evaluated for possible health or environmental risks before they enter the Canadian market.