TL;DR
- Canada published two new Chemicals Management Plan notices on August 29, 2026, covering 200 substances in total.
- Phase 1 covers 184 substances; Phase 2 covers 16.
- Companies meeting the specified reporting criteria are legally required to respond under section 71 of the Canadian Environmental Protection Act.
- Phase 1 responses are due March 3, 2027; Phase 2 reporting runs later, with a September 8, 2027 deadline.
- Importers and users may need composition, quantity and supplier information that is not currently held inside Regulatory or EHS systems.
Why This Matters
This is not a voluntary consultation. For companies that meet the reporting thresholds, Canada’s new notices create an actual information-production obligation.
Environment and Climate Change Canada and Health Canada published the two notices in the Canada Gazette on August 29, 2026, under paragraph 71(1)(b) of the Canadian Environmental Protection Act, 1999. Phase 1 covers 184 substances and Phase 2 covers 16.
The government says the information will support:
- prioritization;
- risk assessment;
- potential risk-management decisions.
For life-sciences companies, the practical challenge may not be understanding the law.
It may be finding the requested data across: procurement → supplier specifications → product formulation → imports → manufacturing → facility use → customers.
The First Question: Are You Actually Required to Report?
The notices use different thresholds depending on where a substance appears in the schedule.
For some listed substances, reporting is triggered when a company manufactured, imported or used more than 100 kg during 2025, subject to the concentration and activity criteria.
For another group, the threshold is 1,000 kg. Certain substance groups are reportable only for specified applications or uses. This means companies should not start by trying to complete the entire reporting file.
Start with applicability. A useful workflow is: Substance list → 2025 activity → quantity → concentration → use/application → reporting obligation
That is much more efficient than sending a 200-substance spreadsheet to every site and asking, “Do we use any of these?”
The Reporting Dates Are Different
- Phase 1 reporting begins with publication of the notice and ends March 3, 2027.
- Phase 2 begins March 4, 2027 and closes September 8, 2027.
- Separate responses are required for each notice.
That suggests companies should run one coordinated internal program but preserve two regulatory deliverables.
“Reasonably Accessible Information” Is the Important Phrase
Canada’s guidance says companies subject to the notices must provide information they possess or could reasonably be expected to access.
That includes information held by:
- employees;
- company agents;
- suppliers;
- customers;
- product documentation;
- import records;
- Safety Data Sheets;
- technical data sheets.
Importers are specifically expected to make reasonable efforts to obtain substance information from suppliers. The government even provides a letter companies can use when contacting foreign suppliers.
This makes supplier responsiveness part of regulatory readiness.
What Companies Do NOT Have to Do
The guidance states that companies are not required to perform new testing merely to comply with the notices. The obligation is primarily about assembling and reporting reasonably accessible information.
However, if relevant information should reasonably exist somewhere in the supply chain, simply saying “we don’t have it” may not be enough. The company should be able to demonstrate reasonable attempts to obtain it.
Where Life-Sciences Companies Could Be Affected
The substance list should be screened against more than active pharmaceutical ingredients.
Relevant substances may occur in:
- formulation ingredients;
- excipients;
- process chemicals;
- laboratory reagents;
- cleaning materials;
- device materials;
- packaging;
- coatings;
- cosmetics;
- supplements;
- manufacturing aids;
- imported finished goods.
A regulatory team looking only at registered product composition could miss operational use at manufacturing sites.
A Common Data Gap
- Procurement knows how much material was purchased.
- Manufacturing knows how much was consumed.
- Regulatory knows finished-product composition.
- EHS knows what is present at the facility.
- Trade compliance knows what crossed the Canadian border.
- None of them may have the complete answer.
That is why section 71 reporting is a useful test of enterprise chemical-data architecture.
What Should Companies Do Now?
Start with a controlled screening exercise.
Create columns for:
CAS number → substance name → Phase → site → supplier → imported/manufactured/used → 2025 quantity → concentration → application → reporting threshold → evidence source → reportable?
Then identify gaps. For foreign-sourced materials, contact suppliers early.
Canada’s guidance explicitly advises companies to inform suppliers and customers as soon as possible because they may hold data needed to complete the response.
Waiting until February 2027 to ask a foreign supplier for confidential formulation data is avoidable risk.
What If the Supplier Will Not Disclose Composition?
Canada allows confidential information to be submitted directly to the government through a blind submission mechanism in appropriate cases.
That is useful where:
- a foreign supplier considers formulation proprietary;
- the Canadian importer needs the data for compliance;
- the supplier does not want to reveal the information commercially.
Your process should therefore distinguish:
information unavailable from information available but confidential.
Those are not the same problem.
Practical Example
A Canadian medical-device company imports a polymer component. The supplier’s technical sheet lists only the polymer family, not a specific additive concentration. One of the 2026 substances may be present in that additive package. The importer cannot answer the notice solely from its ERP system.
It needs: import quantity → component composition → substance concentration → applicable threshold.
If the supplier refuses direct disclosure, a confidential government submission may be needed. This is why the real work should begin months before the filing deadline.
Frequently Asked Questions
Are the Canada 2026 CMP notices voluntary?
No. Companies meeting the reporting criteria have a legal obligation to submit the required information under section 71 of CEPA.
How many substances are covered?
Phase 1 contains 184 substances and Phase 2 contains 16, for a total of 200.
Must companies perform new testing?
The guidance says companies are not required to conduct tests solely to comply with the notices.
What if composition information belongs to a supplier?
Companies are expected to make reasonable efforts to obtain relevant supply-chain information. Canada also provides mechanisms for confidential or blind submissions where appropriate.
