On August 29, 2026, the Government of Canada published two new notices under Section 71 of the Canadian Environmental Protection Act, 1999 (CEPA), requiring information on certain chemical substances as part of the Chemicals Management Plan (CMP). These notices establish reporting requirements for certain chemical substances and introduce two reporting phases: CMP 2026 Phase 1, with submissions due by March 3, 2027, and CMP 2026 Phase 2, with submissions due by September 8, 2027. These notices apply to substances manufactured, imported, or used during the 2025 calendar year.
The information collected through these notices will support Environment and Climate Change Canada (ECCC) and Health Canada in assessing potential risks posed by the listed substances and determining whether additional risk management measures may be required under CEPA. As part of the Chemicals Management Plan (CMP), organizations meeting the reporting criteria will be required to provide information regarding the manufacture, import, use, sale, export and release of reportable substances to support future assessment and regulatory decision-making.
The CMP 2026 initiative has been divided into two separate reporting phases. Phase 1 applies to 184 substances, while Phase 2 applies to 16 substances. Companies should review both the substance lists carefully, as reporting obligations may exist under one or both notices depending on their activities during the 2025 reporting year. Separate submissions are required where both notices apply.
The reporting obligations extend beyond the chemical manufacturers. Depending on the substance and applicable threshold, requirements may apply to importers, formulators, distributors, product manufacturers, and organizations using reportable substances in individual processes. In some cases, reporting may be triggered when a substance is present in a mixture, product or manufactured item above specified reporting thresholds.
The reporting criteria are based on threshold levels specified within the notices. Below is a summary of the primary reporting thresholds.
| Reportable Activity | Part 1 & Part 4 Substances | Part 2 Substances | Concentration Threshold |
| Manufacture | > 100 kg | > 1,000 kg | N/A |
| Import | > 100 kg | > 1,000 kg | ≥ 0.1% w/w in mixtures, products, or certain manufactured items |
| Use in the manufacture of a mixture, product, or manufactured item | > 100 kg | > 1,000 kg | ≥ 0.1% w/w |
| Export | Not Required | Report quantity exported | N/A |
| Other uses (Part 4 substances only) | > 100 kg | N/A | ≥ 0.1% w/W |
If a facility meets the reporting criteria specified in either CMP 2026 Phase 1 or Phase 2 notice, it must submit a Mandatory Section 71 response through Environment and Climate Change Canada (ECCC) Single Window reporting system.
Facilities that do not meet the mandatory reporting thresholds may still choose to provide information through a Declaration of Stakeholder Interest (DSI). A DSI may be appropriate when an organization has experience with a reportable substance but falls below reporting thresholds, has information that may support government decision-making, or has commercial interest in a substance covered by the notices. The Government of Canada encourages stakeholders to share relevant information, even when mandatory reporting requirements do not apply.
Organizations that have no involvement with the reportable substances and no commercial interest in them may submit a Declaration of Non-Engagement (DNE). While there is no legal obligation to submit a DNE, doing so helps inform regulators that the organization has reviewed the notices and determined that no reporting obligations apply.
To prepare for the upcoming reporting deadlines, companies should review product inventories, SDSs, purchasing records, supplier communications, and manufacturing records to determine whether reportable substances are present within their operations. Early planning can significantly reduce the administrative burden of compliance and help ensure complete and accurate submissions.
Trinity is hosting a complimentary webinar on November 18, 2026, on this topic. If you are responsible for EHS, product stewardship, regulatory compliance, chemical management, or sustainability reporting, this session will help you understand your obligations and prepare for the upcoming reporting deadlines.
If you would like to assess whether the new Chemicals Management Plan reporting requirements apply to your facility, or need assistance preparing a Section 71 submission, please email Varshini Padmanabhan in Trinity’s Toronto office or call 437 291-5894 (7204).
