New Canadian Chemical Reporting Requirements

Canadian companies or companies doing business in Canada will now be required to report the use of certain chemicals under the Canadian Environmental Protection Act (CEPA). 

On Aug. 29, the Government of Canada published Notice with respect to certain substances under the Chemicals Management Plan (CMP) 2026 — Phase 1 and Phase 2 under Section 71 of CEPA. Reporting for Phase 1, which covers 184 substances, has already begun, with a deadline of March 3, 2027; Phase 2 covers 16 substances, with reporting beginning March 4, 2027, and a deadline of Sept. 8, 2027.

"The purpose of these notices is to gather information from Canadian manufacturers, importers, and users on the commercial status, facility information (for example, releases), and uses of substances identified by the Government of Canada as priorities under the Chemicals Management Plan," states the Canadian government in a guidance document for Section 71 notices.

Environment and Climate Change Canada (ECCC) and Health Canada will use the information collected to inform prioritization decisions, risk assessment actions, and risk management measures, if needed.

Which companies are affected by new CEPA reporting requirements?

The notices apply to companies that manufactured, imported, or used listed substances above defined reporting thresholds during 2025. For most substances, the reporting threshold is 100 kg, while some substances are subject to a 1,000 kg threshold. The notice also captures substances contained in mixtures, products, and manufactured articles when concentrations exceed specific limits. Special attention is given to substances present in consumer products, children's products, food-contact materials, cookware, textiles, furniture, flooring, bedding, and other articles that may result in direct human exposure.

What are affected companies required to report?

Organizations meeting the reporting criteria must submit detailed information through ECCC's Single Window online reporting. Required information includes company identification details; quantities manufactured, imported, used, or exported; product applications; substance functions; descriptions of products containing the substances; and information on commercial, consumer, and child-related uses. Companies must also identify any unpublished studies or data relevant to the listed substances that have not already been provided to the Government of Canada.

The notices further require facility-level reporting where significant quantities of substances may have been released to the environment. Facilities must provide information such as location, industry classification codes, quantities handled, descriptions of activities involving the substances, and whether releases to air, water, or land are monitored. This information will help regulators better understand substance use patterns and potential environmental releases across Canada. 

Potential fines, information for industry

Failing to comply or providing false or misleading information can result in significant penalties, including fines that may reach $500,000 for large corporations for a first offence, with higher penalties for repeat violations. Companies may request reporting deadline extensions or submit confidentiality claims where justified under CEPA provisions. 

More information on the management of chemical substances can be found on the Government of Canada's Chemicals Management Plan webpage. For information on data gathering initiatives, including links to the notices, Excel Reporting File (ERF), and substance list, visit the Information gathering initiatives webpage.

What should companies do?

Companies that manufacture, import, or use chemicals in Canada should:

1. Screen inventories against the 184 priority substances covered by the notice.
2. Collect volume, concentration, use, facility, release, and study information
3. Prepare their submission before the reporting deadline on March 3, 2027

Starting early on preparing the submission is recommended, especially where companies must obtain composition or other supply-chain information from their suppliers.