Proposed Removal of Substances from the Revised In Commerce List

 In Regulatory Affairs

By: Joe McCarthy, Lab Service Manager/Senior Regulatory Affairs Specialist, email

On September 26, 2020, Health Canada published a Gazette I Notice proposal to remove 669 substances from the Revised In Commerce List (R-ICL) on the basis that the substances were not to be manufactured or imported in Canada, or were used in Food & Drug Act (FDA) Regulated products including Cosmetics at less than 100 kg/yr, or have been discontinued, or have never been marketed, or have been approved for limited use. The comment period on the proposal ends November 25, 2020.

The R-ICL is comprised of substances that were in products that were regulated under the FDA including Cosmetics and that were in Canadian commerce between January 1, 1987, and September 13, 2001.

If the substance is not on the Domestic Substances List (DSL) but is included in the R-ICL and used in a FDA regulated product including Cosmetics, then the substance was exempt from the requirements of the New Substances Notifications Regulations (NSNR).

When these substances are removed from the R-ICL, if you use the substance in a FDA regulated product including Cosmetics at more than 100 kg/yr, then you will need to file New Substance Notifications (NSN) with Environment & Climate Change Canada (ECCC).

Here are some familiar-sounding substances proposed for removal:

  • Acid Blue 104
  • Dipropylene Glycol Methyl Ether
  • Direct Blue 199
  • MDM Hydantoin
  • Caprylamidopropyl Betaine
  • CI 47005/ Acid Yellow 3/Food Yellow 13/Yellow 203
  • Quinoline Yellow
  • EO/PO Block Copolymer

Are your ingredients on the list for removal?

Do you know how to submit comments on the proposal?

Will removal from the R-ICL disrupt your business?

Call Dell Tech to ensure you can keep using these substances in your products.

Dell Tech
Joe McCarthy
Senior Regulatory Affairs Specialist

Dell Tech has provided professional, confidential consulting services to the chemical specialty

industry in Canada, the USA, Europe, and Asia for the last 40 years.

Contact us today for more information.



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