ROHS Compliance

On October 25, 2025, Environment and Climate Change Canada (ECCC) issued a notice under Section 87(3) of the Canadian Environmental Protection Act, 1999 (CEPA 1999), proposing to delete diisodecyl adipate (DIDA, CAS No. 27178-16-1) from Part 1 of the Domestic Substances List (DSL) and add it to Part 2, thereby designating it as a substance subject to Significant New Activity (SNA) requirements.

Background

DIDA is presently included in Part 1 of the DSL, signifying that it was in commercial use in Canada between 1986 and 1996. However, a recent comprehensive evaluation by Canadian authorities has highlighted potential risks linked to its use at high concentrations in specific consumer goods, cosmetics, natural health products, and non-prescription drugs.

Proposed Controls

Under the draft regulations (see Annex), the following activities will be classified as "Significant New Activities" requiring advance notification:

1. Manufacturing DIDA-containing products

· Non-spray lubricants or automotive fluids with DIDA concentrations >84%;

· Spray lubricants with DIDA concentrations >15%;

· Other consumer products, cosmetics, natural health products, or non-prescription drugs with DIDA concentrations ≥0.2%;

· Lip liners with DIDA concentrations >10%.

2. Importing DIDA-containing products Annual imports exceeding 10 kg with concentrations meeting the above thresholds must also be reported.

3. Exemptions

Activities involving research and development, on-site intermediates, or products solely for export are exempt.

Implementation

Once DIDA is formally moved to Part 2 of the DSL, any proposed manufacturing or import activities that trigger the Significant New Activity (SNA) requirements will be obligated to notify the government at least 90 days in advance, providing detailed information to support environmental and human health risk assessments.