Notification Rules for Two Esters in Cosmetics

Summary#

On May 2, 2026, the government issued two Significant New Activity (SNAc) notices under the Canadian Environmental Protection Act, 1999. The notices cover alkanedioic acid, di‑branched alkyl ester (CSIN 19814‑2) and hexanedioic acid, 1,6‑diisotridecyl ester (CAS 26401‑35‑4) and require companies to notify regulators before using them in certain consumer products or cosmetics at or above 0.1% by weight.

What it does#

• Declares that using either substance in the manufacture or sale of a consumer product (excluding machine lubricants) or a cosmetic at concentrations of 0.1% by weight or more is a “significant new activity.”
• Requires the person proposing such a new use to send a Significant New Activity Notification at least 90 days before the activity starts.
• Lists the kinds of information that must be provided, including:
  • anticipated annual quantity;
  • chemical identity (name, CAS or CSIN if available, trade names) and a safety data sheet if available;
  • how people (including children) would be exposed — concentration, frequency, duration, route;
  • the product description, intended use and concentration in the product;
  • toxicity information, including reproductive and developmental tests following OECD methods and studies of dermal penetration;
  • any other relevant data the notifier already has, plus contact information and a signed certification.
• Says the government (the Minister of the Environment and the Minister of Health) will assess the submitted information within 90 days after receiving a complete file.
• Excludes certain activities from the notice:
  • use as a research and development substance or as a site‑limited intermediate, and manufacture for export only;
  • uses already regulated under the Pest Control Products Act, Fertilizers Act, or Feeds Act.
• Includes transitional thresholds running until May 2, 2027:
  • For alkanedioic acid, di‑branched alkyl ester (CSIN 19814‑2), the notice applies immediately, but uses up to 100 kg in a calendar year are allowed during the transition; uses above 100 kg must follow the notification rules.
  • For hexanedioic acid, 1,6‑diisotridecyl ester (CAS 26401‑35‑4), the transition limit is 1 000 kg in a calendar year; uses above 1 000 kg must follow the notification rules.

Who's affected#

• Manufacturers, importers, distributors and formulators of consumer products and cosmetics that might contain either substance at 0.1% or higher.
• Retailers and downstream companies could be affected if they plan to distribute products that exceed the stated concentration or quantity thresholds.
• Researchers and companies that only use the substances for limited R&D, or make products solely for export, are generally not affected.
• It is unclear from the notice whether these substances are currently present in Canadian products; the notices say the substances are not listed on the Domestic Substances List.

Why it matters#

• The government is asking for information before these substances are put into new consumer or cosmetic uses because officials suspect such uses could create health or environmental risks.
• Companies planning to start or increase use may face extra paperwork and planning — notifications must be prepared and submitted 90 days ahead, and necessary studies (e.g., OECD tests) can be costly and take time.
• The rules aim to give regulators the data they need to assess risk before products reach consumers, which could lead to limits or controls if harms are found.