Under the Canadian Environmental Protection Act, 1999, the Department of Environment Canada recently announced an update to the Domestic Substances List. The new regulations, which took effect on November 29, impose stricter restrictions on the use and import of the chemicals "benzenamine, 4,4'-methylenebis" and "formaldehyde, polymer with benzenamine."
| Group of substances | CAS RN | Chemical substance (acronym) |
Application of SNAc provisions |
| MDA | 101-77-9 | 4,4'-Methylenebis(benzenamine) (4,4’-MDA) | subject to subsection 81(3) of the Act |
| 25214-70-4 | Formaldehyde, polymer with benzenamine (pMDA) | subject to subsection 81(3) of the Act |
According to the new amendment, when these chemicals are used in the manufacture or import of consumer products and cosmetics containing a certain concentration, the following new regulations must be followed:
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Manufacturing and import restrictions for consumer products and cosmetics:
- When these chemicals are used in the manufacturing of any consumer products or cosmetics with a content reaching or exceeding 0.1% by weight, manufacturers and importers must comply with the new usage regulations.
- If the annual import volume exceeds 10 kilograms, importers need to declare products containing these substances.
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Restrictions on corporate usage:
- Companies using these chemicals in amounts reaching or exceeding 1,000,000 kilograms per year, or between 100,000 kilograms and 1,000,000 kilograms without implementing at least three control measures at the facility, need to make a special declaration and comply with stricter management measures.
- For companies with annual usage between 10,000 kilograms and 100,000 kilograms, a declaration is also required if at least two control measures are not implemented.
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Control measures:
- Facilities must implement mechanisms or processes that remove at least 90% of the chemical substances.
- These chemicals must be transported in dedicated containers to avoid the need for cleaning.
- Water used for cleaning or rinsing equipment and surfaces must be reused within the same facility or treated through incineration or engineered hazardous waste landfills.
Moreover, all businesses planning to undertake these defined significant new activities must submit a detailed description of the activities, anticipated usage amounts, and other relevant information to the Department of Environment at least 90 days before the activities commence. This information will be used to assess the potential impacts of the chemicals on the environment and human health.
This revision by Environment Canada emphasizes strict management of the potential risks of chemical substances to protect public health and environmental safety. The implementation of this policy will further enhance the monitoring and assessment of the use of chemical substances, ensuring the sustainable development of related industries.
