264 Polymers flagged P; Piperazine SNAc

Summary#

The federal government is asking for comments on two Environment notices published in the Canada Gazette on May 11, 2024. One proposes adding the letter “P” to the entries for 264 polymers on the Domestic Substances List to show they met reduced regulatory requirements. The other proposes applying Significant New Activity rules to the chemical piperazine (CAS 110-85-0) so certain new uses or imports must be reported before they happen.

What it does#

• Adds the letter “P” to the identifiers of 264 polymers on the Domestic Substances List.

  • The “P” flag means the assessed form met the reduced regulatory requirement (RRR) polymer criteria under the New Substances Notification Regulations (Chemicals and Polymers).
  • It clarifies that other forms of those polymers that do not meet RRR criteria would need notification and assessment before manufacture or import.
  • Public comment period: 120 days.

• Proposes to apply the Significant New Activity (SNAc) provisions of the Canadian Environmental Protection Act, 1999 to piperazine (CAS 110-85-0).

  • If someone plans a qualifying new activity, they must submit a notification with specific information at least 90 days before starting.
  • The proposed SNAc triggers focus on: manufacturing or importing piperazine in consumer products or cosmetics at or above 0.1% by weight; for epoxy adhesives or plastic bonder epoxy products a higher concentration cutoff of 1.5% is used; and importation of more than 10 kg of piperazine in such products in a calendar year.
  • Some uses are excluded, such as research-and-development forms, site-limited intermediates, export-only shipments, and certain regulated products.
  • The government’s assessment concluded piperazine does not currently meet the law’s thresholds for immediate action, but SNAc is being proposed because new uses could change exposure and risk.
  • Public comment period: 60 days.

Who's affected#

• Chemical manufacturers, formulators and importers who make or bring into Canada any of the listed polymers, especially if they produce non‑RRR forms of those polymers.
• Companies that make, import or sell products containing piperazine (CAS 110-85-0), especially:
  • makers or importers of consumer products covered by the Canada Consumer Product Safety Act,
  • makers or importers of cosmetics as defined under the Food and Drugs Act, and
  • producers or users of epoxy adhesives and plastic bonder epoxy products.
• Suppliers and retailers may need to check product ingredient levels and supply chains to know whether a notification is required.
• It is unclear from the notice which specific companies or brands will be affected; the changes target substance forms and concentrations rather than named businesses.

Why it matters#

• The polymer change closes a long-standing gap. It makes clear that only the low‑concern (RRR) forms of those 264 polymers are treated as already listed. Other forms now face a pre‑market notification requirement so the government can assess safety first.
• For piperazine, the SNAc proposal means some new uses or larger imports will need prior notification. That gives regulators a chance to review potential health or environmental impacts before products reach consumers.
• Businesses may need to do more testing, record‑keeping, or change formulations to avoid notification thresholds. That can affect product design, sourcing and import planning.
• Consumers are unlikely to notice immediate changes, but the measures are intended to improve oversight of chemicals that could affect health or exposure if used differently in the future.