Bisphenol A (BPA) structural analogues and functional alternatives
Regulatory action for bisphenol A (BPA), as well as consumer and market shifts toward "BPA-free" products, have led to a rise in the use of BPA alternatives. Understanding the potential risk to the environment and human health from a substance used as a substitute for BPA is important to ensure the continued protection of Canadians and the environment.
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2021 Mandatory survey - section 71 notice
In November 2021, a notice with respect to bisphenol A (BPA) and BPA structural analogues and functional alternatives (BPA SAFAs) was issued in the Canada Gazette, Part I: Vol. 155, No. 46 – November 13, 2021 under section 71 of the Canadian Environmental Protection Act, 1999 (CEPA 1999). The notice applies to 188 inanimate (chemical) substances.
The purpose of the notice is to collect information on the commercial status, industrial processes (for example, facility releases) and downstream use of BPA and BPA SAFAs in Canada from manufacturers, importers and those who use these substances to produce goods. The data collected will inform further prioritization decisions, risk assessment activities and risk management, if needed.
The notice applies to those who, during the 2019 calendar year, met any of the following criteria:
- manufactured more than 10 kg of a substance;
- imported more than 10 kg total of a substance whether the substance was:
- at a concentration equal to or above 0.02% by weight (w/w%) in a mixture or in a product; or
- at a concentration equal to or above 0.02% by weight (w/w%) in a reportable manufactured item
- used more than 10 kg of a substance, whether the substance was used alone or at a concentration equal to or above 0.02% by weight (w/w%) in a good, to produce a good
For the complete list of reportable substances, refer to the notice. You may also refer to the Excel Reporting File for an Excel version of the substance list (available under the "Substances and Code Lists" tab).
To help determine if you are subject to the notice, for detailed explanations of data requirements for each section of the notice, and for instructions on how to submit a mandatory Section 71 response via Single Window, refer to the Guidance manual for completing the notice with respect to bisphenol A (BPA) and BPA structural analogues and functional alternatives.
Persons who do not meet the reporting requirements of this notice, but who have an interest in reportable substances included in this notice are encouraged to identify themselves as a stakeholder by submitting a Declaration of Stakeholder Interest (SHI) via Single Window. For detailed instructions on how to submit a SHI, refer to the Guidance manual for completing the notice with respect to bisphenol A (BPA) and BPA structural analogues and functional alternatives. A SHI also allows persons to submit information on these substances that would be beneficial to inform prioritization. Persons submitting such information may be contacted in the future.
Persons who do not meet the requirements to respond to this notice and have no commercial interest in the substances listed in this notice may submit a Declaration of Non-Engagement. A Declaration of Non-Engagement can be submitted by contacting the Substances Management Information Line by email and indicating "BPA SAFA DNE" in the subject line.
Please note that under subsection 71(4) of CEPA 1999, extensions may be granted in some cases. To apply for an extension, a written request must be submitted to the Minister of the Environment, to the attention of the Substances Management Information Line, prior to the deadline for this notice. The request should indicate "BPA SAFA Extension" in the subject line and include the legal name of the party requiring an extension, as well as the reason for the extension request.
For general inquiries, please contact us. If using email, please indicate "BPA SAFA Notice Inquiry" in the subject line.
As a result of the 2017-2018 Identification of Risk Assessment Priorities (IRAP) review, and through similar work being conducted in other jurisdictions, certain bisphenols and related substances (343 BPA SAFAs, in addition to BPA) were identified for further consideration in a problem formulation process in the context of prioritization. As a first step in this further scoping, the Government of Canada published a document entitled the Technical Consultation: Proposed Subgrouping of Bisphenol A (BPA) Structural Analogues and Functional Alternatives on December 18, 2020 for a public comment period, that ended on February 17, 2021.
The intent of this consultation was to obtain input on the group of BPA SAFAs that were identified after applying the approach described in the document.
Comments received on this document will inform the subsequent problem formulation process, as well as any potential future activities for these substances.
|November 13, 2021||Publication in the Canada Gazette, Part I, of a notice with respect to bisphenol A (BPA) and BPA structural analogues and functional alternatives under section 71 of CEPA 1999.|
|December 18, 2020||Publication and start of a public comment period on the Technical Consultation: Proposed Subgrouping of Bisphenol A (BPA) Structural Analogues and Functional Alternatives.|
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