ECCC’s Updated TENF Permit Application: Essential Guide for Disinfectant Manufacturers
By: Jacqui Jenskey, DIRECTOR OF REGULATORY AFFAIRS, email
In the rapidly evolving regulatory environment, compliance is crucial for disinfectant manufacturers and importers. Environment and Climate Change Canada (ECCC) has introduced an updated permit application form for Technical or Economic Non-Feasibility (TENF) under the Volatile Organic Compound (VOC) Concentration Limits for Certain Products Regulations. This update is critical for businesses aiming to continue manufacturing or importing disinfectant products into Canada beyond January 1, 2025. Here’s what you need to know to stay compliant.
ECCC’s Updated TENF Permit Application: What’s New?
The ECCC’s updated TENF permit application form, now available on the Alternative Compliance Options webpage, is an essential tool for any company dealing with disinfectant products. If your product exceeds the VOC concentration limits set by ECCC, securing a TENF permit is mandatory to continue its manufacture or importation into Canada after January 1, 2025.
Key Regulatory Changes Impacting Disinfectant Products
Starting January 1, 2025, disinfectant products that exceed the VOC concentration limits specified in item 31 of Schedule 1 cannot be legally manufactured or imported into Canada without an approved TENF permit. This change is part of Canada’s broader effort to reduce VOC emissions, which significantly impact air quality and climate change.
The revised TENF permit application form is also crucial for those looking to renew existing permits. Applications for renewal must be submitted at least 90 days before the expiration date of the current permit. The updated form includes additional guidance, making it easier to ensure your submission meets ECCC’s requirements, potentially speeding up the approval process.
Who Needs a TENF Permit for Disinfectant Products?
If your disinfectant product falls under Schedule 1, Item 31 of the regulations and exceeds the VOC limits, you will need to apply for a TENF permit to continue selling in the Canadian market. Consider the following criteria:
- The product is not a moist towelette designed for medical, convalescent, or veterinary use.
- It is not intended for use on heat-sensitive medical devices or equipment.
- The product is not marketed as a glass cleaner, toilet or urinal cleaner, deodorizer, metal polish, or fabric refresher.
- It is not intended for use on food contact surfaces without rinsing.
- The product is not designed solely for humans, animals, agriculture, swimming pools, therapeutic tubs, or hot tubs.
VOC Limits for Disinfectant Products
The maximum VOC concentration limits are as follows:
- Aerosol disinfectants: 70%
- Non-aerosol disinfectants: 1%
Available Compliance Options
Disinfectant manufacturers and importers in Canada now have three alternative compliance options to meet the regulatory requirements for Volatile Organic Compounds (VOCs):
- Permit – Technical and Economic Non-Feasibility: Manufacturers and importers can apply for a permit if it is technically or economically unfeasible to meet the VOC limits. The application must be submitted before January 1, 2025.
Additional alternative compliance options include:
- Permit – Products Resulting in Lower VOC Emissions: If a product leads to lower VOC emissions compared to other available alternatives, a permit can be requested, with the same application deadline of January 1, 2025.
- VOC Compliance Unit Trading System (CUTS) – This system allows companies to generate compliance units by reducing VOC emissions. To participate, companies must submit a notice of intent before October 1 of the year they wish to start earning compliance units. They are required to report the actual quantities (manufactured, imported, and exported) by March 1 of the following year.
These options provide flexibility for disinfectant producers and importers, helping them comply with evolving VOC regulations while maintaining market competitiveness.
FAQ: TENF Permit Application for Disinfectants
What is a TENF permit?
A Technical or Economic Non-Feasibility (TENF) permit allows the manufacture or importation of products that exceed specific VOC concentration limits when it is technically or economically unfeasible to meet those limits.
Why do I need a TENF permit for my disinfectant product?
If your disinfectant product exceeds the VOC concentration limits specified in Schedule 1, Item 31, you must obtain a TENF permit to continue manufacturing or importing it into Canada after January 1, 2025.
How do I apply for a TENF permit?
You can apply for a TENF permit by downloading and completing the updated application form from the Alternative Compliance Options webpage. The revised form includes additional guidance on the required information, so ensure your application is comprehensive.
When should I apply for a TENF permit renewal?
If you already have a TENF permit, apply for its renewal at least 90 days before the expiration of your current permit to ensure continuous compliance.
What happens if I don’t obtain a TENF permit by January 1, 2025?
Without an approved TENF permit, you won’t be able to legally manufacture or import disinfectant products that exceed the VOC concentration limits into Canada after January 1, 2025.
Can you assist with the TENF permit application process?
Absolutely. We specialize in regulatory support for disinfectants and can guide you through the TENF permit application process, ensuring all necessary details are covered for a smooth approval process.
Why Partner with Us for Regulatory Compliance?
Navigating these regulatory changes can be challenging, but our team of experts is here to guide you every step of the way. We specialize in regulatory support for disinfectant products, helping you understand and comply with the updated TENF permit application process and VOC limits.
Ensure Compliance with Our Expertise
Staying compliant with ECCC regulations is crucial for your business. Contact us today to learn how we can assist with your TENF permit application and keep your disinfectant products on the Canadian market.
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