[Home](/)/[Resources](/resources)/Canada CEPA New Substances CanadaEnvironmentalChemicals # Canada CEPA New Substances Notification: What Electronics and Hardware Companies Must Know The Canadian Environmental Protection Act, 1999 (CEPA 1999) is Canada's primary federal environmental statute, and its New Substances notification regime is the one most likely to catch hardware companies off guard. Any chemical substance, polymer, or biochemical not already on Canada's Domestic Substances List (DSL) cannot be manufactured in or imported into Canada above threshold quantities without prior notification to Environment and Climate Change Canada (ECCC). Hardware companies import electronics containing novel coatings, dielectric fluids, adhesives, conformal coatings, and other chemical formulations — many of which may not be DSL-listed. A failure to notify before import is a CEPA violation; the penalties can be severe and the corrective action — returning goods to sender — is operationally disruptive. Copy Link[Share on WhatsApp](https://wa.me/?text=https%3A%2F%2Fkrono-labs.com%2Fguides%2Fcanada-environmental-protection-act) At a glance Administering body Environment and Climate Change Canada Key legislation CEPA 1999 DSL search Free ECCC online tool Assessment period 75 days (chemicals) ## How CEPA's New Substances regime works for hardware companies ### The Domestic Substances List (DSL) The DSL is Canada's inventory of chemical substances deemed to be in Canadian commerce. Substances on the DSL do not require New Substances notification — they are considered assessed for the purposes of CEPA. There are approximately 23,000 substances on the DSL. The Non-Domestic Substances List (NDSL) is a second list of about 65,000 substances assessed internationally but not yet DSL-listed — NDSL substances can be imported without notification subject to quantity limits. ### What triggers a New Substances notification If a substance is neither on the DSL nor the NDSL, it requires formal New Substances notification before manufacture or import above threshold quantities. Thresholds are set in the New Substances Notification Regulations (Chemicals and Polymers): quantities as low as 100 kg/year for new substances on Schedule 9 trigger full notification. Some categories have higher thresholds (1,000 kg/year or 10,000 kg/year) with corresponding lighter information requirements. ### What counts as a 'substance' for CEPA purposes CEPA's definition of substance is broad: it includes both discrete chemical compounds and mixtures, polymers, and complex substances. An electronics conformal coating that is a novel polymer formulation not on the DSL is a substance. A new dielectric fluid formulated specifically for a customer is a substance. Importers of articles (physical goods) are generally not required to notify for substances contained within articles — but this exemption has limits when the substance is released during normal use. ### CEPA toxic substance assessments (Significant New Activity provisions) Even DSL-listed substances can be subject to Significant New Activity (SNAc) provisions — essentially a flag on the DSL entry that requires notification if the substance is to be used in a new, potentially higher-risk way. Hardware companies moving into new applications (e.g., using an existing substance in a direct food-contact application it wasn't previously used for) should check whether the DSL entry carries SNAc obligations. ### Interaction with RoHS-analogous requirements CEPA's prohibition orders — issued when a substance is found toxic and risk-managed — can effectively replicate or exceed EU RoHS restrictions. Canada has issued prohibition orders on several substances including lead in solders (with electronics exemptions) and polybrominated diphenyl ethers (PBDEs). Hardware companies should check current Canadian prohibition orders against their bill of materials in addition to checking EU RoHS compliance. ## CEPA New Substances compliance process 01 Screen your product's chemical inputs — coatings, adhesives, flux, thermal interface materials, dielectric fluids, and any chemistry applied in manufacturing — against the DSL and NDSL. ECCC provides a free online DSL/NDSL search tool. Substance identity verification is important: CAS numbers must match DSL entries precisely. 02 For substances not on the DSL or NDSL, calculate annual import quantities and compare to the notification thresholds in the New Substances Notification Regulations (Chemicals and Polymers). If thresholds are exceeded, notification is required before manufacture or import begins. 03 Prepare the notification package appropriate to the schedule — the information requirements range from basic physical/chemical data (for early notification tiers) to full toxicological and ecotoxicological data packages (for higher-volume or higher-risk substance entries). Third-party toxicology review is typically required for full notifications. 04 Submit the notification to ECCC's New Substances program. ECCC has statutory assessment periods: typically 75 days for chemicals, 45 days for polymers (with extensions possible). During the assessment period, the substance cannot be imported or manufactured above notification thresholds. 05 After assessment, comply with any conditions of use that ECCC attaches to the notification outcome. Conditions can include use restrictions, exposure limits, or requirements for additional testing. Some notifications result in 'Significant New Activity' designations that restrict the range of permissible uses. ## Frequently asked questions ### Does CEPA apply to goods imported as finished products (articles)? Generally, the article exemption means that substances contained within solid articles — circuit boards, housings, encapsulants — do not trigger CEPA New Substances notification for the importer of the finished product, as long as the substance doesn't deliberately release during normal use. However, Canada has enacted specific prohibition orders for certain substances in articles (e.g., PBDEs, mercury in some product categories), and these apply to articles directly — not just chemical imports. ### Is CEPA's DSL the same as REACH's SVHC list? They are different tools with different purposes. The DSL is Canada's inventory of substances in commerce (assessing whether notification is needed). REACH's SVHC list is the EU's list of substances of very high concern subject to authorization or restriction. A substance on the DSL may still be restricted under a CEPA prohibition order, and a REACH-compliant substance may not be DSL-listed and thus require CEPA notification for Canadian import. ### How does Canada handle PFAS under CEPA? ECCC has assessed several PFAS substances as toxic under CEPA and has proposed or enacted risk management measures — including some prohibition orders. Long-chain perfluoroalkyl carboxylic acids (LC-PFCAs) and their salts are prohibited from manufacture and import. PFAS as a broad class is under ongoing CEPA assessment, and the regulatory landscape is evolving rapidly — hardware companies using fluorinated coatings or materials should monitor ECCC's PFAS risk management measures actively. ### What penalties apply to CEPA violations? CEPA's penalty regime under Part 10 includes administrative monetary penalties up to CAD 25,000 per day for most violations. Criminal offences can result in fines up to CAD 12 million per day for large corporations. CEPA also includes environmental protection compliance orders that can require immediate cessation of import or manufacture — more operationally disruptive than the fine itself for companies mid-shipment. **Disclaimer:** Educational resource only. Regulatory requirements change and vary by product category. Consult an accredited test laboratory or qualified compliance engineer before making certification decisions. 🇨🇦 Canada roadmap for your product Every standard, document, and test that applies — free, no account required. See your free roadmap[ Want an expert to take your product through 🇨🇦 Canada compliance for you? One consultant from Krono's compliance team takes your product from requirements to legal sale, with a fixed quote before any work starts. See compliance services](/services) Learn this properly In-depth course that teaches the full process, not just this one answer. [Start the course — $149](/courses/47-canada-ised-ic-certification-radio-equipment)[Prefer to read? Get the book — $24.99](/books/47-canada-ised-ic-certification-radio-equipment) Related guides * [Canada CEPA New SubstancesCanada CEPA 1999 new substances notification: the Domestic Substances List, when the article exemption applies to electronics, NSN process, and PFAS/flame retardant CEPA controls.](/guides/canada-cepa-new-substances) * [Canada Hazardous Products ActCanada's Hazardous Products Act and WHMIS 2015 for hardware: GHS hazard classification, 16-section SDS obligations, and bilingual supplier label requirements.](/guides/canada-hazardous-products-act) * [Canada EPR Electronics PackagingProvincial EPR programs for electronics and packaging across Canada: EPRA e-waste, Recycle BC, Ontario RPRA, and Quebec RECYC-QUÉBEC obligations.](/guides/canada-epr-electronics-packaging) * [Canada Carbon Pricing for ManufacturersCanada's federal Output-Based Pricing System and fuel charge applied to electronics manufacturing facilities: Greenhouse Gas Pollution Pricing Act thresholds, compliance credit mechanics, and provincial equivalency agreements.](/guides/canada-environmental-carbon-pricing)