Add 'P' Flag to 145 Polymers

Summary#

The federal government published a notice of intent to add the letter P to the identifiers of 145 polymers on the Domestic Substances List. The change would mark those specific polymer forms as meeting the reduced regulatory requirement (RRR) criteria under the Canadian Environmental Protection Act, 1999 and the New Substances Notification Regulations (Chemicals and Polymers). Comments are open for 120 days from the notice published September 16, 2023.

What it does#

• Adds the letter P after the identifiers of 145 polymers on the Domestic Substances List.
• The P flag indicates the polymer form assessed met the RRR polymer criteria in the New Substances Notification Regulations (Chemicals and Polymers), meaning it is considered lower concern and has fewer pre‑market reporting requirements.
• Clarifies that only the RRR forms of those polymers are considered on the DSL; if someone wants to import or manufacture a form that does not meet the RRR criteria above the regulatory thresholds, they must submit the information required by the Regulations so it can be assessed.
• This is a notice of intent (a proposal). The government is accepting public comments for 120 days after publication. If finalized, the order would come into force when it is registered.

Who's affected#

• Companies that manufacture or import polymers into Canada are the main group affected.
• Businesses that import or make different forms of the same polymer should check whether their specific form meets the RRR criteria; non‑RRR forms would need a formal notification and assessment before being made or imported above set thresholds.
• The public and other stakeholders can comment during the 120‑day comment period.
• It is not always clear from the notice which consumer products or industries use each listed polymer because many entries are given as CAS numbers or masked (confidential) names.

Why it matters#

• The change sharpens which polymer forms are treated as low concern and which still need environmental and health assessment before entering the Canadian market.
• For importers and manufacturers, this affects whether they must submit detailed information and wait for an assessment before bringing a polymer form into Canada in larger quantities.
• For regulators and the public, it gives Environment and Climate Change Canada a clearer basis to require assessments of higher‑risk polymer forms that were previously ambiguous on the list.