Understanding Canada’s Chemicals Management Plan (CMP)

Navigating environmental regulations can feel complex, but staying compliant doesn’t have to be. If your business manufactures, imports, or uses industrial chemicals in Canada, you may have obligations under Environment and Climate Change Canada’s (ECCC) federal information-gathering initiatives.

Here is a straightforward guide to understanding the Section 71 Chemicals Management Plan (CMP) Notices and what they mean for your business.

What is the CMP Section 71 Notice?

The Chemicals Management Plan is a joint program by ECCC and Health Canada designed to evaluate potential risks from chemical substances and manage them safely.

“On August 29, 2026, The Notice with respect to certain substances under the Chemicals Management Plan – 2026 Phase 1 and the Notice with respect to certain substances under the Chemicals Management Plan – 2026 Phase 2 (the notices) were published in the Canada Gazette, Part I, pursuant to paragraph 71(1)(b) of the Canadian Environmental Protection Act, 1999 (the Act).” (ECCC)

Under Section 71 of the Canadian Environmental Protection Act (CEPA), the government issues mandatory notices to collect commercial status, facility data, and usage information from Canadian companies. The current reporting cycle covers 200 priority substances split across Phase 1 (184 substances) and Phase 2 (16 substances).

Does Your Business Need to Report?

Simply having a chemical present in your facility does not automatically trigger a reporting obligation. Whether you are required to submit information depends on a clear screening process:

• Substance Match: Does your facility handle any of the priority substances listed in the Phase 1 or Phase 2 notices?
• Commercial Activity: Do you manufacture, import (alone, in a mixture, or in a product), or use the substance in Canada?
• Concentration & Volume Thresholds: Does the concentration of the substance and the total mass handled over the calendar year exceed the regulatory limits (such as the standard 100 kg/year threshold for many substances)?

If your operations meet these criteria, you are legally mandated to report. If you do not meet the criteria, reporting is generally not required, though alternative filings like a Declaration of Non-Engagement can be evaluated.

NPRI vs. CMP: What’s the Difference?

Many businesses assume that if they already report to the National Pollutant Release Inventory (NPRI), their obligations are covered. However, NPRI and the CMP Section 71 Notices track entirely different things:

• NPRI Focuses on Environmental Release (MPO): NPRI looks at what your facility Manufactures, Processes, or Otherwise Uses to track environmental impact, mass balances, and pollution releases into environment.
• CMP Focuses on Commercial Logistics (MIU): ECCC’s Section 71 Notice tracks strict commercial activity—specifically what you Manufacture, Import, or Use to understand how a substance enters the Canadian marketplace. This includes tracking whether substances are embedded in products sold for everyday consumer use or downstream commercial applications used in manufacturing other goods.
• The “Parts” Mismatch: The categories or “Parts” in your NPRI report (which group chemicals by toxicity thresholds or volatile organic compounds) have a completely different structure than the commercial activity parts found in the CMP reporting spreadsheet.

Airzone is Here to Help

Determining applicability, screening chemical inventories, and completing federal reporting can take valuable time away from running your core business.

You don’t have to figure it out alone. Airzone is here to help. Our team can review your chemical and product lists, guide you through the screening process, and manage your ECCC reporting accurately and efficiently from start to finish.