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.
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.
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
dusing the online reporting system available through Environment and Climate Change Canada’s Single Window; or
sent by mail to the Executive Director, Program Development and Engagement Division, Department of the Environment, Gatineau, Quebec K1A 0H3; or
sent by email to email@example.com.
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.