What You Need To Know About The Federal Government’s New Chemical Reporting Obligations

On August 29, 2026, the federal government published Phase 1 and Phase 2 of the Notices with respect to certain substances under the Chemicals Management Plan – 2026 (the “Notices”) pursuant to section 71(1)(b) of the Canadian Environmental Protection Act, 1999 (“CEPA”). The Notices impose mandatory reporting requirements on businesses that used, manufactured or imported a listed chemical in amounts greater than the prescribed threshold quantities during the 2025 calendar year. Obtaining this information is a priority under the federal government’s Chemicals Management Plan (the “CMP”) and collected information will inform future Environment and Climate Change Canada (“ECCC”) and Health Canada prioritization and risk assessment decisions.

The reporting period for Phase 1 began on August 29, 2026 and ends on March 3, 2027. The reporting period for Phase 2 will begin immediately afterwards on March 4, 2027 and will run until September 8, 2027. This bulletin summarizes the reporting requirements set out in the Notices and their potential implications for businesses.

Canada’s Chemical Management Plan

The CMP is a federal initiative that seeks to reduce risks posed by chemical substances to human health and the environment.¹ The CMP is used to assess and manage risks presented by chemical substances in food and food products, consumer products, cosmetics, drugs, drinking water and industrial releases.² Mandatory and voluntary information collection initiatives are a major component of the CMP and are used to collect both scientific data and commercial activity information. The information collected is used by ECCC and Health Canada to inform future regulatory initiatives and mandates.

The Notices: Listed Chemicals & Reporting Requirements

The Notices list 200 chemicals that trigger reporting obligations: 184 chemicals are listed in Phase 1 and 16 chemicals are listed in Phase 2. Unlike other reports required under CEPA, reporting requirements under the Notices cover a broad range of chemicals, rather than a single class. Reporting obligations depend on whether and in what quantity businesses manufacture, use or import each designated chemical in their operations. Businesses that are obligated to submit a report to the Minister of the Environment, Climate Change, and Nature (the “Minister”) must provide the following information:

• The business name, address, and business number, along with an authorized individual’s contact information and a declaration that the information is accurate and complete.³
• The total quantity (in kilograms) of listed chemicals manufactured, imported, used in manufacturing (of a mixture, product or manufactured item), exported, or used in other activities, along with a description of those activities.⁴
• Information on any facility (other than distribution and warehousing facilities) where more than 100 kg of a listed substance was released or may have been released into the environment in 2025.⁵
• Information on sales of listed chemicals or products containing listed chemicals, including a description of the product, its common or generic name(s), and its intended uses, including whether it is intended for use by children 14 years of age or younger.⁶
• Any unpublished data or studies relating to listed chemicals that have not already been provided to the federal government under the New Substances Notification Regulations (Chemicals and Polymers) or under section 70 of CEPA.⁷

The federal government has published a Guidance document for responding to: Notices with respect to certain substances under the Chemicals Management Plan – 2026 to assist with reporting.

Reporting Extensions

While reporting deadlines are established in the Notices, the Minister may grant requests for additional time. Requests must be submitted to substances@ec.gc.ca before the relevant deadline (submitting requests at least 15 business days before the deadline is recommended) with the following information:

• The requesting organization’s name;
• Contact information;
• The Chemical Abstract Service Registry Numbers of any substances involved;
• The reason for the request; and
• The duration of the requested extension.

Key Takeaways

The Notices introduce new regulatory obligations that could impact a broad range of industries. Businesses should assess whether they are required to report and note the upcoming March 3, 2027 deadline for Phase 1.

Businesses that have previously reported under the section 71 notices for PFAS or plastics will find the reporting process substantially similar. The cumulative administrative burden of successive section 71 information gathering initiatives under the CMP remains a concern for industry stakeholders and is at odds with the federal government’s efforts to reduce red tape under the Treasury Board’s Cabinet Directive on Regulation. Industry associations have noted that Canada’s approach also risks divergence from the chemical management frameworks of key trading partners, including the United States under the Toxic Substances Control Act and the European Union and United Kingdom under their respective REACH regimes, which may be inconsistent with the regulatory cooperation and risk-based principles reflected in CUSMA Annex 12-A.

Businesses may provide input on CMP program delivery through Health Canada’s voluntary survey, which closes September 30, 2026. ECCC will also hold information sessions in October 2026, December 2026, and March 2027 to assist with reporting under the Notices.

Footnotes

1. Government of Canada, “Chemicals Management Plan” (modified 21 March 2022).

2. Ibid.

3. Government of Canada, “Canada Gazette, Part I, Volume 160, Number 35: GOVERNMENT NOTICES” (August 29, 2026), s. 6.

4. Ibid, s. 7.

5. Ibid, s. 8.

6. Ibid, s. 9.

7. Ibid, s. 10.