Scope of the Canadian Environmental Protection Act

Question: The Canadian Environmental Protection Act (CEPA) requires companies to report certain products using quaternary ammonium compounds. What finished products (i.e. articles, not chemicals) are in scope of this requirement?

Answer: CEPA’s guidance indicates quaternary ammonium reporting requirement targets items “considered to be key sources of exposure to the general population.” Products (non-chemicals) impacted fall into one of three categories, defined as manufactured items:

  • Intended to be used by or for children under the age of six years.
  • Items intended to come into contact with the mucosa of an individual. Mucosa is defined as a group of mucous membranes that line parts of the body that lead to the outside and are exposed to air (i.e. mouth, digestive tract, urogenital tract, respiratory tract and ears).
  • Items intended to release the substance during conditions of use such that the substance may be inhaled or come into dermal contact with an individual.

This content is accurate as of May 10, 2019.

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