Environment and Climate Change Canada (ECCC) has proposed an amendment to the Domestic Substances List (DSL) under the Canadian Environmental Protection Act, aiming to add a letter "P" to the identifiers of 264 polymers to indicate compliance with Reduced Regulatory Requirements (RRR). The proposal is subject to a 120-day public consultation period, after which it will be finalized and published in Part II of the Canada Gazette to take effect.
Overview of the Canadian Domestic Substances List
DSL catalogs substances commercially made or imported in Canada. Substances not on the DSL are considered new and require evaluation for potential hazards before being produced or imported, depending on their volume. Notably, polymer notifications in Canada are categorized into three distinct scenarios.
- Low Concern Polymers (RRR Polymers): Notify 30 days in advance under Schedule 9 upon reaching an annual volume of 1 ton.
- Polymers not listed on the Domestic Substances List (NDSL), or polymers with DSL or NDSL monomers: Notify 30 days in advance under Schedule 9 for volumes of 1 ton/year, 60 days in advance under Schedule 10 for 10 tons/year, and 60 days in advance under Schedule 10+ for 50 tons/year.
- Other Polymers: Notify 30 days in advance under Schedule 9 for 1 ton/year, 60 days in advance under Schedule 10 for 10 tons/year, and 60 days under Schedule 11 for 50 tons/year.
Understanding RRR and its Policy on Polymers
The Reduced Regulatory Requirement (RRR) is a Canadian initiative that enhances regulatory efficiency by streamlining unnecessary administrative processes. RRR polymers, identified for their low-risk characteristics, undergo simplified regulatory oversight during production, use, and disposal.
Significance of the Letter “P”
The letter “P” added to a material identifier signifies that the substance meets the RRR polymer standards for inclusion in the DSL, thus qualifying for reduced information requirements under the New Substances Notification Regulation (Chemicals and Polymers), hereafter referred to as the Regulation. Non-RRR polymers without the "P" designation are subject to more rigorous requirements, necessitating detailed submissions from those planning to manufacture or import them into Canada above specified thresholds.
ChemRadar Insights
ECCC has confirmed the listing of certain RRR polymers on the DSL before 2003. Substances on the DSL are not usually subject to notification under current regulations. However, identifiers marked with “S”, “S prime”, or “P” require additional reporting. "S" indicates Significant New Activity (SNAc), which calls for notification to the ECCC for new uses, processes, or exposures. "S prime" (S') requires notification under specific conditions or variations, despite being listed on the DSL.
Additionally, substances on the DSL must be reported to ECCC in these instances, but not limited to:
- New or changed uses: Notification is required for substances used for non-registered purposes.
- Quantity overruns: Exceeding DSL limits in production or importation must be reported.
- New risks: Emerging risks identified by new data require reassessment and notification.
- Export requirements: Some exports necessitate prior notification to ECCC.
