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Canada Proposes to Amend the Manufacture and Importation Requirements of Cosmetics Containing Nitrilotriacetic Acid Trisodium Salt

Canada proposes that, under certain conditions, the manufacture and importation of cosmetics containing Na3NTA are required to submit a SNAN.

Introduction to Domestic Substances List (DSL)

The Domestic Substances List (DSL) is an inventory of substances manufactured in, or imported into Canada on a commercial scale. Substances on the DSL are grouped into 8 parts and may have one or more of the 5 available flags. For example, the S flag indicates that the substance is subject to Significant New Activity (SNAc*) requirements and is applied when the substance was subject to SNAc requirements prior to its addition to the DSL.


  • Part 1: Chemicals and polymers that are identified by their CAS numbers, or their Substance Identity Number assigned by the Department of the Environment and the name of the substance;

  • Part 2: Chemicals and polymers subject to SNAc requirements that are identified by their CAS numbers.

An introduction to other parts of the DSL can be found here.


*The SNAc provisions trigger an obligation for a person to submit a significant new activity notification (SNAN) to the government when proposing to use, import or manufacture the substance for a significant new activity. The government will then assess the substance for potential risks to human health and the environment. If risks are identified, the government may impose management measures.

On Nov. 26, 2022, Canada published the Canada Gazette, Part I, Volume 156, Number 48, including a notice of intent to amend the DSL to apply the SNAc provisions to “nitrilotriacetic acid trisodium salt”. 1 The manufacture and importation requirements for cosmetics containing “nitrilotriacetic acid trisodium salt" were proposed to be amended.

Ingredient Information


Common Name

Name in DSL


Nitrilotriacetic acid trisodium salt (hereafter referred to as “Na3NTA”)

Glycine, N,N-bis(carboxymethyl)-, trisodium salt

Within 60 days after the publication of this notice, any suggestions can be submitte

Reason for Amendments

Following a screening assessment conducted by the Minister of the Environment and the Minister of Health (the ministers), Na3NTA was considered to have concern of human health effects. There is speculation that the information concerning significant new activities in relation to Na3NTA may contribute to determining the specific circumstances in which Na3NTA is toxic or capable of becoming toxic.

Canada intends to amend the DSL to indicate that under certain conditions, SNAN is required to be submitted with the manufacture and importation of products (including cosmetics) containing Na3NTA. The ministers will assess the information provided by the notifier and other available information to determine whether Na3NTA, if used in the proposed new activity, could pose a risk to the environment or human health, and, if so, whether risk management is required.

Proposed Amended Requirements for Cosmetics Containing Na3NTA

Na3NTA was removed from part 1 of DSL and added to part 2. SNAN is required to be submitted with cosmetics containing Na3NTA under the following conditions.

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