New federal chemical reporting requirements announced
Environment and Climate Change Canada has published two mandatory reporting notices under the Canadian Environmental Protection Act, 1999, covering roughly 200 substances under the Chemicals Management Plan: the Phase 1 notice and the Phase 2 notice, published in the Canada Gazette on August 29, 2026. The government is gathering information on chemicals that were manufactured, imported or used in Canada during the 2025 calendar year to inform future assessments and, where warranted, potential regulation down the road. At this stage, the notices require reporting only. Nothing is being restricted or banned.
The substance lists are notably relevant to the automotive aftermarket. They include ingredients found in coolant and antifreeze, brake fluid, refinish and collision products, car care and cleaning products, lubricants and additives, and tires, with zinc oxide in tires named specifically.
Reporting is mandatory for companies that meet the criteria, and non-compliance is an offence under the Act. Whether your business needs to report depends on what it did in 2025 rather than what kind of business it is.
Broadly, a company is likely required to report if it manufactured a listed substance in Canada, imported one (alone, in a mixture, or in certain products), or used one to manufacture another product, above the applicable quantity thresholds.
Buying from Canadian suppliers or distributors generally does not trigger an obligation. The obligation typically sits with the company that manufactured or imported the substance, and companies that import directly, including through private-label or direct-purchase programs, may have obligations even where another party handles customs.
These thresholds and definitions are technical, so each business should review its own 2025 activities against sections 2 and 4 of the notices, with the help of the guidance manual. AIA Canada is not in a position to determine whether any individual member is required to report.
The Phase 1 reporting deadline is March 3, 2027, and the Phase 2 reporting period runs from March 4, 2027, to September 8, 2027. Responses are submitted by completing the Excel reporting file through ECCC’s Single Window.
ECCC is hosting information sessions in October 2026, December 2026 and March 2027, offered in English and French, and members can register here. Companies that need composition information from foreign suppliers are encouraged to start those conversations early. ECCC provides a template letter for that purpose on its Request for information from foreign suppliers page.
Questions can be directed to ECCC’s Substances Management Information Line at 1-800-567-1999 or substances@ec.gc.ca.
Please contact AIA Canada’s Vice President Emily Holtby at Emily.holtby@aiacanada.com with any additional questions.