On May 2, 2026, the Government of Canada published a notice in the Canada Gazette, Part I (Volume 160, Number 18), applying Significant New Activity (SNAc) provisions to two ester substances under the Canadian Environmental Protection Act, 1999 (CEPA 1999). Companies are required to submit a Significant New Activity Notification (SNAN) before undertaking specific manufacturing or distribution activities involving these substances in consumer products and cosmetics. The provisions came into force immediately upon publication.
Substances Affected
- Alkanedioic acid, di-branched alkyl ester (Confidential Substance Identity Number 19814-2)
- Hexanedioic acid, 1,6-diisotridecyl ester (CAS No. 26401-35-4)
Key Requirements for Cosmetic Products
Manufacturing: A SNAN is required if a company uses either substance in the manufacture of a cosmetic product at a concentration equal to or greater than 0.1% by weight.
Distribution: A SNAN is also mandatory for the distribution for sale of such cosmetics containing the substance.
Exemptions
An activity is not considered a significant new activity if:
- The substance is used strictly as a research and development substance;
- The substance is used as a site-limited intermediate substance; or
- The substance or product containing it is intended only for export.
Notification Timeline and Required Information
Companies proposing a significant new activity must submit a comprehensive set of information to the Minister of the Environment at least 90 days before the day on which the activity begins. The submitted information will be assessed within 90 days of receipt. The required information includes, but is not limited to:
- Description of the significant new activity in relation to the substance;
- Anticipated quantity of the substance to be used in a calendar year;
- Chemical names, CAS registry numbers (if assigned), trade names, and synonyms;
- Safety Data Sheet (SDS) for the substance, if available;
- Exposure information: whether the substance will be used in children's products, and the anticipated degree of direct human exposure (concentration, duration, frequency, and circumstances);
- Product information: description of the product/end-use products, intended use, method of application, function of the substance, and its concentration;
- Information related to reproductive and developmental toxicity (conducted in accordance with OECD principles of Good Laboratory Practice);
- Information sufficient to assess dermal penetration at concentrations relevant to the intended end use (conducted under OECD GLP);
- All other available information or test data permitting the identification of adverse effects on the environment and human health, and the degree of exposure;
- Details of previous submissions to other government agencies regarding the substance and risk management actions imposed;
- Contact information of the proposer and certification of accuracy.
Transitional Provisions
Both notices include a transitional period running from May 2, 2026, to May 2, 2027. During this period, the SNAN requirement is triggered only if the substance is present at ≥ 0.1% by weight AND the quantity used exceeds the following thresholds:
- Alkanedioic acid, di-branched alkyl ester: Quantity greater than 100 kg
- Hexanedioic acid, 1,6-diisotridecyl ester: Quantity greater than 1,000 kg
CIRS Reminder
The SNAc provisions took effect on May 2, 2026, with a one-year transitional period during which the SNAN requirement applies only when both the concentration threshold (≥ 0.1%) and the quantity threshold are met. Companies are encouraged to assess their product portfolios early to determine whether these substances are present, and to plan ahead for the 90-day notification window to avoid potential disruptions to manufacturing or distribution activities in Canada.
If you need any assistance or have any questions, please get in touch with us via service@cirs-group.com.
Our Services
- Canada Cosmetics Formula and Label Compliance Review
- Canada Cosmetics CNF Registration
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Further Information：
Canada Gazette
