Canada’s 2026 Chemicals Management Plan: Who Must Report, By When, and Why It Matters for Automotive Suppliers

What is the CMP 2026 notice?

The “2026 Phase 1” and “2026 Phase 2” notices are the latest round of Canada’s Chemicals Management Plan (CMP), an information-gathering program that has run since 2006 to assess and manage substances that may pose a risk to human health or the environment.

They were issued under paragraph 71(1)(b) of the Canadian Environmental Protection Act, 1999 (CEPA), which lets the Minister compel this kind of information from industry to help determine whether a substance is “toxic” under the Act, or how it should be managed if it is. Nathalie Morin, Director General of the Science Policy, Planning and Assessment Directorate, issued both notices on behalf of the Minister.

Key definitions that decide who is in scope

Section 1 of each notice defines the terms that determine what counts as reportable:

Who is required to report under the 2026 CMP notices?

You must respond if, during 2025, you did any of the following with a substance listed in Part 1, 2, 3, or 4 of Schedule 1:

• Manufactured more than 100 kg of a Part 1 or Part 4 substance, or more than 1,000 kg of a Part 2 substance.
• Imported more than 100 kg of a Part 1 or Part 4 substance (1,000 kg for Part 2) — alone, at 0.1% w/w or more in a mixture or product, or at 0.1% w/w or more in a manufactured item falling into a listed product category (see below).
• Imported more than 100 kg of a Part 3 substance, tied to that substance’s specific listed application.
• Used more than 100 kg of a Part 1 or Part 4 substance (1,000 kg for Part 2) to manufacture a mixture, product, or manufactured item.
• Used more than 100 kg of a Part 3 substance to manufacture goods tied to its listed application.
• Used more than 100 kg of a Part 4 substance in non-manufacturing activities.
• Are a successor or assign of a company that met any of the above in 2025 — a reorganization or asset sale does not remove the obligation.

One response covers all of a company’s facilities — there’s no need to file separately per site. Importantly, the obligation isn’t limited to whoever first makes or imports a substance; it also reaches anyone who uses it above threshold to manufacture something else.

Manufactured-item product categories that trigger reporting (0.1% w/w threshold)

The four parts of Schedule 1: Phase 1 vs. Phase 2

Schedule 1 is not the same list in both notices. Phase 1 and Phase 2 each have their own Part 1 through Part 4, with different substances and different counts — though the threshold and reporting logic for each Part stays consistent across both notices.

Standard exclusions apply to both notices: substances only in transit through Canada, or contained in regulated hazardous waste, a registered pest control product, fertilizer, feed, or treated seed.

What information must be reported?

• Company information: name, address, business number, an authorized contact, and a signed declaration of accuracy.
• Substance quantities: manufactured; imported (alone, in a mixture/product, or in a manufactured item); used in manufacturing (with an ECCC substance-function code, plus a written description if the catch-all code U999 applies); exported (Part 2 substances only).
• Facility-level data: for any facility (other than distribution or warehousing) where more than 100 kg of a qualifying substance was released or may have been released — the facility’s identity and NAICS code, per-substance quantities, and whether air, water, or land releases are monitored.
• Goods sold: application code, substance function code, concentration and quantity by substance/application-code combination, export quantities, and whether the goods are for commercial use, consumer use, or use by children 14 and under — extending, where known, to downstream goods the substance is later incorporated into.
• Unpublished studies: titles of any unpublished data or studies on a qualifying substance not already shared with the government under the New Substances Notification Regulations or section 70 of CEPA.

Reporting timeline and deadlines

The two notices are staggered so the reporting workload doesn’t land all at once. Both report on the 2025 calendar year regardless of filing date, and both are submitted through ECCC’s online Single Window system.

Extensions, confidentiality, and penalties for non-compliance

• Extensions: send a written request to substances@ec.gc.ca before the deadline, naming the legal entity, the relevant substance identifiers, and the reason.
• Confidentiality: a request under subsection 313(1) of CEPA can be submitted alongside the information itself, with reasons required under subsection 313(2). ECCC and Health Canada’s joint published approach describes how such claims are handled.
• Penalties: fines range from a maximum of $25,000 for an individual convicted on summary proceedings up to $500,000 for a large corporation convicted on indictment — doubling for repeat offences. Offences include failing to respond and providing false or misleading information.
• Not in scope? Companies outside the reporting criteria can still file a Declaration of Stakeholder Interest or a Declaration of Non-Engagement to formally record their position.

Why automotive fuel-system and aftermarket-parts suppliers should pay close attention

Most of the 200 substances across both notices are fragrance ingredients, dyes, and general industrial solvents with no connection to vehicle manufacturing. But a smaller group is used in — or is chemically identical to compounds used in — fuel systems, brake systems, tires, fasteners, and under-hood or interior components:

None of this means a given company is automatically in scope — that depends entirely on actual 2025 volumes and concentrations. But any supplier working with fuel additives, brake fluid, tire or rubber compounding, hydraulic fluids, fastener finishing, or plastic stabilizer packages should treat this list as a screening checklist against its own bills of materials and safety data sheets.

Compliance checklist: 5 steps to get ready

Frequently asked questions

Source: Canada Gazette, Part 1, Volume 160, Number 35 — Government Notices.