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On March 26, 2025, Canada amended the Domestic Substances List to apply Significant New Activity (SNAc) provisions to trixylyl phosphate (CAS RN 25155-23-1). This requires prior notification before undertaking any new use that could significantly increase human or environmental exposure to the substance.

Precautionary Action Under CEPA

Based on the suspicion that information about new activities involving trixylyl phosphate could help determine its potential toxicity under Section 64 of the Canadian Environmental Protection Act (CEPA), the Environment Minister, Steven Guilbeault, and the Health Minister jointly made the decision.

The order, issued under subsection 87(3) of CEPA, serves as a preventive measure to guarantee that any future applications of the substance are thoroughly evaluated to limit risks to the environment and public health.

Further details can be found in the Canada Gazette, Part II, Volume 159, Number 7 (here), which includes the precise substance impacted and outlines the necessary regulatory requirements.

SNAc provisions to trixylyl phosphate

Order 2024-87-24-01 amends the Domestic Substances List to apply CEPA's SNAc provisions to trixylyl phosphate, also known as phenol, dimethyl-, phosphate (3:1). This action seeks to manage potential risks associated with increased exposure in Canada and the environment due to significant new activities.

Although current use levels do not pose an immediate risk, the substance is used in flame retardants, hydraulic fluids, lubricants, plastics, and possibly food packaging. It has been identified as having potential reproductive toxicity and environmental persistence.

Notification Requirements for New Activities

Under the new requirements, any individual or company proposing a significant new activity involving trixylyl phosphate, particularly in cosmetics or consumer products, must submit a Significant New Activity Notification (SNAN) containing detailed information on the proposed use, exposure levels, and safety measures, at least 90 days prior to the activity.

The regulatory amendment follows assessments under Canada’s Chemicals Management Plan (CMP) and aims to proactively protect public health and the environment from future risks associated with the increased or altered use of this substance.

Transport Canada has announced the publication of a new edition of its key packaging standard for dangerous goods.  Developed by the Canadian General Standards Board (CGSB), CAN/CGSB-43.150-2025, titled “Design, Manufacture and Use of UN Standardized Drums, Jerricans, Boxes, Bags, Combination Packaging, Composite Packaging and Other Packagings for the Transport of Dangerous Goods, Classes 3, 4, 5, 6.1, 8, and 9” was officially released in April 2025.

The updated standard ensures that Canada’s requirements for the design, manufacture, and use of containers for dangerous goods remain aligned with international best practices.

Coming Into Force

The CAN/CGSB-43.150-2025 standard will be incorporated by reference into the Transportation of Dangerous Goods Regulations (TDGR).
Until the TDGR is amended, stakeholders must continue to comply with the following standards:

• TP14850-2010: Small Containers for Transport of Dangerous Goods, Classes 3, 4, 5, 6.1, 8, and 9 (Transport Canada Standard)

• CAN/CGSB-43.126-2019 (reaffirmed in 2024): Reconditioning, Remanufacturing and Repair of Drums for the Transportation of Dangerous Goods

Regulatory updates adopting the 2025 standard into the TDGR are anticipated in the near future.

Key Updates in the 2025 Edition

The 2025 edition introduces important changes to improve safety, harmonization, and regulatory clarity:

• Alignment with International Recommendations: Updates incorporate changes from the 23rd edition of the UN Recommendations on the Transport of Dangerous Goods, enhancing international compatibility.

• Integration of Reconditioning and Repair Requirements: The provisions from CAN/CGSB-43.126 are now being incorporated directly into CAN/CGSB-43.150, streamlining requirements for the reconditioning, remanufacturing, and repair of drums.

These updates ensure that Canadian manufacturers, reconditioners, and users of UN-standardized containers meet the most recent international safety and performance standards.

How to Access the New Standard

The CAN/CGSB-43.150-2025 standard is available free of charge here.