Environment Canada’s Plan of Priorities Summary   

In 2023 CEPA was modernized when Bill S-5 became law. As part of this modernization, the Minister must develop and publish to Stakeholders a Plan of Priorities. This plan will also be reviewed and updated every 8 years as part of the Bill S-5 requirement.  

It is important to keep in mind that this is a PROPOSED Plan and Environment and Climate Change Canada (ECCC) is looking for feedback from stakeholders. Please also note that each of the items identified in the plan will go through assessment and comment periods of their own before any regulatory changes are made that could impact their use in Canada.  

The first part of the Plan of Priorities is the substances prioritized for assessment. This list includes individual substances and groups of certain substances. See the list below. The assessment periods and timelines will be updated periodically. This link contains the Workplan that has been posted, it is a list of substances and when to expect the assessment period on them.  

The second part is the list of prioritized activities or initiatives that support the assessment, control or other management of risks to the environment or to human health posed by substances. These activities include risk management activities and research activities. Please note there are other topics aside from the ones listed below. If you would like to review the whole Plan of Priorities, please follow this link.   

1. Risk management activities: The activities include managing certain substances that have been found to be toxic under CEPA or providing permits to allow the use of toxic substances for restricted activity or when there are no feasible alternatives. Another big activity that could impact industry is the investigation into labelling of certain substances in products. There was a Notice of Intent (NOI) posted in 2022 regarding this proposal. This NOI states that labelling would be similar to other established regulations such as the Volatile Organic Compound Concentration Limits for Certain Products Regulations, or the Products Containing Mercury Regulations. These Regulations outline the requirement for date codes or a contains statement such as “Contains mercury”. This is still in the proposal phase and has not yet been finalized. There will be further consultation periods regarding this proposal on mandatory labelling.  
2. Research and surveillance activities: with hot topics such as animal testing, persistence, bioavailability and bioaccumulation being discussed around the world, ECCC is looking at ways to gather information about substances and develop new techniques to identify substances and determine toxicity without the use of animals. Through research, new methods may become available that would allow for the identification of substances that otherwise would have been difficult to identify and study. This will help us understand the persistence, bioavailability, bioaccumulation and toxicity and how certain substances act in the environment and the cumulative impact these substances have on human health.  
3. Information gathering: ECCC has 2 mandatory information gathering Section under CEPA, Section 46 and 71. For example, currently there is a Section 71 notice that is focused on PFAS uses in Canada. In addition to these mandatory initiatives there are other opportunities throughout the year where Environment Canada may open a consultation period regarding a specific substance or a group of chemicals. Here is a link to a website where ECCC will post updates on their plans for information gathering. The next upcoming information gathering session will be in December 2025 and will be focused on certain substances that are under the Chemicals Management Plan (CMP).  

The above is a high-level summary of the initiatives ECCC is looking to direct their attention to over the coming years. We would recommend reviewing the Plan of Priorities for an in-depth look at all the initiatives that ECCC is proposing. ECCC has advised that any changes to the Plan will be communicated through the various web pages that have been linked throughout this summary. If you would like the provide feedback to ECCC on their Proposed Plan of Priorities, please use the following contact information: 

Email Contact: substances@ec.gc.ca 

Include the following in the email subject line: “Comments on the Proposed Plan of Priorities” 

Or by mail: 

Plan of Priorities Team, Chemicals Management Division 
Environment and Climate Change Canada 
Place Vincent Massey, 351 St. Joseph Blvd 
Gatineau, QC K1A 0H3 

The final Plan of Priorities is expected to be published by June 13, 2025.  

Helpful Resources: 

1. Proposed Plan of Priorities: https://www.canada.ca/en/environment-climate-change/services/canadian-environmental-protection-act-registry/implementing-modernized-cepa/plan-of-priorities-landing-page.html 
2. Canada Gazette on Labelling of Toxic Substances: https://canadagazette.gc.ca/rp-pr/p1/2022/2022-10-29/html/notice-avis-eng.html#ne3 

Proposed Plan of Priorities Workplan: https://www.canada.ca/en/environment-climate-change/services/canadian-environmental-protection-act-registry/implementing-modernized-cepa/plan-of-priorities-landing-page/priority-substances.html 

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