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On February 25, 2026, Canada published Canada Gazette, Part II, Volume 160, Number 4: Government Notices, which includes Order 2025-87-20-01 Amending the Domestic Substances List (SOR/2026-15). 1
The Order applies Significant New Activity (SNAc) provisions to cyclohexanamine (CAS No. 108-91-8), also known as cyclohexylamine. As a result, companies must submit a Significant New Activity Notification (SNAN) before undertaking certain new manufacturing or import activities involving this substance in consumer products and cosmetics.
The regulatory amendment entered into force on February 3, 2026.
Key Cosmetic-Related Requirements
The newly applied SNAc provisions target potential significant new activities involving cyclohexanamine that could result in a new or increased exposure to the substance in Canada. For the cosmetic industry, the key regulatory requirements are as follows:
Manufacturing Triggers
A Significant New Activity Notification (SNAN) is required if a company uses cyclohexanamine in the manufacture of a cosmetic containing the substance at a concentration equal to or greater than 0.1% by weight;
Importation Triggers
SNAN is mandatory for the importation of cyclohexanamine in a cosmetic containing the substance at a concentration equal to or greater than 0.1% by weight, provided the total quantity imported in all such products in a calendar year exceeds 10 kg;
Cosmetic Exemptions
SNAN explicitly do not apply to the manufacture or importation of aerosol hairspray products, which are exempt from these specific notification triggers. Additionally, substances used exclusively for research and development, as site-limited intermediates, or in products intended solely for export are exempt.
Notification Timeline and Required Information
Companies proposing a significant new activity must submit the following information to the Minister at least 90 days before the day on which the manufacturing or importation activity begins. The Minister will conduct a risk assessment within 90 days of receiving the complete submission to determine whether the activity can proceed under regulatory safeguards.
| (a) a description of the significant new activity in relation to the substance; (b) the quantity of the substance that is anticipated to be used or imported in a calendar year; (c) the information specified in items 3 to 7 of Schedule 4 to the New Substances Notification Regulations (Chemicals and Polymers); (d) the information specified in paragraphs 2(d) to (f) and 8(f) and (g) of Schedule 5 to those Regulations; (e) a description of the product that contains the substance, the intended use and method of application of that product and the function of the substance in that product; (f) the quantity of the product containing the substance that the person proposing the significant new activity expects to sell in Canada in a calendar year; (g) if known, the three sites in Canada where the greatest quantity of the substance is anticipated to be used or processed and the anticipated quantity by site; (h) all other information or test data in respect of the substance that are in the possession of the person proposing the significant new activity, or to which they may be reasonably expected to have access, and that permit the identification of the adverse effects that the substance may have on the environment and human health and the degree of environmental and public exposure to the substance; (i) the name of every government department or government agency, either outside or within Canada, to which the person proposing the significant new activity has provided information regarding the use of the substance and, if known, the department’s or agency’s file number and, if any, the outcome of the department’s or agency’s assessment and the risk management actions that the department or agency has imposed in relation to the substance; (j) the name, civic and postal addresses, telephone number and, if any, the fax number and email address of the person proposing the significant new activity and, if they are not resident in Canada, of the person resident in Canada who is authorized to act on their behalf; and (k) a certification that the information provided under this section is accurate and complete, dated and signed by the person proposing the significant new activity or, if they are not resident in Canada, by the person resident in Canada who is authorized to act on their behalf. |
Further Reading
Webinar Recommendation
To help global beauty companies seamlessly access the Canadian market, ChemLinked invited three officials from Health Canada to explain Canada's current regulatory framework and offer guidance on both pre- and post-market requirements. The webinar will conclude with a live Q&A session, offering businesses an opportunity to engage with Health Canada regulators and have their questions addressed.
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