Triclosan: pollution prevention notice performance report

Pollution prevention (P2) planning is a process by which organizations can improve their environmental performance by strategically planning to reduce or eliminate pollution before it is created.

A P2 notice is an instrument under the Canadian Environmental Protection Act, 1999 (CEPA) that requires organizations to develop and implement P2 plans to achieve the risk management objective.

Three companies subject to the Notice requiring the preparation and implementation of pollution prevention plans with respect to triclosan in certain products have submitted a Declaration That a Pollution Prevention Plan Has Been Prepared and Is Being Implemented (refer to Schedule 1 of the notice) and a Declaration That a Pollution Prevention Plan Has Been Implemented (refer to Schedule 5 of the notice). This report summarizes the information obtained from 2021 to 2023 in the declarations submitted by these companies under the notice. 

Summary

The notice is still in effect. There are three known companies subject to the notice. The three companies submitted their final declaration (Schedule 5 of the Notice) summarizing the outcomes of their implemented P2 plan by the deadline of November 9, 2023. These companies have met the target by reducing the total mass of triclosan by at least 30% in the manufacture or import of their products subject to the notice. Two of the three companies have completely discontinued the manufacture and import of triclosan in their products subject to the Notice.

Background and introduction

Triclosan [phenol, 5-chloro-2-(2,4-dichlorophenoxy)] (CAS RN 3380-34-5) is an antimicrobial agent used as a preservative to stop the growth of bacteria, fungi and mildew. Triclosan can be found in cosmetics, drugs, and natural health products. Examples include bodywash, hand soap, toothpaste, and hand sanitizer.

In the Final Assessment Report for Triclosan, published in November 2016, in was concluded that triclosan meets the criteria under paragraph 64(a) of CEPA as it is entering or may enter the environment in a quantity or concentration or under conditions that have or may have an immediate or long-term harmful effect on the environment or its biological diversity.

On October 10, 2020, Environment and Climate Change Canada (ECCC) published the Notice requiring the preparation and implementation of pollution prevention plans with respect to triclosan in certain products in the Canada Gazette Part I.

The environmental objective for triclosan is to reduce concentrations of triclosan in the aquatic environment to levels below the predicted no-effect concentration (PNEC) of 376 ng/L. The risk management objective is to reduce the quantity of triclosan released to the aquatic environment as a result of the use by consumers of triclosan-containing products imported into or formulated in Canada.

Triclosan P2 notice requirements

The Notice requiring the preparation and implementation of pollution prevention plans with respect to triclosan in certain products applies to any person or class of persons who, on the date of publication of the Notice or anytime thereafter, either:

• uses 100 kg or more of triclosan in a calendar year in the manufacture of cosmetics, natural health products or drugs
• imports 100 kg or more of triclosan in a calendar year contained in cosmetics, natural health products or drugs

Deadlines for the reports are dependent on the calendar year during which the company became subject to the notice. Companies subject to the notice in the 2020 calendar year were required to:

• Prepare a pollution prevention plan by October 10, 2021, and submit a Declaration That a Pollution Prevention Plan Has Been Prepared and Is Being Implemented (Schedule 1) by November 9, 2021; and then
• implement the pollution prevention plan by October 10, 2023, and submit a Declaration That a Pollution Prevention Plan Has Been Implemented (Schedule 5) by November 9, 2023

If a company became subject to the notice in the 2021 calendar year or any calendar year thereafter, they must prepare a pollution prevention plan one year from the date they became subject and submit a Schedule 1 report within the next 30 days. The implementation of the pollution prevention plan can span up to 24 months from the date the company became subject and a Schedule 5 report must be submitted within the next 30 days.

In the preparation and implementation of their P2 plan, companies have to consider all the factors set out in the notice (refer to section 4 Factors to consider in preparing a plan in the notice). The notice remains in effect and will continue to apply to any person or class of persons who become subject to the notice.

Refer to the Triclosan P2 notice for all other requirements.

Reduction targets for companies subject to the triclosan P2 notice

Reductions in the total mass of triclosan used or imported in products are calculated by using levels from a base year and an implementation year, which is dependent on the year the person became subject to the notice (see Table 1).

This notice provided flexibility to allow companies that had already made reductions in triclosan use to be recognized for their early action. A person or class of persons who became subject to the notice in the 2020 calendar year had to endeavour to achieve and maintain a minimum reduction of 30% of the total mass of triclosan used or imported in products from the base year level. These companies could select their base year to be any year between 2011 and 2020 and their implementation year was to be either 2021 or 2022.

To provide a disincentive for increasing triclosan use in the future, a person or class of persons who became subject in the 2021 calendar year or any calendar year thereafter, must endeavour to achieve and maintain a minimum reduction of 95% of the total mass of triclosan used or imported in products from the base year level. In this case, the base year is the calendar year when the person becomes subject to the notice and the implementation year is the year following the base year.

Results and actions taken to achieve the objective

As of June 2025, three companies have reported under the notice and 47 companies have informed ECCC that while they had uses or imports of cosmetics, natural health products or drugs containing triclosan in the past, they no longer use triclosan in their products. All three reporting companies were subject in the 2020 calendar year and have submitted their Declaration That a Pollution Prevention Plan Has Been Prepared and Is Being Implemented (Schedule 1) in 2021 and Declaration That a Pollution Prevention Plan Has Been Implemented (Schedule 5) in 2023. All reports were received on time. As the three reporting companies were subject to the notice in 2020, their reduction target is 30% from their base year.

Companies reported either manufacturing drugs containing triclosan or importing drugs containing triclosan (Table 2). Base years selected by the companies varied between 2011 and 2020 and the implementation year was 2022 for all three companies. All reporters achieved the 30% reduction target as reported in their Schedule 5 declarations. Two of the three companies have completely discontinued the manufacture and import of triclosan in their products subject to the notice.

The schedules submitted by the three companies are accessible via the following webpage: Online search - Pollution Prevention Planning Reports

Monitoring of triclosan levels in surface water

Monitoring of triclosan levels in surface (fresh) water was conducted under the Chemical Management Plan’s (CMP) Monitoring and Surveillance (M&S) program. Triclosan levels were measured in surface water in 2022, 2023, and 2024 to determine if levels of triclosan have reduced in the environment in comparison to surface water testing prior to the P2 Notice being published. The sampling data for triclosan in surface water can be accessed at the following webpage: Chemical Management Plan Monitoring Program – Surface Water - ECCC Data Catalogue.

Based on the data obtained by the M&S program, all samples were very close to the method detection limit (depending on the method the lowest detectable limit is either 7.9 ng/L or 10.6 ng/L). The highest measured concentration was 31.8 ng/L, far below the predicted no-effect concentration (PNEC) of 376 ng/L.

During the sampling before the P2 Notice was published, there was one location sampled that had values over double the PNEC value. Upon sampling the location in 2024, the triclosan concentrations at this location were just above the detection limit of 7.9 ng/L.

Conclusion

All three companies subject to the notice achieved and surpassed the reduction target of 30% relative to their base year. The notice achieved an overall 58% reduction in triclosan use from the 3 participating companies, and a further 47 companies withdrew from use of triclosan in advance of the publication of the notice.

Based on the sampling completed under CMP’s Monitoring and Surveillance program in 2022, 2023, and 2024, the environmental objective to reduce concentrations of triclosan in the aquatic environment to levels below the predicted no-effect concentration (PNEC) of 376 ng/L has been achieved.

The notice remains in effect. Should a person or class of persons become subject to the notice in the future, they would be required to prepare and implement a pollution prevention plan and report to ECCC. Further information on triclosan and the P2 Notice can be found on the Triclosan webpage.