P2 Planning Notice for Triclosan:
The final P2 Planning Notice for Triclosan has been released today by Environment and Climate Change Canada (ECCC). Health Canada and ECCC published a joint scientific assessment of triclosan in November 2016. A proposed Notice was published on November 24, 2018 for a 60-day comment period. The assessment concluded that potential for harm exists from exposure to triclosan in aquatic ecosystems. The notice applies to manufacturers and importers of Cosmetics, Drugs and NHPs who manufacture or import products with Triclosan of 100 kg or more. There are different considerations in the Notice depending on if you have been historically producing products containing Triclosan or if your looking into bringing products containing Triclosan for the first time. The two scenarios are highlighted below:
For companies with historical activity with Triclosan (meet Notice threshold in 2020):
- Targets 30% reduction from use/import volumes from base year (any year prior to 2020 but no earlier than 2011)
– any reductions realized in the past (going back to 2011) can be considered
After the Notice comes into force notifiers have 12 months to prepare a plan and 30 days following the 12 months the notifier must issue a declaration of planning by October/November 2021 within 30 days of the 12-month period. The plan must be in place for 2 years following the declaration (2023).
For companies looking to introduce new product in the market (meet Notice threshold in 2021 and beyond):
- Target 95% reduction
- Have 12 months to prepare a plan
- Same declaration logistics as historical notifiers (please see above)
- Plan must be in place 1 year following declaration
This final notice was supposed to be published March/April but was delayed because of COVID-19.
Please note that there are provisions for a one-time extension if needed, which is rationale based (COVID-19 and economic reasons can be used as a rationale). If you have reduced the use or import of triclosan prior to publication of the notice and are no longer subject, ECCC invites you to submit a Notification of Non-Engagement form to the email address to ec.produits-products.ec@canada.ca.
Draft Screening Assessment of Triclocarban:
Environment and Climate Change Canada will be releasing the Draft Screening Assessment for Triclocarban on Saturday, October 10, 2020. This is an interesting development as we were expecting it to reflect a similar finding to Triclosan especially reflecting the environmental conclusions for Triclosan. It is concluded that Triclocarban does not meet any of the environmental or human health concerns and is concluded to be not CEPA toxic. While exposure of the general population and the environment to triclocarban is not of concern at current levels, the substance is associated with effects of concern. Therefore, there may be concern if exposure were to increase. Follow-up activities to track changes in exposure or commercial use patterns are under consideration. Cosmetics Alliance is aware that this substance is of high interest in the NGO community.
The draft Screening Assessment will be subject to a 60-day public comment period and will be available on the Chemical Substances website.
Please let us know if you have any comments or concerns however we do not anticipate any concerns as this a positive conclusion for Triclocarban.
