Canada Seeks Input on Risk Management of Chlorinated Alkanes under CEPA

On February 13, 2025, the Government of Canada launched a consultation on risk management measures for short-chain chlorinated alkanes (SCCAs), medium-chain chlorinated alkanes (MCCAs), and long-chain chlorinated alkanes (LCCAs) with up to 20 carbon atoms. A screening assessment found  that these substances meet the toxicity criteria under the Canadian Environmental Protection Act, 1999 (CEPA). The objectives of this consultation are to:

1. Inform stakeholders and obtain comments on the proposed prohibition of MCCAs and LCCAs up to 20 carbon atoms under the Prohibition of Certain Toxic Substances Regulations, 2012.

2. Gather information on concentration thresholds for SCCAs and MCCAs.

3. Propose the addition of SCCAs, MCCAs, and LCCAs to the Export Control List (ECL) in Schedule 3 of CEPA.

Background

Chlorinated alkanes, also known as chlorinated paraffins, are hydrocarbons with carbon chain lengths ranging from 10 to 38 atoms. SCCAs (10-13 carbon atoms) have been prohibited in Canada since 2013, while MCCAs (14-17 carbon atoms) and LCCAs (18-20 carbon atoms) continue to be used in industrial applications such as metalworking fluids, plastics, rubber, paints, coatings, adhesives, and sealants.

Assessments by Environment and Climate Change Canada (ECCC) and Health Canada concluded that chlorinated alkanes up to 20 carbon atoms are harmful to the environment and human health, resulting in their inclusion in Schedule 1 of the CEPA in 2011.

International Risk Management

Chlorinated alkanes are under global regulatory scrutiny due to their persistence and potential harm to human health and the environment. Various international agreements and national regulations have restricted or prohibited their use and trade.

• Stockholm Convention: SCCAs were listed for elimination in 2017; MCCAs are recommended for inclusion in 2025.

• Rotterdam Convention: SCCAs were listed in 2017, requiring prior informed consent for international trade.

• United States: MCCAs and LCCAs are subject to Significant New Use Rules (SNURs) under the Toxic Substances Control Act (TSCA).

• European Union: MCCAs are classified as Substances of Very High Concern (SVHCs) under REACH and are subject to strict regulatory controls.

Proposed Risk Management Measures

To protect human health and the environment, Canada proposes to ban certain chlorinated alkanes, set concentration limits, and restrict exports.

1. Prohibition of MCCAs and LCCAs

The Government of Canada proposes to amend the Prohibition of Certain Toxic Substances Regulations, 2012 to prohibit the manufacture, use, sale, and import of MCCAs and LCCAs with up to 20 carbon atoms. Temporary exemptions may be considered for:

• Metalworking fluids

• Plastics and rubbers

• Adhesives and sealants

• Automotive parts

2. Establishment of Concentration Thresholds

Proposed incidental presence thresholds for regulatory alignment:

• SCCAs: 1% by weight for substances, 0.15% for manufactured items

• MCCAs: 0.1% by weight for all products

• LCCAs: Further data required

3. Addition to the Export Control List (ECL)

In order to comply with international obligations, SCCAs, MCCAs, and LCCAs with up to 20 carbon atoms may be added to Part 2 and Part 3 of the ECL under CEPA, thereby restricting exports.

Information Gathering

Stakeholders are invited to submit information on:

• Product use and industry applications.

• Available alternatives and transition timelines.

• Socio-economic impacts of prohibition.

• Data on incidental presence thresholds.

Next Steps

The Government of Canada is inviting industry stakeholders, manufacturers, and environmental groups to provide feedback by April 14, 2025. Stakeholder feedback will help refine the regulatory amendments and inform Canada’s position at the Stockholm Convention in April/May 2025.