Canada Expands Substances Under Toxic Substances Regulations (2025)

Delsie Braganza

Delsie joined the Focal Point Research team in 2011 and has been an invaluable asset for our clients. With her strong regulatory and quality assurance background, she is able to help clients understand the Canadian and US requirements, set targets to achieve compliance, and attain their goals to get products to market.

Delsie is able to audit facilities, set up and maintain GMP compliant facilities, develop strong quality management systems, and co-ordinate successful Health Canada inspections. In addition to this, Delsie oversees all regulatory compliance reviews and submissions made to Health Canada and the US FDA.

Delsie obtained an Honours Bachelor of Science (Hons. B. Sc.) in Pharmaceutical Chemistry from the University of Toronto, Post-Graduate Certificate in Pharmaceutical Regulatory Affairs and Quality Operations (RAQ) from Seneca College and Regulatory Affairs Certification (RAC) from the Regulatory Affairs Professional Society (RAPS).

When she’s not learning something new, Delsie loves spending time with family, going on road trips or long walks, and swimming.

Jennifer Porter, BA Psychology, MBA – President & CEO

Having started at Focal Point Research in 2011, Jenn has been fully engaged in the company and since day one, has leveraged her MBA and interest in the regulated products industries to grow her passion for the business and services offered.

Jenn has excelled at building on initial conversations with a variety of companies from all industries seeking regulatory and quality assurance services. She has developed strong relationships with each client, offering each one a unique opportunity to have the Focal Point Research team help them develop successful strategies and bring products to market, while ensuring their compliance needs are being fulfilled.

Jenn has not only been a leader internally, but a key contact for all clients and in 2021, Jenn was the obvious choice to lead Focal Point Research into the future as the successor to company founder, Rob Fichtner.

Jennifer balances her career by honouring her wanderlust, spending her leisure time golfing, and enjoying the outdoors with her loving dog.

Environment and Climate Change Canada (ECCC) has significantly expanded the list of Chemical Abstracts Service Registry Numbers (CAS RNs) associated with the Prohibition of Certain Toxic Substances Regulations, 2025.

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.

Delsie Braganza

Jennifer Porter, BA Psychology, MBA – President & CEO

Canada Expands Substances Under Toxic Substances Regulations (2025)

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