264 Polymers Flagged 'P' and Piperazine SNAc

Summary#

• Environment and Climate Change Canada published two related notices on May 11, 2024 about substances on the Domestic Substances List (DSL).
• One notice proposes adding the letter "P" to the identifiers of 264 polymers to show they meet the reduced regulatory requirement (RRR) polymer criteria; another sets out plans to require advance notification for certain new uses of piperazine (CAS 110-85-0) after a health assessment.

What it does#

• Polymers:

  • Proposes to add the letter "P" to the identifiers of 264 polymers on the Domestic Substances List (DSL).
  • That letter marks the assessed form of the polymer as a reduced regulatory requirement (RRR) polymer.
  • If a company wants to import or make a form of one of these polymers that does not meet the RRR criteria, it would have to give the government notification under the New Substances Notification Regulations (Chemicals and Polymers) before doing so.
  • The public can comment on this proposal within 120 days of the notice.

• Piperazine:

  • The ministers assessed piperazine (CAS 110-85-0) and concluded it does not currently meet the test in section 64 of the Canadian Environmental Protection Act, 1999, so no immediate regulatory action is planned.
  • Despite that, the government intends to amend the DSL so that the Significant New Activity (SNAc) rules apply to piperazine. That means people must notify the government before starting certain new uses.
  • The proposed notification triggers include: manufacturing or importing products that contain piperazine at concentrations of 0.1% by weight or more (with an exception for epoxy adhesives/plastic bonder epoxy products where the trigger is 1.5% by weight), or importing more than 10 kg of piperazine in those products in a year.
  • Anyone proposing a covered new activity would need to provide required information at least 90 days before starting it.
  • The public can comment on this proposal within 60 days of the notice.

Who's affected#

• Companies that make, import, formulate, or sell:
  • Polymers and products that contain those polymers.
  • Products that contain piperazine, including some paints and coatings, industrial uses (such as chemical intermediates and gas-scrubber applications), epoxy adhesives, certain veterinary medicines, and potentially cosmetics or flavoring uses (these uses were identified in the assessment).
• Product formulators, importers and retailers who handle consumer products or cosmetics that could contain piperazine at or above 0.1% by weight.
• Environmental and health stakeholders who track chemical assessments.
• It is unclear from the notice whether every listed polymer or every user of piperazine will be affected; impact depends on the exact form, concentration, and how a substance is used or imported.

Why it matters#

• For polymers: adding "P" makes it clear which forms of the listed polymers were considered low concern. That lets regulators require assessment before higher‑risk forms are brought into Canada. This reduces the chance that an unassessed, non‑RRR form of a polymer is manufactured or imported without oversight.
• For piperazine: even though the assessment found no current need for restrictions, applying the SNAc rules means the government will get advance notice about new uses that could increase public or environmental exposure. This gives officials time to assess risks and, if needed, act before widespread use or importation occurs.
• Both items give businesses and the public a chance to comment: 120 days for the polymer change and 60 days for the piperazine SNAc proposal.