The Environment and Climate Change Canada (ECCC) recently released a Risk Management Consultation Document for Short-Chain, Medium-Chain, and Long-Chain Chlorinated Paraffins (Carbon Chains ≤20), proposing to expand controls over chlorinated paraffins and soliciting feedback from stakeholders. This initiative aims to mitigate environmental and health risks while accelerating industry transition to safer alternatives.
Background and Regulatory Objectives
Under the Canadian Environmental Protection Act (CEPA 1999), short-chain chlorinated paraffins (SCCPs), medium-chain chlorinated paraffins (MCCPs), and long-chain chlorinated paraffins (LCCPs, carbon chains ≤20) have been identified as substances requiring strict control due to their persistence, bioaccumulative potential, and toxicity. Canada banned SCCPs in 2012 under the Prohibition of Certain Toxic Substances Regulations. The new consultation proposes two key measures:
- Expanded Prohibition Scope: Ban the manufacture, import, use, and sale of MCCPs and LCCPs (carbon chains ≤20), including products containing these substances.
- Enhanced Export Controls: Add these substances to the Export Control List to restrict international trade.
Key Consultation Topics and Data Requests
ECCC invites industry submissions in the following areas:
1. SCCPs Residue Thresholds
Provide details on products with non-intentional SCCPs residues (concentration levels, applications, and justification) to establish scientifically sound "unintentional presence" thresholds.
2. MCCPs Substitution and Transition Timelines
- Submit usage data for MCCPs in metalworking fluids, PVC plastics, coatings, aerospace, etc., including quantities, product types (oil-/water-based), and process specifications.
- Provide feasibility analyses of alternatives, phase-out timelines, cost estimates, and technical challenges.
- Advocate international collaboration to phase out MCCPs globally.
3. LCCPs Regulatory Framework
Share application data for LCCPs in adhesives, rubber materials, and other sectors, mirroring MCCPs requirements, and propose residue threshold criteria.
Exemptions and Industry Support
ECCC emphasized that "limited exemptions" may be granted for specific uses where alternatives are unavailable, provided companies demonstrate objective challenges (e.g., national defense or critical industries). Exemptions would require evidence of transition necessity and lack of viable substitutes.
Participation and Next Steps
All submissions must be sent via email to interdiction-prohibition@ec.gc.ca by April 14, 2025. Feedback will inform final regulations expected in 2026.
