Canadian manufacturers, importers, and users with a commercial status now have new reporting requirements about their uses (including industrial processes such as facility releases) and downstream uses of 188 bisphenol A (BPA) and BPA structural analogues and functional alternatives (BPA SAFAs). The reporting requirements are pursuant to the information gathering provisions of paragraph 71(1) of the Canadian Environmental Protection Act, 1999. Compliance with the Act is mandatory, and penalties include fines worth thousands of dollars may apply if persons who fail to comply.
The Government of Canada recently published a Notice with respect to bisphenol A (BPA) and BPA structural analogues and functional alternatives (BPA SAFAs)on November 13th, 2021 in the Canada Gazette, Part I, Environment and Climate Change Canada (ECCC) published this notice to collect information from Canadian manufacturers, importers, and users with commercial status.
The Government of Canada recently published a Notice with respect to bisphenol A (BPA) and BPA structural analogues and functional alternatives (BPA SAFAs)on November 13, 2021 in the Canada Gazette, Part I, pursuant to the information gathering provisions of paragraph 71(1) of the Canadian Environmental Protection Act, 1999.
Environment and Climate Change Canada (ECCC) publishes this notice to collect information from Canadian manufacturers, importers and users on the commercial status, industrial processes (e.g., facility releases), and downstream use of 188 substances that are BPA or BPA SAFAs. Compliance with the Act is mandatory, and penalties include fines may apply if persons who fail to comply.
These reporting requirements apply to those who, during the 2019 calendar year, met any of the following criteria:
- manufactured more than 10 kg of a substance
- imported more than 10 kg total of a substance whether the substance was:
- alone
- at a concentration equal to or above 0.02% by weight (w/w%) in a mixture or in a product; or
- at a concentration equal to or above 0.02% by weight (w/w%) in a reportable manufactured item
- used more than 10 kg of a substance, whether the substance was used alone or at a concentration equal to or above 0.02% by weight (w/w%) in a good, to produce a good
A summary list of substances subject to this notice can be found in the following places:
1) Schedule 1 -Substances, are toxic or are capable of becoming toxic;
2) Schedule 2 Substance function codes;
3) Schedule 3 Application codes:
Part 1 Substances used for furnishings, cleaning, treatment or care,
Part 2 Substances used for construction, paint, electrical or metal,
Part 3 Substances contained in packaging, paper, plastic or hobby materials,
Part 4 Substances used for automotive, fuel, agriculture or outdoor use,
Part 5 Substances contained in items for food, health or tobacco,
Part 6 Substances contained in products, mixtures or manufactured items not described by other codes
The deadline to report is March 16th, 2022. Every person to whom the notice applies is required to comply by submitting an Excel Reporting File via Single Window.
You can respond to this notice by downloading and completing an Excel Reporting File and submitting it through Environment and Climate Change Canada’s Single Window.
Any person not subject to this notice, who has an interest in a substance or has information the Government may find useful on these substances, may identify themselves and submit this information through a Declaration of Stakeholder Interest (SHI) via Single Window.
Persons who do not meet the requirements of the notice and have no interest in the substances may submit a Declaration of Non-Engagement (DNE) by email.
Refer to the Information gathering initiatives and Guidance manual web pages for additional information on responding to the notice, including detailed steps on how to submit the Excel Reporting File, SHI and DNE.
If you require information from your foreign suppliers in order to respond to the notice, a letter for communicating with your foreign suppliers is available upon request by email.
More information:
- Bisphenol A (BPA) and BPA structural analogues and functional alternatives (BPA SAFAs)
- Canada Gazette Notice
- Excel Reporting File
- Guidance manual
For any questions or inquiries, please contact the Substances Management Information Line.
Telephone: 1-800-567-1999 (Toll Free in Canada) or 1-819-938-3232 (Outside of Canada)
If using email, please indicate “BPA SAFA Notice Inquiry” in the subject line
Email: substances@ec.gc.ca