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Canada Proposes to Include Benzophenone and Triarylmethanes into the List of Toxic Substances

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Canada had proposed adding benzophenone and triarylmethanes group to Schedule 1 to the Canadian Environmental Protection Act, 1999 (CEPA). The substances are subject to risk management measures.


In January 2021, the final screening assessment was published. The screening assessment was conducted to determine whether the substance meets one or more of the criteria for a toxic substance as set out in section 64 of CEPA (i.e. to determine if the substance could pose a risk to the environment or human health in Canada). Results show that benzophenone meets the human health criterion for a toxic substance as set out in paragraph 64(c) of CEPA, and thus constitutes a risk to human health in Canada.

On April 2, 2022, Canada proposed to benzophenone to Schedule 1 of the CEPA and started a 60-day public comment period.

Risk Assessment

It was concluded that benzophenone may pose a risk to human health, based upon a comparison of the levels to which Canadians may be exposed to benzophenone when using nail polish, exterior and interior paints as well as stains and the critical endpoints that will affect human health. By contrast, other sources of exposure (such as food, indoor air, dust and baby bottles), were not considered to pose a risk to human health.

To reduce exposure to benzophenone from products, the government is considering:

  • To add benzophenone into the List of Toxic Substances, which allows Canada to take preventive or control actions over the life circle of certain substances. The List also includes the R&D, manufacture, use, storage, transportation, disposal and recycling of benzophenone, and the list of prohibited or restricted cosmetic ingredients.
  • To formulate a practice code urging manufacturers to reduce the concentration of benzophenone to a maximum of 0.1% (w/w) or 1,000 mg/kg in certain paint.

Triarylmethanes Group

In October 2020, Canada released the result of the screening assessment for Triarylmethanes Group. On April 2, 2022, the Canadian authorities proposed to add Basic Violet 3, Malachite Green, Basic Violet 4, and Basic Blue 7 into Schedule 1 of the CEPA with a 60-day public comment period.

Risk Assessment

Triarylmethanes do not occur naturally in the environment. According to the information collected, these substances are primarily used as coloring agents: as dyes and/or pigments in inks, toners and colourants, in paper products and manufactured items, and potentially in food packaging. Substances in this group may also be used in other products such as cosmetics, cleaning products, and water treatment for aquarium fish. They are also used in industrial and laboratory products.

As a result of the screening assessment, the Government concluded that Malachite Green is harmful to human health at levels of exposure considered in the assessment. Also, Basic Violet 3, Malachite Green, Basic Violet 4, and Basic Blue 7 are concluded to be harmful to the environment.

To address human health concerns for Malachite Green, the Government is considering the following actions:

  • Describing it as a prohibited or restricted ingredient on Health Canada’s Cosmetic Ingredient Hotlist.
  • Any proposed new manufacture, import or use of certain products containing Malachite Green (for example, markers) be subject to further assessment and potential risk management.
  • To address ecological concerns, the Government is considering an environmental release guideline to limit releases of Basic Violet 3, Malachite Green, Basic Violet 4, and Basic Blue 7 to water from pulp and paper facilities. An amendment to include these 4 substances in the Guidelines for the Reduction of Dyes Released from Pulp and Paper Mills may be proposed.

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Triarylmethanes Group



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