Canada - New Substances

Anyone intending to import or manufacture a new substance in Canada must submit a notification to the New Substance Program prior to importing or manufacturing the substance. The New Substance Notification Regulations (NSNR) apply to chemicals, polymers, biochemicals, biopolymers and animate products of biotechnology, such as bacteria, fungi, and genetically modified fish and livestock.

Any substance not listed on the Domestic Substances List (DSL) is considered a new substance. The DSL is a compilation of substances that were added in accordance with the Canadian Environmental Protection Act (CEPA), and it regularly undergoes revisions as new substances qualify for listing through the New Substances assessment process.

TSG has extensive experience with the notification of new chemicals and polymers in Canada under the CEPA regulation. TSG’s staff can determine which notification schedules are needed and whether new polymers meet the CEPA Reduced Regulatory Requirements (RRR), which require minimal notification data.

TSG services include:

▲ Evaluating DSL and NDSL status of a new chemical substance;

▲ Determining which notification schedule is required for the new chemical or new polymer;

▲ Preparing and submitting new substance notifications (NSN);

▲ Acting as a Canadian registration agent for non-Canadian notifiers;

▲ Acting as technical contact for non-Canadian notifiers;

▲ Fulfilling CEPA legal requirement for non-Canadian notifiers to maintain NSN documentation in Canada; and

▲ Preparing and submitting Notice of Manufacture/Import (NOMI) or Notice of Excess Quantity (NOEQ).

For foreign companies importing a new substance into Canada, a Canadian registration agent is required. A registered agent, such as TSG Canada, acts as a registered address of the corporation in Canada. TSG Canada provides this registered address for the receipt of service of government filings – and sometimes legal documents – and acts as a liaison for government agencies. Acting as the registered agent, we forward all documents and correspondence to our clients.