The R-ICL is an administrative list of substances found in products regulated under the Food and Drugs Act that were in Canadian commerce between January 1, 1987, and September 13, 2001. Under CEPA, substances on the R-ICL may be added to the DSL once specific eligibility criteria have been met.

With their addition to the DSL, these 656 substances have been removed from the R-ICL and are no longer subject to the New Substances Notification Regulations. This change may reduce regulatory requirements for companies using these substances in products regulated in Canada. For more such updates, contact us.

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​While the published regulations formally introduced two new substance categories, i.e., Dechlorane Plus (DP) and decabromodiphenyl ethane (DBDPE), an update to ECCC’s Substances Search Tool reveals an increase in the listed substances, jumping from 209 CAS RNs under the 2012 Regulations to 3,218 CAS RN entries with the 2025 Regulations.

The addition of over 3,000 CAS RNs does not reflect new regulatory amendments, but rather individual chemicals that fall under broad structural definitions already regulated, particularly per- and polyfluoroalkyl substances (PFAS) such as PFOA, PFOS, and LC-PFCA precursors.

​The List is Non-Exhaustive: ECCC emphasizes that its database is a compliance guide, not an all-inclusive list. If a substance meets the structural definition outlined in the regulations, it is prohibited or restricted regardless of whether its CAS RN is explicitly cataloged.

​A screening by industry regulatory teams identified 13 cosmetic-relevant CAS RNs linked to International Nomenclature of Cosmetic Ingredients (INCI) names: including ingredients like Perfluorononyl Dimethicone, Perfluorooctylethyl Triethoxysilane, and certain fluorinated phosphates.

​Recommended Next Steps for Manufacturers and Brand Owners:

• Review all cosmetic ingredients and formulations against relevant substance groups and definitions.
• Request comprehensive ingredient disclosures and Certificates of Analysis (CoA) from the suppliers.
• Review relevant packaging, components and other materials associated with cosmetic products, as these may also be implicated.

Ensuring proactive compliance with evolving Canadian environmental standards is essential to preventing supply chain interruptions, product recalls, or import holds.

​If you have any questions regarding how this update may affect your business, do reach out to us today.

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Key Changes in the 2025 Regulations:

The 2025 regulatory framework completely repeals and replaces the older 2012 regulations. Key updates include:

• Stricter restrictions have been placed on the manufacture, use, sale, and import of PFOS, PFOA, LC-PFCAs, HBCD, and PBDEs.
• New controls have been introduced for Dechlorane Plus (DP) and decabromodiphenyl ethane (DBDPE).
• To support businesses in transitioning to alternative ingredients, there are temporary exemptions and permit options available.
• New laboratory reporting requirements apply to DP and DBDPE, which must be submitted using Environment and Climate Change Canada’s (ECCC) Regulatory Services Platform.

Updates to the Export Control List:

Changes to the Export Control List were launched at the same time.

• Export controls have been added for PFOA, LC-PFCAs, HBCD, PBDEs, and ferbam.
• These updates help Canada fulfill its international commitments under the Rotterdam Convention regarding the trade of hazardous chemicals and pesticides.
• While Dechlorane Plus (DP) has also been added to the Export Control List, this specific listing will not be enforced until December 31, 2030.

Next Steps for Businesses:

If your company manufactures, imports, or exports any of these affected substances, you should carefully review the new requirements to determine if you have any permit or reporting obligations. Please feel free to reach out to us if you have any questions regarding this update.

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Key Assessment Findings:

• The review covered 13 substances containing titanium, which include titanium dioxide, titanium tetrachloride, and various titanium alkoxides.
• These ingredients are broadly used across many industrial and consumer applications.
• The government officially concluded that none of the 13 evaluated substances meet the strict criteria to be classified as toxic under section 64 of CEPA.
• Based on current exposure levels, these substances do not enter the environment in amounts that would pose a risk to human health or the environment.
• Because no significant risks were found, the government has not proposed any new risk management measures for these materials.

Important Note on Nanomaterials:

• This specific assessment does not apply to nanoscale titanium dioxide (TiO2 nano).
• Nanoscale materials, including TiO2 nano, are scheduled to be assessed separately under the Government of Canada’s Plan of Priorities.

If you have any concerns or questions regarding this recent publication or the upcoming assessment of TiO2 nano, please contact us today.

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What Are the New Restrictions?

To manage identified concerns, the government is placing limits on how this substance can be manufactured, imported, and used. The condition mandates that Castoryl Maleate must be kept at a concentration of less than 2.5% by weight in several everyday personal care items. This concentration limit applies to the following products:

• Liquid body washes and shower gels
• Shampoos and hair conditioners
• Liquid hand soaps
• Toothpaste

Who Does This Affect?

Currently, these restrictions do not apply broadly to the entire cosmetics industry or to existing users of similar ingredients. The rules strictly apply only to the original notifier of the substance, as well as anyone to whom the substance is transferred who then becomes subject to the same conditions. It serves as an important heads-up: if your business is planning to submit notifications for this ingredient in the future, you should anticipate facing these same restrictions. If you have questions about how these rules might apply to your business, contact us today.

The post Ministerial Condition Ordered for Castor Oil, Monomaleate (INCI Name: Castoryl Maleate) appeared first on Focal Point.

However, four specific ingredients that are relevant to the cosmetics industry have been flagged for potential health concerns: Diethanolamine (DEA), lauramide DEA, cocamide DEA, and triethanolamine (TEA). The government is proposing to add these four substances to the CEPA Watch List and apply SNAc rules to them. This means that the government must be notified and must conduct an assessment before any significant new uses of these substances are introduced.

Proposed Notification Triggers:

If a business uses these substances, they will need to notify the government if their usage exceeds a 10-kg annual volume threshold combined with specific concentration limits based on the product type. The proposed concentration triggers are:

• Diethanolamine (DEA): Notification is required if used at a concentration greater than 3% in all-purpose cleaning liquids or cleaning sprays. Because DEA is already prohibited on the Cosmetic Ingredient Hotlist, there is no notification trigger for cosmetic applications.
• Lauramide DEA: Notification is required if used at a concentration greater than 2.5% in leave-on cosmetic products.
• Cocamide DEA: Notification is required if concentrations exceed 12.5% in cleaning sprays/liquids, 21% in shampoos or liquid body soaps, or 0.5% in leave-on cosmetics.
• Triethanolamine (TEA): Notification is required if concentrations exceed 4% in air fresheners, 5% in non-fluoridated toothpaste, or 1% in non-fluoridated mouthwash.

Next Steps and Call for Feedback:

A 60-day public comment period is currently open regarding these proposed SNAcs, which will officially close on August 27, 2026.

If you have any questions regarding the publication and how this may impact your business, please feel free to reach out to us.

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