Canada Releases New Compliance Guide for Certain Products Containing Toxic Substances
Trade Update • March 12, 2026
Key Points
Canada published the Certain Products Containing Toxic Substances Regulations (SOR/2025-36) on March 12, 2025.
The rules prohibit certain coal tar–based sealant products and restrict sealants containing high levels of polycyclic aromatic hydrocarbons (PAHs).
Sealant restrictions took effect for manufacture and import on October 1, 2025, and sales on December 31, 2025.
The regulations also replace the previous 2-Butoxyethanol (2-BE) Regulations.
Environment and Climate Change Canada released a compliance guide explaining testing, record-keeping, exemptions, and permit rules.
Environment and Climate Change Canada has issued a compliance guide for businesses affected by the Certain Products Containing Toxic Substances Regulations, published on March 12, 2026. The regulations restrict the manufacture, import, and sale of specific products containing toxic substances. The goal is to reduce environmental and human health risks by prohibiting certain coal tar–based sealants, limiting polycyclic aromatic hydrocarbons (PAHs) in sealant products, and maintaining concentration limits for products containing 2-butoxyethanol (2-BE). Most provisions entered into force by the end of 2025.
Products Covered by The Regulations
The regulations focus on the following categories of products containing toxic substances.
Sealant Products Containing Coal Tar
The regulations prohibit sealant products that contain coal tars and their distillates. These substances have been associated with environmental contamination and health risks.
Affected products include:
- Paving sealant products
- Roofing sealant products
- Sealant products used for industrial applications on metal, structural steel, concrete components, pipelines, and buried infrastructure
Please note:
- Manufacture and import of these sealant products became prohibited on October 1, 2025.
- Sales of affected products became prohibited on December 31, 2025.
- The regulations do not allow any concentration of coal tar or its distillates in these products.
Sealant Products Containing PAHs
Sealant products that contain polycyclic aromatic hydrocarbons (PAHs) also fall under the regulations.
Affected products include:
- Paving sealant products
- Roofing sealant products
Please note:
- PAH concentration must not exceed 1,000 parts per million (ppm).
- Manufacture and import restrictions began October 1, 2025.
- Sales restrictions began December 31, 2025.
Products Containing 2-Butoxyethanol (2-BE)
The regulations also address products containing 2-butoxyethanol (2-BE), a chemical commonly used in cleaning agents, paints, and coatings. These requirements previously existed under the 2-Butoxyethanol Regulations, which were repealed and incorporated into the new regulatory framework.
Concentration limits apply to a range of products, including:
- Automobile cleaners (excluding degreasers and internal engine cleaners): up to 10% by weight
- Rug or carpet cleaners: up to 10% by weight
- Floor or baseboard strippers: up to 2% by weight
- Paint strippers or thinners: up to 0.5% by weight
- Laundry stain removers: up to 22% by weight
- Aerosol cleaners: 5% to 6% by weight, depending on the formulation
- Aerosol paints or coatings: up to 0.1% by weight
- Non-aerosol paints or coatings: up to 0.5% by weight
These limits are already in effect for the manufacture, import, and sale of these products.
Compliance Responsibilities for Businesses
Environment and Climate Change Canada recommends the following actions:
- Review product formulations and regulatory thresholds.
- Include regulatory compliance requirements in supplier or procurement contracts.
- Obtain supplier certifications confirming regulatory compliance.
- Conduct laboratory testing when product composition is uncertain.
Companies should also maintain records and documentation demonstrating compliance with the regulations.
Authorities may investigate suspected violations and take enforcement actions if regulated products exceed allowed limits or remain in the market after prohibitions take effect.
How GHY Can Help?
GHY specializes in helping businesses navigate and reduce the impacts of tariffs through strategic solutions tailored to their needs. Our experts can audit your supply chain to identify inefficiencies, uncover cost-saving opportunities, and ensure compliance with evolving trade regulations. We also employ tariff engineering techniques to optimize product classification and sourcing strategies, minimizing duty exposure and maximizing profitability.
By partnering with GHY, your business gains access to the tools and expertise needed to streamline operations and stay competitive in a challenging trade environment.
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