The Chemicals Management Plan (CMP) is a Government of Canada initiative aimed at reducing the risks posed by chemical substances to Canadians and the environment. Through the CMP, the Government of Canada assesses and manages risks to human health and the environment posed by chemical substances that can be found in food and food products, consumer products, cosmetics, drugs, drinking water and industrial releases.
The notice [
Canada Gazette, Part 1, Volume 157, Number 25: GOVERNMENT NOTICE] applies to the 2022 calendar year. If a facility meets the reporting criteria for the reporting year, they must respond to the notice with a section 71 submission. If the facility does not meet the reporting criteria for the reporting year, they are not required to respond to the notice.
However, if the facility has information that the government may find useful the facility is encouraged to provide this information through a Declaration of Stakeholder Interest (DSI).
The reporting criteria is based on threshold levels listed in the regulation Annex 1. Below is a summary table of reporting thresholds.
| Part of the Substance List (Part) | Thresholds |
| Manufacture | Import | Use | Use for other activities |
| 1 | > 100kg | > 100kg | > 100kg | N/A |
| 2 | > 1,000kg | > 1,000kg | > 1,000kg | N/A |
| 3 | N/A | > 100kg | > 100kg | N/A |
| 4 | > 100kg | > 100kg | > 100kg | > 100kg |
Below are examples of some of the common substances that may be at use at industrial facilities.
- Part 1 substances: Naphthalene (CAS # 91-20-3), Dodecanoic acid (CAS # 143-07-7)
- Part 2 substances: 1,4-Dinitrobenzene (CAS # 100-25-4), Decanal (CAS # 112-31-2)
- Part 3 substances: Methanol (CAS # 67-56-1), Tetrahydrofuran (CAS # 109-99-9), Cumene (CAS # 98-82-8)
- Part 4 substances: Dichloromethane (CAS # 75-09-2), Sodium fluoride (CAS # 7681-49-4)
Once a facility determines applicability, there are three ways of responding to the notice:
Excel Declaration File
If the notification criteria are met for one or more reportable substances, the facility must respond to the notice by entering the required data into the Excel Declaration File (EDF) and submitting it by January 17, 2024, the reporting deadline. Facilities are allowed to request for an extension of time to report to Section 71, however extensions must be requested in writing and the following must be included:
- The name of the organization;
- Contact information;
- The CAS RN of the substances in question; and
- A rationale for the request.
Declaration of Stakeholder Interest
If the facility has an activity with one or more reportable substances, the facility can opt to submit this information through a Declaration of Stakeholder Interest (DSI). A DSI can be submitted in the following situations:
- The facility did not have an activity with a reportable substance during the reporting year but had an activity in another calendar year.
- Goods were imported or used that contained a reportable substance but did not meet the reporting thresholds.
- The facility imported manufactured items containing reportable substances that did not meet the reporting thresholds.
- The facility has unpublished studies on substances that do not meet reporting requirements.
- The facility has an activity with a reportable substance, but benefit from an exemption as listed in Section 4 of the Notice – Exclusions.
Declaration of Non-Engagement
If the facility is not involved with any reportable substances and has no commercial interest in these substances, the facility may send a Declaration of Non-Engagement (DNE) email for the notice to [email protected].
Please note that there is no legal obligation to submit a DSI or DNE, whichever applies; however, the facilities are encouraged to do so.
If you would like to report under the CEPA’s Chemical Management Plan and how they may impact your facility, please contact Trinity’s
Toronto Office or call
416.391.2527.
For more information or for assistance, please contact Trinity Consultants at
800.229.6655.
