Guidance for responding to the
Notice with respect to substances included as part of the
2017 Inventory Update
(the Notice)

Published in the Canada Gazette, Part I, on January 14, 2017

Date modified: May 18, 2017

(PDF Format - 851 KB)

Table of Contents

• 1. Overview
  • 1.1 Purpose of the Notice
  • 1.2 Information to which you may reasonably be expected to have access
  • 1.3 Information previously submitted
• 2. Reportable Substances - Schedule 1 of the Notice
• 3. Persons Required to Provide Information - Schedule 2 of the Notice
  • 3.1 Reporting Criteria
  • 3.2 Exclusions
  • 3.3 Calendar years targeted by the notice
  • 3.4 Reportable activities
    • 3.4.1 Manufacture
    • 3.4.2 Import
    • 3.4.3 Import of Mixtures, Products and Manufactured Items
  • 3.5 Quantity and concentration thresholds for responding to the Notice
• 4. Reportable Codes
  • 4.1 North American Industry Classification System (NAICS) codes
  • 4.2 Substance Function Codes
  • 4.3 Consumer and Commercial Codes
    • 4.3.1 Additional Information Related to Consumer and Commercial Codes
• 5. Sections to be completed - Schedule 3 of the Notice
  • 5.1 Illustrative example
  • 5.2 Section 5 - Activity from 2012 to 2015
  • 5.3 Section 6 - Facilities
  • 5.4 Section 7 - Total Quantity
  • 5.5 Section 8 - Uses and applications of the substance alone, in mixtures or products
  • 5.6 Section 9 - Canadian Customers
  • 5.7 Section 10 - Uses and Applications of the Substance in Manufactured Items
• 6. Request for confidentiality
• 7. Blind submissions
• 8. Declaration of Stakeholder Interest
• 9. Declaration of Non-Engagement
• 10. Submission of Voluntary Information
• 11. Reporting Deadline
• 12. Online Reporting Tool
• 13. What if I need more time to comply with the Notice?
• 14. Questions?
• Appendices
  • Appendix A: Substance Function Codes and Corresponding Descriptions
  • Appendix B: Consumer and Commercial Codes and Corresponding Descriptions

List of Tables

• Table 1: Categories of reportable manufactured items and examples
• Table 2: Information required based on activity

List of Figures

• Figure 1: Reporting diagram for each substance listed in Part 1 and Part 2
• Figure 2: Reporting diagram for each substance listed in Part 3
• Figure 3: Reporting diagram for each substance listed in Part 4

This document provides guidance for responding to the Notice with respect to substances included as part of the 2017 Inventory Update published in the Canada Gazette, Part I, on January 14, 2017, pursuant to paragraph 71(1)(b) of the Canadian Environmental Protection Act, 1999 (the Act). In case of discrepancy between this document and the Notice or the Act, the official versions of the Notice and the Act take precedence.

1. Overview

1.1 Purpose of the Notice

Announced as a key component of the Chemicals Management Plan (CMP), current information on the commercial activities of substances in Canada is critical to support priority setting and decision making for on-going management of chemicals in the future.

Moving forward, inventory update (IU) will be conducted in an on-going, cyclical manner, with reporting to the government every four years. The scope of the IU considers emerging science, evolving domestic and international programs and the timely information on the commercial status of substances in Canada in order to ensure future priorities are reflective of Canada’s dynamic market.

The 2017 Inventory Update (2017 IU) collects information on approximately 1500 chemicals and polymers to inform activities in priority setting, risk assessment and risk management programs at Environment and Climate Change Canada and Health Canada, including prioritization for activities in 2020 and beyond.

The selection of substances for the 2017 IU was based on:

• results from the Identification of Risk Assessment Priorities (IRAP) approach
• available new monitoring, biomonitoring and surveillance data
• significance in other jurisdictions
• new relevant information for substances with unknown commercial status or where changes in the marketplace could be of concern
• recent additions to the Domestic Substances List
• substances of concern for which monitoring of non-regulated activities is required
• certain substances of concern for potential endocrine effects

Although the criteria for future IUs are not yet finalized, they are anticipated to be similar and be based on lessons learned and experiences from this current iteration.

1.2 Information to which you may reasonably be expected to have access

You are required to provide information that your company possesses or to which you may be reasonably expected to have access. For example, manufacturers would be reasonably expected to have access to their formulations. When importing a substance, mixture, product or manufactured item, you may be reasonably expected to have access to import records and the relevant Safety Data Sheets (SDS) that contain information on the composition of the imported goods. Your supply chain and sector association may be able to provide more detailed information on product composition.

Suppliers may have information that you may not be aware of as an importer. Working with your supply chain to obtain the requested information will help the Government of Canada ensure all activities related to these substances are considered before taking any further action.

Suppliers who wish to protect their formulations can submit the information directly to the Government of Canada as a blind submission.

Tip: You are not required to conduct tests to comply with the Notice.

1.3 Information previously submitted

As indicated in section 3 of Schedule 3 of the Notice, if any of the information required under the Notice was previously submitted to the Government of Canada, it may be relied on as your response to any question in Schedule 3 to the Notice if the information previously submitted is applicable to the calendar year for which you are responding to the Notice.

If this applies to you, the previously submitted information is not required to be resubmitted under the Notice; you must simply provide the following information as an attachment to your submission:

• the CAS RN or the Confidential Accession Number of the substance(s) to which the submitted information relates;
• the date on which the information was submitted;
• the name of the person who submitted the information; and
• the program and/or individuals at the Government of Canada to which the information was submitted.

"Example: During a voluntary data collection initiative, you provided 2010 data to the Minister of the Environment for a substance listed in Schedule 1 to the Notice, and the data is still applicable for the 2015 calendar year. You should reference the previously submitted information in response to the applicable section(s) of Schedule 3, and attach the information specified in section 3 of Schedule 3.

2. Reportable Substances - Schedule 1 of the Notice

Schedule 1 of the Notice lists 1430 reportable substances subject to this Notice. Based on the different information requirements for the various substances, Schedule 1 is divided into four separate parts.

• Part 1 contains 219 substances
• Part 2 contains 26 substances
• Part 3 contains 507 substances
• Part 4 contains 678 substances

Note that, although identified by two different CAS RNs, the following substances are in fact the same:

• CAS RN 1506-02-1: Ethanone, 1-(5,6,7,8-tetrahydro-3,5,5,6,8,8- hexamethyl-2-naphthalenyl)-
• CAS RN 21145-77-7: Ethanone, 1-(5,6,7,8-tetrahydro-3,5,5,6,8,8- hexamethyl-2-naphthalenyl)-

Therefore, when considering the quantity threshold, a combined total quantity greater than 100 kg for both CAS RN 1506-02-1 and CAS RN 21145-77-7 is applicable.

It is important to note that Part 4 substances are found on the Revised In Commerce List and are reportable under the Notice ONLY when they are, are contained in, or are intended to be components in the following products subject to the Food and Drugs Act:

• cosmetics,
• food,
• therapeutic products or
• natural health products

For definitions of each term above (cosmetic, food, therapeutic product and natural health product), you should refer to the Food and Drugs Act.

While the Food and Drugs Act defines “food” as including "any article manufactured, sold or represented for use as food or drink for human beings, chewing gum, and any ingredient that may be mixed with food for any purpose whatsoever”, the intention is to obtain information on substances permitted for use as food additives and novel foods. Information on permitted food additives and novel foods can be found in the Food and Drug Regulations. It is not expected that other food ingredients intended for human consumption would be reported.

Substances in Part 4 in other applications do not have to be reported under the Notice, but may be subject to the New Substances Notifications Regulations.

The reporting requirements for the various parts differ. More information on the reporting requirements can be found in Section 5. Throughout the Notice, as well as this guidance document, there will be a clear indication as to which substances are implicated in the various sections. As a result, sections that apply to all substances will read "For each substance listed in Schedule 1…" whereas those that only apply to substances in a specific part of Schedule 1 read "For each substance listed in Part x of Schedule 1…".

3. Persons Required to Provide Information – Schedule 2 of the Notice

3.1 Reporting Criteria

To determine whether you are required to respond, the following factors must be considered:

• Exclusions
• Calendar year
• Type of activity
• Quantity and concentration threshold

The Notice applies to those who, during either the 2014 or 2015 calendar year, met any of the following criteria:

• Manufactured a total quantity greater than 100 kg of a substance listed in Part 1, Part 2 or Part 3 of Schedule 1 to the Notice;
• Manufactured a total quantity greater than 100 kg of a substance listed in Part 4 of Schedule 1 to the Notice, that is, or that is intended to be a component in, a cosmetic, food, therapeutic product or natural health product subject to the Food and Drugs Act;
• Imported a total quantity greater than 100 kg of a substance listed in Part 1, Part 2 or Part 3 of Schedule 1 to the Notice, whether the substance is:
  • alone;
  • at a concentration greater than or equal to 0.1% by weight (w/w%) in a mixture or in a product; or
  • listed in Part 3 of Schedule 1 and at a concentration greater than or equal to 0.1% by weight (w/w%) in a reportable manufactured item.
• Imported a total quantity greater than 100 kg of a substance listed in Part 4 that is, is contained in, or is intended to be a component in, a cosmetic, food, therapeutic product or natural health product subject to the Food and Drugs Act.

The 10 categories of reportable manufactured items are listed, with examples, in section 3.4.3.

If your company who owns more than one facility, you must meet the reporting criteria on a company-wide basis. Your response for each question should be an amalgamated response that includes information from all facilities owned by the company, except for section 6 which requires an individual response per facility.

For example, your company owns 4 facilities. A reportable substance is being imported from a foreign supplier and is shipped directly from your supplier to each of your facilities. The facilities receive 20 kg, 15 kg, 50 kg and 40 kg of the reportable substance respectively. You imported a total of 125 kg of the substance on a company-wide basis, and have met the quantity threshold for responding to the Notice.

The following reporting diagrams can be used to determine whether you are required to respond to the Notice.

Long description for figure 1

The figure provides a schematic description of the reporting requirements for Notice with respect to substances included as part of the 2017 Inventory Update using a flow diagram. The diagram is composed of multiple rectangular and oval boxes that are connected with unidirectional arrows.
1. Starting from the top part of the diagram, the first box asks whether you need to report for Part 1 and Part 2 substances. If you want to know if you need to report for a Part 1 and Part 2 substance, you are directed to the second and third boxes.
2. The second box asks whether you imported the substance in 2014 or 2015. If your answer is yes, then you are directed to the fourth box. If your answer is no, then you are directed to the sixth box.
3. The third box asks if you manufactured the substance in 2014 or 2015. If your answer is yes, then you are directed to the fifth box. If your answer is no, then you are directed to the sixth box.
4. The fourth box asks importers whether the substance was imported alone, or at a concentration greater than or equal to zero point one percent by weight in a mixture or a product. If your answer is yes, then you are directed to the fifth box. If your answer is no, then you are directed to the sixth box.
5. The fifth box asks whether the quantity of substance imported or manufactured was greater than one hundred kilograms for 2014 or 2015. If your answer is yes, then you are directed to the seventh box. If your answer is no, then you are directed to the sixth box.
6. The sixth box informs you that you do not have a legal obligation to report for this activity and it directs you to the eighth and ninth box.
7. The seventh box asks whether you met all of the above criteria for 2015. If your answer is no, then you are directed to the tenth box. If your answer is yes, then you are directed to the eleventh box.
8. The eighth box encourages you to submit a Declaration of Non-Engagement if you have no involvement with a reportable substance.
9. The ninth box encourages you to submit a Declaration of Stakeholder Interest (for voluntary data) if you have a past, current or future interest for a reportable substance.
10. The tenth box informs you that you have a legal obligation to report for this activity for 2014.
11. The eleventh box informs you that you have a legal obligation to report for this activity for 2015.

Long description for figure 2

The figure provides a schematic description of the reporting requirements for Notice with respect to substances included as part of the 2017 Inventory Update using a flow diagram. The diagram is composed of multiple rectangular and oval boxes that are connected with unidirectional arrows.
1. Starting from the top part of the diagram, the first box asks whether you need to report for Part 3 substances. If you want to know if you need to report for a Part 3 substance, you are directed to the second and third boxes.
2. The second box asks whether you imported the substance in 2014 or 2015. If your answer is yes, then you are directed to the fourth box. If your answer is no, then you are directed to the seventh box.
3. The third box asks if you manufactured the substance in 2014 or 2015. If your answer is yes, then you are directed to the sixth box. If your answer is no, then you are directed to the seventh box.
4. The fourth box asks importers whether the substance was imported alone, or at a concentration greater than or equal to zero point one percent by weight in a mixture or a product. If your answer is yes, then you are directed to the sixth box. If your answer is no, then you are directed to the fifth box.
5. The fifth box asks importers whether the substance was imported at a concentration greater than or equal to zero point one percent by weight in a manufactured item listed in subparagraph 3(c) of Schedule 2. If your answer is yes, then you are directed to the sixth box. If your answer is no, then you are directed to the seventh box.
6. The sixth box asks whether the quantity of substance imported or manufactured was greater than one hundred kilograms for 2014 or 2015. If your answer is yes, then you are directed to the eighth box. If your answer is no, then you are directed to the seventh box.
7. The seventh box informs you that you do not have a legal obligation to report for this activity and it directs you to the ninth and tenth box.
8. The eighth box asks whether you met all of the above criteria for 2015. If your answer is no, then you are directed to the eleventh box. If your answer is yes, then you are directed to the twelfth box.
9. The ninth box encourages you to submit a Declaration of Non-Engagement if you have no involvement with a reportable substance.
10. The tenth box encourages you to submit a Declaration of Stakeholder Interest (for voluntary data) if you have a past, current or future interest for a reportable substance.
11. The eleventh box informs you that you have a legal obligation to report for this activity for 2014. 12. The twelfth box informs you that you have a legal obligation to report for this activity for 2015.

Long description for figure 3

The figure provides a schematic description of the reporting requirements for Notice with respect to substances included as part of the 2017 Inventory Update using a flow diagram. The diagram is composed of multiple rectangular and oval boxes that are connected with unidirectional arrows.
1. Starting from the top part of the diagram, the first box asks whether you need to report for Part 4 substances. If you want to know if you need to report for a Part 4 substance, you are directed to the second box.
2. The second box asks whether the substance was a cosmetic, food, therapeutic product or natural health product subject to the Food and Drugs Act, or if it was contained in such a product, or intended to be a component in such a product. If your answer is yes, then you are directed to the third and fourth boxes. If your answer is no, then you are directed to the sixth box.
3. The third box asks whether you imported the substance in 2014 or 2015. If your answer is yes, then you are directed to the fifth box. If your answer is no, then you are directed to the sixth box.
4. The fourth box asks if you manufactured the substance in 2014 or 2015. If your answer is yes, then you are directed to the fifth box. If your answer is no, then you are directed to the sixth box.
5. The fifth box asks whether the quantity of substance imported or manufactured was greater than one hundred kilograms for 2014 or 2015. If your answer is yes, then you are directed to the seventh box. If your answer is no, then you are directed to the sixth box.
6. The sixth box informs you that you do not have a legal obligation to report for this activity and it directs you to the eighth and ninth box.
7. The seventh box asks whether you met all of the above criteria for 2015. If your answer is no, then you are directed to the tenth box. If your answer is yes, then you are directed to the eleventh box.
8. The eighth box encourages you to submit a Declaration of Non-Engagement if you have no involvement with a reportable substance.
9. The ninth box encourages you to submit a Declaration of Stakeholder Interest (for voluntary data) if you have a past, current or future interest for a reportable substance.
10. The tenth box informs you that you have a legal obligation to report for this activity for 2014.
11. The eleventh box informs you that you have a legal obligation to report for this activity for 2015.

The following are examples of how to determine whether the reporting criteria of the notice are met:

Company meets the reporting criteria if:

• in 2015, your company manufactured 300 kg of a reportable substance. The quantity threshold (greater than 100 kg) reporting criterion is met.
• in 2014, your company imported 500 kg of a mixture that contained 10% of a reportable substance and 300 kg of a product that contained 50% of the same reportable substance. The total quantity of the reportable substance imported is 200 kg. Both the concentration (greater than 0.1%) and quantity threshold (greater than 100 kg) reporting criteria are met.
• in 2015, your company imported 800 kg of a cosmetic containing 20% of a substance in Part 4 of Schedule 1. The total quantity of the reportable substance is 160 kg. The quantity threshold (greater than 100 kg) reporting criteria is met, as well as the application criterion for Part 4 substances.

Company does not meet the reporting criteria if:

• your company imported 1,000 kg of a reportable substance during the 2013 calendar year only, then the reporting year criterion is not met.
• in 2014, your company imported 6,000 kg of a product that contained 0.08% of a reportable substance. The quantity of the substance imported is 480 kg. Although the quantity threshold is met, the concentration threshold is not met. You are encouraged to provide the information on the substance on a voluntary basis, by filling out the Declaration of Stakeholder Interest.
• in 2015, your company imported 200 kg of a mixture that contained 5% of a reportable substance. Since only 10 kg of the substance was imported, the quantity threshold for responding to the notice is not met. You are encouraged to provide the information on the substance on a voluntary basis, by filling out the Declaration of Stakeholder Interest.
• in 2014, your company imported 500 kg of a mixture that contained 5% of a reportable substance and 1,000 kg of a manufactured item that contained 1% of the same reportable substance. The substance is in Part 1 of Schedule 1 which does not require reporting on manufactured items. Since only 25 kg of substance was imported in the mixture, the quantity threshold for responding to the notice is not met. You are encouraged to provide the information on the substance on a voluntary basis, by filling out the Declaration of Stakeholder Interest.
• your records indicate that you do not have any commercial interest for any of the reportable substances. You are encouraged to submit a Declaration of Non Engagement.

3.2 Exclusions

There are several exclusions that apply to this Notice, which are found in Schedule 2:

• A substance that is in transit through Canada
  • Tin fluoride (CAS RN 7783-47-3) contained in dental care products or mixtures;
  • A substance that is, or is contained in, a hazardous waste or hazardous recyclable material within the meaning of the Export and Import of Hazardous Waste and Hazardous Recyclable Material Regulations and that was imported pursuant to a permit issued under those Regulations;
  • A substance that is, or is contained in, a pest control product registered under the Pest Control Products Act;
  • A substance that is, or is contained in, a fertilizer or supplement registered under the Fertilizers Act;
  • A substance that is, or is contained in, a feed registered under the Feeds Act; or
  • A substance that is mixed with, or attached to, a seed registered under the Seeds Act.

Note, "in transit" refers to the portion of an international transboundary movement of a substance through the territory of a country that is neither the country of origin nor the country of destination of the movement. At time of entry into Canada, if the shipping destination of the substance is located outside of Canada, then the substance is considered to be in transit. For example, a substance that enters Canada on a ship from Europe with a final destination in Seattle, Washington, is transferred from the ship in Halifax to a truck that brings it to Toronto where it is placed on a rail car that brings it to Vancouver, then transferred on a truck that brings it to Seattle, is considered to be in transit in Canada.

3.3 Calendar years targeted by the notice

The Notice applies to two calendar years, 2014 and 2015, but you only have to report for one (the most recent).

The reporting year is determined by the most current year in which the activity took place. This means that for any substances where the reporting criteria are met for 2015, the reporting year becomes is 2015. If you meet the reporting requirements for both the 2015 and 2014 calendar years for a specific substance, then you must only provide information for that substance for 2015 only. However, your activity with the substance in the alternate year may still be of interest to the Government and you can provide this information on a voluntary basis via the Declaration of Stakeholder Interest.

Since the reporting criteria must be applied to each substance, you may have to report for 2014 for some substances while providing information for 2015 for others.

If you do not meet the reporting requirements for either 2014 or 2015, you are not legally obligated to respond to the Notice. However, if you have activity with a reportable substance for a different calendar year, this information may be of interest to the Government, and you can provide information on a voluntary basis via the Declaration of Stakeholder Interest.

3.4 Reportable activities

Manufacture and import are the two activities reportable under the Notice.

3.4.1 Manufacture

Manufacture relates to the creation or production of the substance itself and includes both intentional, and incidental production of the substance. Manufacture does not refer to the manufacture of a mixture, product or manufactured item containing the substance.

Incidental production of a substance may occur if, during the process of blending or formulating, a chemical reaction occurs that results in the production of a substance that is reportable under the Notice. Additionally, a naturally occurring substance listed under Schedule 1 is considered as "manufactured" if it is extracted from its natural source. However, the naturally occurring substance is not "manufactured" if it is unprocessed, or if it processed only by manual, gravitational or mechanical means, by dissolution in water, by flotation or by heating solely to remove water; or extracted from air by any means.

Possible situations where you are considered to manufacture a substance include, but are not limited to, the following examples:

• You conducted a reaction of substance A with substance B to produce substance C. You manufactured substance C.
• You blended substance D with substance E, and substance F was produced as a reaction by-product. You manufactured substance F.
• You extracted a mixture of waste and ore from the ground and separated substance G by electrorefining. You manufactured substance G.

It is important to note that for the purpose of the Notice, making a mixture, product or manufactured item containing a reportable substance would NOT be considered "manufacture". In this case, the activity is considered "use", which is not a reportable activity under the Notice. However, your activity with the substance may still be of interest to the Government and you can provide this information on a voluntary basis via the Declaration of Stakeholder Interest.

3.4.2 Import

"Import relates specifically to the movement into Canada from another country of any substance listed in the Notice, whether the substance is imported alone or in a mixture, a product or a manufactured item".

Examples of activities that meet the definition of "import":

• You purchased a substance listed in the Notice from a foreign supplier, and the substance was shipped directly from the foreign supplier to your location in Canada
• You ordered a mixture containing a reportable substance from a foreign source, and the mixture was shipped directly from the foreign source to a distribution warehouse in Canada, on your request
• You received a product containing a reportable substance as an internal company transfer from a foreign source

Examples of activities that do not meet the definition of "import":

• You purchased a manufactured item containing a reportable substance from a Canadian company
• You ordered a product containing a reportable substance from a warehouse located in Canada
• You transferred a mixture containing a reportable substance across provincial borders to be stored in a different warehouse
• You purchased or received a substance listed in the Notice alone, or in a mixture, a product or a manufactured item that was already located in Canada

Importers of record and foreign suppliers

The sender or foreign supplier (i.e. exporting to Canada) is not required to respond to the Notice. It is rather the receiver (who imports to Canada) that is subject to a notice if the requirements are met. "Importer of Record" is a term used for the purpose of Canadian Border Services Agency, and may or may not be the same company that is required to report to a notice. An importer is the person responsible for the movement of substance(s) into Canada from another country. For the purposes of the Notice, the person responsible for responding to the Notice is the company who "caused" the substance (whether alone, in a mixture, in a product or in manufactured item) to come into Canada. In other words, the substance came into Canada on their request.

"Importers of record" located outside of Canada (i.e. "non-resident importers") are encouraged to inform their customers that they import a reportable substance and may meet the reporting requirements of the Notice. Foreign suppliers can also choose to submit information voluntarily on behalf of their Canadian customers. If confidential business information (CBI) cannot be shared with Canadian customers to allow them to respond to the notice, please refer to Section 7 for information on the blind submission process. This process allows foreign suppliers and Canadian customers to collaborate to provide all the information required in the Notice while still protecting CBI.

3.4.3 Import of Mixtures, Products and Manufactured Items

The reporting criteria may differ whether the substance is alone, in a mixture or in a product, or if it is in a manufactured item.

Tip: For this Notice, you do not have to differentiate between mixture and product since the reporting requirements are consistent for both. However, you will have to identify if your substance is found in a manufactured item as reporting requirements for these differ.

Mixtures

A mixture is a combination of substances that does not produce a substance that is different from the substances that were combined. Mixtures include, but are not limited to:

• prepared formulations;
• homogenous and heterogeneous alloys
• hydrates; and
• reaction mixtures that are characterized in terms of their constituents.

Products

A product is anything that does not meet the definition of a mixture or manufactured item.

Products include, but are not limited to:

• paints and coatings
• ink refills and colourants
• cosmetics and personal care products (e.g. toothpaste, mouthwash, creams, and lotions)
• cleaning liquids, gels or sprays
• adhesives and glues

Manufactured items

A manufactured item is an item that is formed into a specific physical shape or design during manufacture and has, for its final use, a function or functions dependent in whole or in part on its shape or design.

For Part 3 substances only, 10 categories of manufactured items are reportable, targeting items that are considered to be key sources of exposure to the general population. Part 3 substances imported in other manufactured items are not reportable under the notice.

Manufactured items containing Part 4 substances that are considered cosmetics, foods, therapeutic products, and natural health products are also reportable.

Tip: For a specific substance, one or more of the categories identified in Table 1 can be applicable.

Important definitions to consider:

• Mucosa is defined as a group of mucous membranes that line parts of the body which lead to the outside and are exposed to air (i.e., mouth and digestive tract, urogenital tract (urethra and vagina), respiratory tract (including the nose) and ears).
• Direct contact with food occurs when a manufactured item (e.g., cookware, cooking or serving utensils, reusable food or beverage containers, or food packaging) is not separated from the food or beverage by an effective functional barrier, so there is potential for substances to migrate to the food or beverage.
• Inhalation or dermal contact is reasonably expected to occur if the substance is intentionally released when the manufactured item is used in accordance with instructions or as intended by the manufacturer.
• Textile fibre means any natural or manufactured matter that is capable of being made into a yarn or fabric and, without limiting the generality of the foregoing, includes human hair, kapok, feathers and down and animal hair or fur that has been removed from an animal skin.
• Fabric means any material woven, knitted, crocheted, knotted, braided, felted, bonded, laminated or otherwise produced from, or in combination with, a textile fibre.

3.5 Quantity and concentration thresholds for responding to the Notice

You are required to respond to the Notice for any substance that was manufactured or imported in a quantity greater than 100 kg in either of the 2014 or 2015 calendar years. This is the quantity of the substance itself, and not the quantity of the product, mixture or manufactured item containing the substance.

Quantities reported in the Notice should be:

• for the substance itself and not the quantity of the mixture, product or manufactured item containing the reportable substance.
• in kilograms (kg)
• rounded to 2 significant digits. For example:
  • 0.0368 should be reported as 0.037
  • 831.29 should be reported as 830
  • 541 231 should be reported as 540 000

Tip: Remember that this quantity threshold applies to each activity with a substance on a company-wide basis.

When considering the quantity threshold, a combined total quantity greater than 100 kg for both CAS RN 1506-02-1 and CAS RN 21145-77-7 is applicable.

When importing a Part 1, Part 2 or Part 3 substance in a mixture, a product or a manufactured item, you will also need to determine whether the concentration threshold of 0.1% by weight is met. Only mixtures, products or manufactured items containing a reportable substance at a concentration greater than or equal to 0.1% by weight are required to be included in your response to the Notice.

Possible situations where you may meet the reporting requirements for quantity and/or concentration include, but are not limited to, the following examples:

• In 2014, your company imported 4,000 kg of Product X that contains 50% of a reportable substance. A total quantity of 2,000 kg of the substance was imported, and the quantity threshold of 100 kg is met. Additionally, the concentration of 50% exceeds the concentration threshold of 0.1% therefore the concentration threshold is also met.
• In 2015, your company imported 500 kg of Mixture X that contains 10% of a reportable substance and 300 kg of Product Y that contains 20% of the same substance. A total quantity of 110 kg of the substance was imported, and the quantity threshold is met. Additionally, the concentrations of 10% and 20% exceed the concentration threshold of 0.1% therefore the concentration threshold is also met for both the mixture and the product.

The following is an example where one of two imported mixtures does not meet the concentration threshold of 0.1%:

• In 2015, your company imported 1,000 kg of Mixture X that contains 5% of a reportable substance (equal to 50 kg of substance) and 500,000 kg of Product Y that contains 0.05% of the same substance (equal to 250 kg of substance). Although you imported a total of 300 kg of reportable substance, Product Y does not meet the concentration threshold of 0.1%.Therefore you are not required to take Product Y into account in your calculations. As a result, the quantity threshold of 100 kg is not met since you are only required to report on Mixture X (equal to 50 kg of substance).

4. Reportable Codes

When submitting your response to the notice, you may be required to consider 3 sets of codes:

• North American Industry Classification System (NAICS) codes
• Substance Function Codes
• Consumer and Commercial Codes

These codes have been developed jointly with other North American partners to facilitate the exchange of information between countries and to encourage consistency in reporting on chemical substances by industry.

4.1 North American Industry Classification System (NAICS) codes

In your response to the Notice, for each of your facilities where substances listed in Part 1, Part 2 or Part 3 were manufactured or to which they were imported for purposes other than distribution or warehousing, you will be required to provide the applicable NAICS codes. You should report the code(s) that best describes the activities taking place at each facility. The code(s) will provide general information on the number and types of sectors involved with the substances listed in the Notice.

The NAICS 2017 list of codes is available at the Statistics Canada web site

4.2 Substance Function Codes

Substance Function Codes, beginning with the letter U, are used to describe the function of a substance. The codes refer to the function of the substance itself with regards to the intended physical or chemical characteristic for which a chemical substance is consumed as a reactant; incorporated into a formulation, mixture, product, or manufactured item; or used.

For example, if the substance function is to;

• Polish a surface, then, substance function code "U001 - Abrasives" should be selected;
• Give colour to a mixture, then, substance function code "U021 - Pigments" should be selected;
• Dissolve oils from a textile, then, substance function code "U029 - Solvents (for cleaning or degreasing" should be selected.

The Substance Function Codes are listed in Appendix A with their descriptions and some examples. Note that for this Notice, the following new Substance Function Codes have been created:

• Active ingredients in health products (U062)
• Flavourants (in foods and health products) (U063)
• Contaminants (U064), by-products (U065) and wastes (U066).

Tip: Code U999 can be used when there is no other code to match the function of the substance. When selecting this code, a concise written description of the substance function must be provided.

4.3 Consumer and Commercial Codes

Consumer and Commercial Codes, beginning with the letter C, are used to identify the application of the mixture, product or manufactured item containing a substance with regards to its purpose in a consumer or commercial setting.

These codes also apply to substances, mixtures, products, and manufactured items that may be used in an industrial setting only or for an industrial application.

For example, if the substance is contained in;

• A toothpaste, then, Commercial and Consumer code "C108 - Personal care" should be selected;
• A floor paint, then, Commercial and Consumer code "C202 - Paints and coatings" should be selected;
• A glue product, then, Commercial and Consumer code "C201 - Adhesives and sealants" should be selected.

If a mixture, product or manufactured item has more than one application, you should report the applicable code that best describes each application.

Note that for this Notice, certain Consumer and Commercial Codes that capture multiple types of applications have been subdivided. For example, code C202 "Paints and Coatings" has been divided into C202.01 "Paints and Coatings" and C202.02 "Paint thinners and removers" since exposure to the substance in these applications differs.

As with U999, C999 can be used when there is no other code to match the application or function of the substance.

In addition, you will be required to provide a written description for C105 (Cleaning and furnishing care) and C108 (Personal care and cosmetics). These applications are of great interest and the additional detail provides important information to support prioritization of future activities. When selecting C105, C108 and C999, a concise written description of the consumer and commercial (including industrial) application of the substance, or of the mixture, product, or manufactured item containing the substance, must be provided.

A description is not required for any other code; however you are strongly encouraged to provide a written description when possible. You may provide your description in the "Notes" field of the online reporting form.

The Consumer and Commercial Codes are listed in Appendix B with their descriptions and some examples.

4.3.1 Additional Information Related to Consumer and Commercial Codes

When providing information on Consumer and Commercial Codes, two additional factors should be considered.

The Notice explains that Consumer and Commercial Codes are intended to describe the "known or anticipated final goods containing the substance". "Known or anticipated final goods" refers to the goods containing the substance that is offered for sale. Final goods can be a substance alone, or a mixture, a product or a manufactured item.

Not everyone responding to the Notice will be able to provide information on the final goods containing the substance, therefore, when completing this section of the Notice, respond using the most complete and accurate information available to you.

For example, company A imports a pure substance and formulates a lubricant, which is then sold to a company who manufactures household appliances. In this example, the final goods are household appliances. If Company A knows or can anticipate that the lubricant is being used on household appliances, Company A should provide code C205 (Electrical and Electronics) as the appropriate Consumer and Commercial Code for this situation. In the case where Company A does not know or cannot anticipate what the customer will do with the lubricants, C402 (Lubricants and Greases) should be used to reflect the application of the substance.

In another example, if Company A imports the pure substance, sells it as is, and does not have any knowledge of what its customers do with the substance, C999 (Other) should be used, with a written description that the known or anticipated final goods is the substance itself.

When providing information on the intended application of the known or anticipated final goods, you will also need to consider if the goods are destined for commercial use, consumer use, or use by or for children 14 years of age or younger.

Commercial activity refers to the use of a substance or the use of a mixture, product or manufactured item containing a substance, by a commercial enterprise providing saleable goods or services.

For example:

• Substance is contained in a mixture sold to a company as an automotive cleaning product.
• Substance is contained in a product used by a company when providing their painting services to other persons or companies.

Consumer activity refers to the use of a substance that is directly, or as part of a mixture, a product, or a manufactured item, sold to or made available to consumers for their use in or around a permanent or temporary household or residence, a school, or a recreational area.

For example:

• Substance is contained in an imported manufactured item (e.g., mouthing toys) that is sold or made available to consumers.
• Substance is contained in a product (e.g., sealant) sold or made available to consumers for do-it-yourself home maintenance.
• Substance is contained in food packaging items that are sold or made available to consumers for their personal use.

Intended to be used by or for children also refers to a substance, or mixture, product or manufactured item made available to children 14 years of age or younger.

For example:

• Paint that will be used to make children's toys
• Sporting equipment intended for school aged children
• Reusable beverage containers depicting popular cartoon characters

5. Sections to be completed - Schedule 3 of the Notice

If you determine that you meet the reporting criteria of the Notice, you must respond by completing the sections of Schedule 3 applicable to your activity with each reportable substance.

In the online reporting tool, you will be asked to indicate your involvement with each reportable substance. Based on your responses, the tool will select the sections that apply to you.

5.1 Illustrative Example

The following example has been developed to illustrate how each question should be completed.

For the purpose of this scenario, the reportable substances are:

Substance A is a Part 1 substance. This substance has been imported in an industrial cleaner at a concentration of 5% and in a mixture at a concentration of 20%. The quantity of substance in the imported cleaner and mixture in 2014 and 2015 is 180 kg and 80 kg respectively, making it reportable for 2014.

Substance B is a Part 2 substance. This substance is a contaminant that is produced during the manufacture of paints and coatings. Since the production of a contaminant meets the definition of incidental manufacturing, this substance is manufactured. The quantity manufactured in 2015 is 125 kg, making it reportable for 2015.

Substance C is a Part 3 substance. This substance is imported in vinyl floor tiles at a concentration of 10%. Floor tiles are a reportable manufactured item (as per the list of 10 reportable categories of manufactured items) for Part 3 substances. The quantity of substance in the imported vinyl floor tiles in 2015 is 140 kg, making it reportable for 2015.

Substance D is a Part 4 substance. This substance is imported in digital thermometers for medical use at a concentration of 1%. Digital thermometers for medical use are a reportable manufactured item (therapeutic product) for Part 4 substances. The quantity of substance in the imported thermometer in 2015 is 102 kg, making it reportable for 2015.

5.2 Section 5 - Activity from 2012 to 2015

Section 5 of Schedule 3 applies to all respondents.

Building on lessons learned from past inventory updates and considering approaches used in other jurisdictions, this section requires you to indicate whether you manufactured greater than 100 kg of the substance, or imported greater than 100 kg of the substance whether alone, in a mixture, in a product, or in a manufactured item at a concentration greater than or equal to 0.1% by weight (w/w%), during 2012, 2013, 2014, and 2015, by selecting "yes" or "no".

When completing this section, you will also be confirming, the calendar year (2014 or 2015) for each substance that your company is reporting. If you had activity with the substance in 2014 and 2015, you are required to report only for the 2015 calendar year.

Example:

Based on the scenario above, you have already determined that you met the reporting criteria for Substance A for the 2014 calendar year, and Substances B, C, and D for the 2015 calendar year.

Tip: If concentration information is not available to you, but you know that the quantity threshold is met, you are encouraged to respond to the Notice.

For Substance A, you determined that you imported the same cleaner and mixture in 2012, 2013, 2014 and 2015, and that there was no change to the formulations (i.e. the concentrations remained at 5% and 20% respectively). The quantity of substance imported is 80 kg, 90 kg, 180 kg and 80 kg in 2012, 2013, 2014 and 2015 respectively. Since the reporting criteria are met for 2014, you indicate that you had activity with this substance in 2014. However, since the quantities imported in 2012, 2013 and 2015 are below the reporting threshold of 100 kg, you indicate that you did not have reportable activity with this substance in 2012, 2013 and 2015. The reporting year for Substance A is 2014.

Tip: If you had activities with a reportable substance below threshold, it is still valuable information that you are encouraged to report to the Program. You can either include it with your s.71 notice submission and indicate that your activity was below threshold or submit the information via a Declaration of Stakeholder Interest.

For Substance B, you determined that you incidentally manufactured the same contaminant in quantities of 200 kg, 300 kg, 90 kg and 125 kg in 2012, 2013, 2014 and 2015 respectively.  Since the reporting criteria are met for 2012, 2013 and 2015, you indicate that you had activity with this substance in these years. However, since the quantity manufactured in 2014 is below the reporting threshold of 100 kg, you indicate that you did not have activity with this substance in 2014. The reporting year for Substance B is 2015.

For Substance C, you determined that you imported the same vinyl floor tiles in 2012, 2013, 2014 and 2015 with no change to the formulation (i.e. concentration remains at 10%). The quantity of substance imported is 80 kg, 110 kg, 130 kg and 140 kg in 2012, 2013, 2014 and 2015 respectively. Since the reporting criteria are met for 2013, 2014 and 2015, you indicate that you had activity with this substance in these years. However, since the quantity imported in 2012 is below the reporting threshold of 100 kg, you indicate that you did not have activity with this substance in 2012. The reporting year for Substance C is 2015.

For substance D, you determined that you imported the same medical thermometers in 2012, 2013, 2014 and 2015 with no change to the formulation (i.e. concentration remains at 1%). The quantity of substance imported is 105 kg, 110 kg, 75 kg and 102 kg in 2012, 2013, 2014 and 2015 respectively. Since the reporting criteria are met for 2012, 2013 and 2015, you indicate that you had activity with this substance in these years. However, since the quantity imported in 2014 is below the reporting threshold of 100 kg, you indicate that you did not have activity with this substance in 2014. The reporting year for Substance D is 2015.

It is important to note that for Substance C, although you met the reporting criteria for both 2014 and 2015, you will not be required to provide any additional information in the subsequent questions for the 2014 calendar year.. However, you may choose to provide 2014 information on a voluntary basis via the Declaration of Stakeholder Interest.

5.3 Section 6 - Facilities

Section 6 of Schedule 3 requires information on facilities where a Part 1, Part 2 or Part 3 substance is manufactured, or to which a Part 1, Part 2 or Part 3 substance is imported, whether alone, or at a concentration equal to or above 0.1% by weight (w/w%) in a mixture or a product.

Tip: This section does notapply to:

• Part 1, Part 2 or Part 3 substances that are imported in manufactured items
• Part 4 substances

You are required to provide the CAS RN, the name and the address of each facility where you manufactured or to which you imported the substance during the reporting year and any applicable six-digit North American Industry Classification System (NAICS) code. You should report the code(s) that best describes the activities taking place at each facility. The code(s) will provide general information on the number and types of sectors involved with the substances listed in the Notice. The NAICS 2017 list of codes is available on the Statistics Canada web site.

You are not required to provide the name and address of facilities where the only activities that occurred with the reportable substances during your reporting year were distribution and warehousing. Note that this section applies to your facilities, not any customer facilities.

Tip: The online reporting tool will allow you to generate your own list of facilities that you will be able to use for reporting on other substances, if applicable.

Example:

Your company owns two facilities in Canada: a warehouse located in Halifax, Nova Scotia, and a manufacturing plant located in Mississauga, Ontario.

Substance A is imported to the Mississauga plant and is used on-site to clean surfaces. Substance A is also used to make paints and coatings. Substance B is manufactured at this plant since it is incidentally produced during the making of the paints and coatings. Since you manufactured Substance B at this plant and your activity with Substance A goes beyond distribution and warehousing, you are required to provide the information for this facility. The NAICS code that applies to the manufacture of paints and coatings is 325510 (Paint and coating manufacturing).

Substances C and D are imported to the Halifax warehouse where they are later distributed to customers in Canada. Substance C and D are imported in manufactured items, which are not reportable in this section. Furthermore since your activity with these substances is solely warehousing and distribution, you are not required to provide any information on this warehouse.

5.4 Section 7 - Total Quantity

Section 7 of Schedule 3 applies to all reportable substances, whether manufactured or imported alone, or at a concentration equal to or above 0.1% by weight (w/w %) in a mixture or in a product.

Tip: This section does not apply to substances that are imported in manufactured items.

For each reportable substance, you are required to provide the total quantity of the substance that you manufactured, imported and exported in kilograms (rounded to two significant digits).

Tip: Export alone is not an activity that triggers reporting to the Notice. Reporters who also export a reportable substance are required to provide the quantity of substance exported, regardless of the quantity of substance exported.

Example:

In 2014, your company imported 400 kg of an industrial surface cleaner containing Substance A at a concentration of 5% (equal to 20 kg of Substance A). You also imported 800 kg of a mixture containing Substance A at a concentration of 20% (equal to 160 kg of Substance A). The total quantity of Substance A imported in 2014 is 180 kg.

In 2015, your company incidentally manufactured 125 kg of Substance B during the manufacturing of a specialty coating. The total quantity of Substance B manufactured is 125 kg. The contaminant remains in the coating, which is primarily sold to customers in Canada, but some coating containing 15 kg of Substance B was sold to customers outside of Canada. The total quantity of Substance B exported is 15 kg.

Substances C and D do not have to be reported here, as both substances were imported in manufactured items.

5.5 Section 8 - Uses and applications of the substance alone, in mixtures or products

Section 8 of Schedule 3 applies to all reportable substances, whether manufactured or imported alone, or at a concentration equal to or above 0.1% by weight (w/w%) in a mixture or in a product.

Tip: This section does not apply to substances that are imported in manufactured items.

For each reportable substance, you are required to provide all applicable Substance Function Codes. For each Substance Function Code, you will need to provide, all applicable Consumer and Commercial Code(s) that describe the known or anticipated final goods containing the substance.

Finally, for each Consumer and Commercial Code, you have to provide the quantity of the substance that was manufactured or imported, reported in kilograms (rounded to two significant digits) and indicate whether any known or anticipated final goods containing the substance is intended for use in commercial activities, in consumer activities, and for use by or for children 14 years of age or younger.

Tip: The online tool will allow you to easily search both sets of codes to help you pick the most appropriate code.

Example:

In 2014, your company imported 180 kg of Substance A, of which 20 kg was in an industrial surface cleaner that you used on site, and 160 kg was in an ingredient mixture that you used to manufacture interior latex paint. The function of Substance A is "solvent which becomes part of a formulation" (U030) in both cases. The applicable Consumer and Commercial Codes for the known or anticipated final goods is C105 (Cleaning and furnishing care) for the cleaner, and C202.01 (Paints and Coatings) for the ingredient mixture. Since C105 is a category for which a written description is required, you will indicate that the known final goods is an industrial surface cleaner.

The industrial surface cleaner is marketed for industrial and commercial use only and not intended for consumer use or children use. The paint is intended for commercial and consumer use, but not for use by or for children 14 years of age or younger.

In 2015, you manufactured 125 kg of Substance B as a contaminant (U064) during the manufacturing of a specialty coating (C202.01). The coating is intended for commercial use only.

Substances C and D do not have to be reported here, as they are imported in manufactured items.

5.6 Section 9 - Canadian Customers

Section 9 of Schedule 3 only applies to a reportable substance in Part 2, whether manufactured or imported alone, or at a concentration equal to or above 0.1% by weight (w/w %) in a mixture or in a product.

Tip: This section does not apply to:

• Part 1, Part 3 or Part 4 substances
• Part 2 substances when imported in manufactured items
• Substances in mixtures or products intended for use by consumers for non-commercial purposes.

For each reportable substance, you are required to provide the name, city and province of the 10 Canadian customers to whom you sold the largest quantity of substance above 100 kg as well as the total quantity of substance you sold to each customer, reported in kilograms (rounded to two significant digits).

It is not expected that stakeholders who sell mixtures or products directly to consumers for non-commercial purposes would provide a response in this section. For example, retailers who sell mixtures and products directly to consumers for personal use are not expected to provide information on the retail customers to whom they sold the goods.

Example:

In 2015, your company manufactured a commercial coating, containing 125 kg of Substance B to supplement stock remaining from 2014. Substance B is reportable since it is not contained in a consumer product. In 2015, you sold 145 kg to 3 customers:

• Customer 1 is a Canadian customer who purchased 102 kg
• Customer 2 is a Canadian customer who purchased 28 kg
• Customer 3 is an international customer who purchased 15 kg

Since Customer 1 is Canadian, and purchased more than 100 kg, you report the name and address of Customer 1 in Canada (Kemi Inc. in Big Town, Ontario), as well as the quantity of Substance B you sold to the customer (102 kg).

Since Customer 2 purchased less than 100 kg, and Customer 3 is located outside of the country, you are not required to provide any information for these two customers.

Substances A, C and D do not have to be reported here, as they are not Part 2 substances.

5.7 Section 10 - Uses and Applications of the Substance in Manufactured Items

Section 10 of Schedule 3 applies to all reportable substances in Part 3 or 4 when imported in a reportable manufactured item at a concentration equal to or above 0.1% by weight (w/w%).

Tip: This section does not apply to:

• Part 1 or Part 2 substances; or
• Part 3 or Part 4 substances when manufactured or imported alone, in mixtures or in products.

For Part 3 substances, you are required to identify each manufactured item category that applies to the reportable substance.

For Part 4 substances, you are required to indicate if the manufactured item is considered a cosmetic, food, therapeutic product or natural health product subject to the Food and Drugs Act.

For each substance, you are required to provide the applicable Consumer and Commercial Code(s) that describe the manufactured item containing the substance.

Tip: The Substance Function Codes do not have to be reported in this section.

For each Consumer and Commercial Code, you then have to indicate whether the manufactured item containing the substance is intended for use in commercial activities, in consumer activities, and for use by or for children 14 years of age or younger.

If a substance has more than one application, you should report all the applicable codes. Note that for codes C105 (Cleaning and furnishing care), C108 (Personal care and cosmetics) and C999 (Other), a description of the manufactured item containing the substance is required. A written description needs to be clear and concise. While a description is not required for any other code, you are strongly encouraged to provide one where applicable to increase the precision of information being submitted.

Example:

In 2015, your company imported Substance C in vinyl floor tiles that were distributed to various home renovation stores. These floor tiles are reportable manufactured items therefore you will identify the manufactured item category as "carpet, vinyl or laminate flooring, or foam underlay for flooring, intended to be used in a residence". The Consumer and Commercial Code applicable to the floor tiles is C101 (Floor coverings). The floor tiles are intended for commercial and consumer use, but not for use by or for children 14 years of age or younger.

Your company also imported Substance D (Part 4 of Schedule 1), in medical digital thermometers that were distributed to various retailers. Thermometers are considered manufactured items, and in this case they are therapeutic products as defined in the Food and Drugs Act. The Consumer and Commercial Code applicable to the thermometers is C565 (Medical devices). The thermometers are intended for consumer use and use for children 14 years of age or younger.

6. Request for confidentiality

Pursuant to section 313 of the Act, any person who provides information in response to the Notice may submit, a written request that it be treated as confidential.

If you provide information in response to the Notice, and request that the information be treated as confidential, you will be asked for the reason for requesting confidentiality based on the following criteria:

1. the information is a trade secret;
2. it is information of a financial, commercial, scientific or technical nature that you treat consistently in a confidential manner;
3. disclosure of the information could reasonably be expected to result in material financial loss or gain, or could reasonably be expected to prejudice your competitive position; or
4. disclosure of the information could reasonably be expected to interfere with contractual or other negotiations you are conducting.

You should make a request for confidentiality only for information that is truly confidential.

For more information on the treatment of Confidential Business Information, please contact us.

7. Blind Submissions

To determine whether you meet the reporting criteria of the notice, and in order to fill out your response, you may request information from a supplier of imported mixtures, products or manufactured items. The supplier may be reluctant to provide it to you if it is Confidential Business Information. In such a case, you and your supplier can agree to both participate in a joint response, where each party submits part of the information directly to the Substances Management Coordinator, allowing you to meet your reporting obligation, while protecting the supplier's trade secrets. Blind submissions can also be initiated by a supplier who knows/suspects that a customer should report, based on quantities purchased. In any case, a cover letter or note should be provided with each part of the blind submission indicating that the supplier's submission completes the customer's submission. Both parties must agree to this approach.

Example:

During 2014, you imported Product 123 into Canada from a foreign supplier. You follow up with your supplier to obtain information on the composition of Product 123 (CAS RN and concentration of the substance in the product). Your supplier confirms that Product 123 contains a reportable substance and that based on the total quantity of Product 123 you purchased in 2014, you would meet the reporting criteria outlined in Schedule 2 to the Notice for the substance. However, your supplier is reluctant to share the composition of Product 123 since their formulation is confidential.

You can submit a "Blind Submission" jointly with your supplier, in which:

• Based on information in your possession, you respond to the Notice providing as much information as you can (e.g., the quantity of Product 123 imported in 2014, Consumer and Commercial Codes, intended use).). Along with your submission, you should provide a cover letter to clearly explain the situation and identify your foreign supplier.
• Your supplier provides the confidential information required to complete your submission directly to the Substances Management Coordinator (e.g., CAS RN, concentration of the substance in the product and applicable Substance Function Code). Along with their submission, your supplier should provide a cover letter to clearly indicate that their information is confidential and that it completes your submission.

The Substances Management Coordinator makes the necessary connection between the two submissions, while keeping all information confidential.

8. Declaration of Stakeholder Interest

Persons not subject to the Notice, but who have a past, current or future interest in a reportable substance, are encouraged to identify themselves as a "stakeholder" for the substance by completing the voluntary Declaration of Stakeholder Interest using the online reporting system via Environment and Climate Change Canada's Single Window.

Interested stakeholders may be contacted for further information regarding their interest in a reportable substance. When completing the declaration, you should specify your activity or potential activity with the substance(s) (e.g., import, manufacture, or use).

9. Declaration of Non-Engagement

Persons who have no involvement with any of the reportable substances and have no commercial interest in these substances may submit a Declaration of Non-Engagement for the Notice using the online reporting system via Environment and Climate Change Canada's Single Window.

Tip: Via the online reporting tool, if you reported information as part of the section 71 Notice, you can also submit information via a Declaration of Stakeholder Interest for any other reportable substances. On the other hand, submitting a Declaration of non-engagement indicates you have no involvement with any reportable substance and therefore the option to submit under the section 71 Notice will not be available.

10. Submission of Voluntary Information

Interested stakeholders are encouraged to voluntarily submit additional information that is deemed beneficial on a reportable substance, through a Declaration of Stakeholder Interest using the online reporting system via Environment and Climate Change Canada's Single Window.

For example, if you did not have activity with a reportable substance in 2014 or 2015, but had activity in alternate calendar years, you are encouraged to provide information deemed beneficial for the alternate calendar years voluntarily by completing a Declaration of Stakeholder Interest.

Voluntary data supplementing a response to the Notice can be submitted online in any "Notes" fields of the Section 71 reporting form within the Environment and Climate Change Canada's Single Window reporting system. The online reporting tool also allows you to upload documents.

When providing voluntary information, please clearly indicate if any of the information is confidential and provide the calendar year for which it applies.

Additional information can be helpful in further supporting prioritization and decision-making related to these substances.

11. Reporting Deadline

Responses to the Notice must be provided no later than July 17, 2017, 3 p.m., Eastern Daylight Saving Time, and must be completed using the online reporting system available through Environment and Climate Change Canada's Single Window. The online form must be "Submitted" to transmit the data.

12. Online Reporting Tool

Environment and Climate Change Canada's Single Window is an online data reporting system. Those reporting to the CMP can use the system to provide responses to Section 70 and New Substances notifications as well as calls for voluntary data. Foreign suppliers and authorized third parties can also use the system to provide data. Refer to the Single Window guidance document for details on how to create and manage an account.

If you meet the reporting criteria of the notice, you must provide your response online, using the online reporting system. Once you have created an account, you will be logged into the Single Window Information Management system (SWIM) as a new user. You will then proceed to set up your profile. After that you must link your profile to your organization.

Tip: if the organization does not exist in the system, you will need to create it.

The following organization information is mandatory:

• Organization legal name.
• Canadian physical and mailing addresses.
• Canadian Federal Business Number (assigned by Canada Revenue Agency (CRA)).
• Facilities in Canada owned by the organization (name and full physical address).
• Names of employees who will be assigned roles (Roles determine how the user can interact with the data entered in SWIM and access rights).
• Organization Lead (note: If you create a new organization, then you are automatically assigned the role of SWIM Organization Lead for that organization).

Once you set up your SWIM profile and organization, return to the home page of SWIM. Click on the Chemicals Management Plan (CMP) link. On the CMP Reporting Dashboard page, you will be able to select the initiative (section 70, section 71 Notices, new substances, voluntary initiatives) that you want to complete.

Refer to the "CMP Online Reporting - How-To Guide" for additional guidance.

13. What if I need more time to comply with the Notice?

Requests for additional time to comply with the Notice must be submitted in writing. The request should include:

1. the company name,
2. contact information and;
3. the reason for the request.

It is important to note that you must request an extension of time in writing before July 17, 2017, 3 p.m., Eastern Daylight Saving Time. No extensions will be granted after the deadline has expired. It is recommended that any request for an extension be submitted at least five (5) business days before the deadline to respond, so that a request can be processed by the Minister of the Environment before expiry of the deadline.

Requests for an extension of time should be sent to the Minister of the Environment, to the attention of the Substances Management Coordinator.

14. Questions?

Inquiries concerning the Notice may be directed to the Substances Management Information Line.

Indicate in the subject line "2017 IU Inquiry".

15. Appendices

Appendix A: Substance Function Codes and Corresponding Descriptions

Appendix B: Consumer and Commercial Codes and Corresponding Descriptions

Date modified:

2017-06-19