News Details

As part of its ongoing efforts to strengthen chemical risk oversight, the Canadian government has introduced new Significant New Activity (SNAc) notification requirements for several substances under the Chemicals Management Plan (CMP). These measures were formalized through orders published in the Canada Gazette, Part II on 25 February 2026, and target substances listed on the Domestic Substances List (DSL). This  includes cyclohexylamine, 2-ethylhexyl 2-ethylhexanoate, and related substances such as calcium 2-ethylhexanoate and sodium cyclamate.

New SNAc Requirements for Cyclohexylamine

Under the newly adopted order, cyclohexylamine (CAS 108-91-8) is now subject to SNAc notification requirements when used in certain consumer applications. Notification is required if the substance is used or imported in products such as gel fuel canisters, paints, coatings, stains, or other consumer products, particularly where exposure risks may arise. Additional notification obligations apply when the substance is used in cosmetic products at concentrations of 0.1% by weight or higher, with specific exclusions such as aerosol hairsprays.

Cyclohexylamine is commonly used as a corrosion inhibitor, boiler treatment agent, and processing aid, and it may also be present in food packaging materials and cosmetics. Health Canada has identified potential concerns relating to consumer exposure, particularly through products that may lead to inhalation or dermal contact. This has prompted the need for a pre-market assessment of new uses.

Expanded Controls for 2-Ethylhexyl 2-Ethylhexanoate and Calcium 2-Ethylhexanoate

A separate order introduces SNAc notification requirements for 2-ethylhexyl 2-ethylhexanoate (CAS 7425-14-1), a substance already restricted in cosmetics under the Cosmetic Ingredient Hotlist. The new provisions require notification when the substance is used in consumer products at concentrations of 0.1% by weight or greater, including imported products exceeding 10 kg annually.

The regulatory scope also reflects broader concerns identified under CMP assessments, which include related substances such as calcium 2-ethylhexanoate (CAS 136-51-6). These substances are used in applications such as coatings, lubricants, and industrial formulations, and may pose risks under certain exposure scenarios, particularly to the general population.

SNAc Provisions for Sodium Cyclamate and Cyclohexylamine Linkages

Health Canada has also assessed sodium cyclamate (CAS 139-05-9), which can degrade into cyclohexylamine. While sodium cyclamate is primarily used as a sweetener in food and pharmaceuticals, its indirect contribution to cyclohexylamine exposure has been identified as a potential concern. Consequently, the regulatory framework considers both substances when evaluating risk and determining appropriate control measures.

Objective: Strengthening Pre-Market Oversight of Chemical Risks

The introduction of SNAc requirements allows the Canadian government to evaluate new or expanded uses of substances before they enter the market. Companies intending to manufacture, import, or use these substances in new ways must submit detailed information to the relevant authorities. This enables a risk assessment to be carried out to determine whether additional controls are required.

However, the notification requirements do not apply in certain cases, such as when substances are used exclusively for research and development, as site-limited intermediates, or in products intended solely for export.

Regulatory Impact and Industry Implications

These measures reflect Canada’s proactive approach to chemical management, ensuring that substances already identified as potentially hazardous are closely monitored when used in new applications. For industry, this means increased compliance obligations, particularly with regard to tracking the concentrations, volumes, and end uses of affected substances.

Overall, the new SNAc orders support the protection of human health and the environment, while maintaining a science-based regulatory framework that promotes safe innovation and the responsible use of chemicals.