New Compliance Requirements for the Canadian Domestic Substance List (DSL)

by | Apr 2, 2026 | Cosmetics, Health Canada Updates, Our View

On March 25, 2026, the Government of Canada published Order 2026-87-20-01 in the Canada Gazette, Part II. This order introduces significant amendments to the Domestic Substance List (DSL) under the Canadian Environmental Protection Act (CEPA). The changes impact a total of 223 substances and may require immediate action to ensure your products remain compliant. There are direct implications for manufacturers, importers and distributors selling products in Canada.

What is Changing?

The update focuses on Significant New Activity (SNAc) provisions. These are risk management tools used when a substance, already on the DSL, is used in a new quantity, concentration, or circumstance that could change its impact on human health or the environment.

  • SNAc requirements have been applied to 54 existing substances and modified for 161 others.
  • Part 2 of the DSL (Chemicals and Polymers) is now split into Division 1 (individual substances) and Division 2 (group of substances).
  • A new Schedule 1 has been added to standardize information required for SNAc Notifications (SNAN).

Why This Matters to Your Business?

The most critical takeaway is the potential for instant non-compliance. Many of these changes specifically target consumer products and cosmetics, and the triggers for reporting are much lower than previous standards.

  • Low concentration triggers: Some substances now have concentration triggers as low as 0.1% or 1%.
  • Low volume triggers: Compliance requirements may now kick in at just 10 kg per year. This is significantly lower than standard New Substances Notification (NSN) triggers.
  • Pre-emptive reporting: Companies are required to submit a Significant New Activity Notice (SNAN) at least 90 days before the day on which the significant new activity begins. If your current operations exceed these new thresholds, you may need to act immediately.

Recommended Next Steps:

  • Review your current raw materials and finished product formulations against the updated DSL list.
  • Check if any of your ingredients fall under the 223 impacted substances.
  • Determine if your annual use exceeds the new concentration or volume thresholds. 
  • File a SNAN for any significant new activity.

If you need assistance reviewing your formulations or determining your compliance status under these new requirements, please contact us. We are here to help you navigate these changes and ensure your products remain compliant.