Some Canadian bodyshops may need to file reports under new federal chemical rules.
The requirement is aimed at businesses that used large amounts of certain chemicals in 2025 or imported listed chemicals and products directly into Canada. The first notice covers 184 chemicals and carries a reporting deadline of 2027-03-03. The second covers 16 chemicals and must be filed between 2027-03-04 and 2027-09-08.
For ordinary repair, cleaning and maintenance work, reporting is required only when a business used more than 100 kg of one listed chemical. If the chemical was an ingredient in a paint, cleaner or other product, it must also have accounted for at least 0.1% of that product’s weight.
The threshold applies to the chemical, not the complete product. A business using 1,000 kg of paint containing 10% of a listed chemical would have used 100 kg of the chemical. It would remain below the reporting threshold, which is more than 100 kg.
A bodyshop that did not exceed the applicable threshold and did not directly import a reportable quantity does not have to file.
The requirements took effect on 2026-08-29 and apply to work completed during the 2025 calendar year. The federal government is collecting the information to assess the chemicals and decide whether future controls are needed. The chemicals have not been banned and the notices do not place new restrictions on their use.
Products requiring attention can include automotive coatings, paint strippers, degreasers, panel adhesives, seam sealers, epoxy repair products, corrosion protection products, cleaners, lubricants, hydraulic fluids, cutting fluids and antifreeze. A product creates no reporting requirement unless it contains one of the listed chemicals and the business crosses the applicable threshold.
One listed chemical is UV-328 or CAS 25973-55-1. UV-328 has been used in automotive coatings to protect the coating and colour from sunlight.
Several listed benzothiazole chemicals are used to harden rubber or protect it from aging. These include CAS 95-31-8, 95-33-0, 120-78-5, 149-30-4, 155-04-4, 2492-26-4 and 4979-32-2.
Some forms of 2-mercaptobenzothiazole can also be used in adhesives, antifreeze, hydraulic fluids, cutting fluids and corrosion protection products.
Installing a finished tire, hose, belt or seal does not count as using the chemicals inside it. The calculation covers chemical products applied or consumed during repair, cleaning or maintenance.
Other chemicals named in the notices have direct connections to automotive products. Bromoethane, CAS 74-96-4, is associated with degreasers. Chloroethane, CAS 75-00-3, is associated with exterior vehicle waxes, polishes and coatings.
The uses identified for 1-bromopropane, CAS 106-94-5, include paint and coating strippers, finishing sprays and interior vehicle cleaners. CAS 17540-75-9 is associated with brake fluid.
N-methyl-2-pyrrolidone, CAS 872-50-4, may be used in single-part adhesives and paint or coating strippers. Zinc oxide, CAS 1314-13-2, is used in tires.
Using those six chemicals during an ordinary repair does not by itself require a report. They become relevant to most collision businesses only when products containing them are ordered directly from outside Canada.
A bodyshop can be considered a direct importer when it orders a product from a foreign supplier and causes it to enter Canada. The business does not have to be identified as the formal importer of record.
Purchasing a foreign-made product from a Canadian supplier or warehouse does not count as importing. Moving the product between provinces also does not count.
Companies operating several bodyshops must combine their use of the same chemical across every location. Four locations using 30 kg each would produce a company total of 120 kg. Independently owned franchisees do not combine their use simply because they operate under the same banner.
Businesses can search safety data sheets, technical data sheets, purchasing records and import documents for the listed chemical names and CAS numbers. They should request composition information from suppliers when their own records are incomplete. Laboratory testing is not required.
