Trisiloxane cosmetic SNAc; terpenes and melamine

Summary#

• On January 25, 2025, the federal government published several Environment notices under the Canadian Environmental Protection Act, 1999.
• Key items: a new Significant New Activity Notice No. 21912 for the silicone trisiloxane, 3-ethyl-1,1,1,3,5,5,5-heptamethyl- (CAS RN 17861-60-8) that affects some cosmetic uses; draft findings on the 14 Terpene and Terpenoid Substances Group proposing that 12 of 14 substances may be harmful and could be added to the federal list of toxic substances; and supplemental risk material about melamine (CAS RN 108-78-1) with updated health concerns. Public comments are requested on the assessments.

What it does#

• Significant New Activity (SNAc) for trisiloxane:
  • Declares certain new uses of trisiloxane (CAS RN 17861-60-8) in cosmetics to be "significant new activities."
  • Requires anyone planning such an activity to notify the Minister at least 90 days before starting and to provide specific data, including lab studies done to OECD Test No. 428, 407, and 421 methods.
  • Excludes small or specific uses: hair dye at ≤ 5%, rinse-off cosmetics at ≤ 10%, and foundation/facial makeup remover/hair gel/lipstick at ≤ 1% by weight.
  • Transitional rule: between publication and January 24, 2026, uses or sales are allowed up to 100 kg without full notification; after that threshold will be tightened.
  • Exemptions include research & development, site-limited intermediates, and export-only manufacture.
• Draft assessment of the 14 terpenes:
  • Releases a draft health and environment assessment for the 14 Terpene and Terpenoid Substances Group.
  • Proposes that 12 substances (examples include cade oil, jonquil oil, Ginkgo biloba extract, sage oil, wormwood oil, and several cyclohexanol derivatives) meet criteria in section 64 of CEPA and could be added to Part 2 of Schedule 1.
  • Proposes no further action for norlimbanol and amberlyn at this time.
  • Identifies consumer uses of concern (cosmetics, personal care, air fresheners, DIY essential oil uses) and finds margins of exposure may be inadequate for some substances.
• Melamine supplemental material:
  • Publishes an additional risk characterization for melamine (CAS RN 108-78-1) that identifies new critical human health effects and an updated risk management scope.
  • Flags consumer products of concern: melamine tableware (including “bambooware”), polyurethane-foam products (mattresses, upholstered furniture, infant/child restraint systems), paints, sealants and some cleaners.
  • Confirms the draft conclusion still proposes that melamine meets CEPA criteria for human-health risk.
• Public input:
  • Comment opportunity for the terpene assessments and the melamine material runs from January 25, 2025 to March 26, 2025.

Who's affected#

• Businesses and organizations:
  • Cosmetic manufacturers, formulators, importers and retailers using or selling products that contain trisiloxane or any of the 14 terpene substances.
  • Companies that import or make melamine or melamine-containing products (tableware, foam products, paints, sealants, cleaners).
  • Laboratories and consultants who prepare toxicology and exposure studies (because specific tests and data will be required).
• Consumers and specific groups:
  • People who use cosmetics, essential oils, air fresheners and DIY aroma products.
  • Infants and children, and people of reproductive age — identified as potentially more vulnerable in the assessments, especially for some terpene exposures and melamine in household items.
• If unclear:
  • Some uses (industrial acts listed in CEPA Schedule 2, wastes, impurities, certain mixtures) are excluded; businesses should check the full notices or consult the government if they’re unsure whether a use is covered.

Why it matters#

• For companies: the SNAc for trisiloxane means you may need to delay new cosmetic uses until you submit data and wait the required period. That can affect product launches, sourcing and reformulation decisions. The tests required can also be costly and take time.
• For product safety: the draft conclusions on the 14 terpenes and the new melamine material highlight potential health risks from everyday products (cosmetics, essential oils, tableware, mattresses, furniture). If finalized, these findings can lead to restrictions, new labelling, or changes in how products are made and sold.
• For consumers: the notices flag specific product types and groups (infants, children, pregnant people) that may face higher exposures. The public can read the assessment documents and submit comments until March 26, 2025 to influence next steps.
• For everyone: these are early regulatory steps — the terpene conclusions are proposals and melamine risk management is being scoped. Final rules or controls would come later after assessment, consultation, and further decisions by government.