CPCA: Adhesives & Sealants Advisory Council

The paint and coatings industry continues to be among the most heavily regulated sectors in the economy. Adhesives and sealants companies are no exception, including major companies among CPCA’s membership. CPCA ensures a strong voice on important advocacy efforts with a proven track record of success in government relations and regulatory affairs. To leverage CPCA’s regulatory approach, contacts and initiatives, CPCA created the Adhesives and Sealants Advisory Council to address current and future government regulations.

The third phase of the federal government’s Chemicals Management Plan (CMP-3), assessing chemicals in commerce in Canada over the next five years, will review a vast number of substances in the adhesives and sealants sector. In some cases substances used in adhesives and sealants rank first or second in terms of the industries most impacted by the CMP. To help ensure proper risk assessment and risk management, CPCA established the Adhesives & Sealants Advisory Council. This Council will provide relevant input to ensure that critical substances used in the industry are not inadvertently determined to be CEPA-toxic and banned, or, where risk management measures are required, that they are evidenced-based, fully discussed with industry, and properly managed.

Right now manufacturers or importers of any of the 1,550 substances identified under CMP-3 can benefit greatly from early engagement with the federal government. There are multiple benefits to identifying early in the process to convey what extent companies are impacted by any substance now or in future. For instance, government has indicated that it is moving away from the requirement for “mandatory” surveys, which trigger company-specific compliance activities. Instead, it will maximize opportunities to engage with industry through sectoral approaches and joint industry submissions, which are arguably CPCA's strengths.

By reviewing the identified list of substances, member companies in the adhesives and sealants business can begin to develop an early strategy for engagement, whether as a direct company stakeholder or by working through CPCA. In some cases it can be both. This way the sector will gain a better understanding of the extent of the impacts of CMP-3 and thereby focus resources more effectively on information gathering and on common approaches.

There are 210 polymers and 195 substances (25 manufactured, 170 imported) of the 1,550 to be reviewed in CMP-3, which are used in adhesives and sealants, representing 26 per cent of the total. The government also received 825 notifications of interest for substances used below the established threshold or that might be included in future uses. This is a substantial number of substances to be assessed by the federal government for a possible ban or a risk management measure. Member companies of the Council must be fully engaged over the next five years as governments escalate their assessment of adhesives and sealants. Many of these substances are common to paint and coatings formulations. By joining CPCA and becoming members of the Council, companies will have an opportunity to coordinate discussions and actions with CPCA’s Paint and Coatings Working Group for maximum effect.

Decisions that are not aligned with other jurisdictions or assessments that lead to negative decisions by the federal government with respect to substances used in thousands of products sold in Canada can quickly lead to the following negative impacts: 

  • Trade disruptions and difficulties in the management of stocks for North American trade;
  • Abandonment of products with high penetration in the Canadian marketplace;
  • Reformulations required for products with substitutes that are not always cost-effective or available in Canada;
  • Extensive testing, re-labelling and special precautions with respect to transportation of goods;
  • Unique Canadian restrictions of use and/or misalignment with U.S. and international regulatory measures for substances; and
  • The potential of creating a negative image for the industry generally with respect to substances used in product formulations in cases where products and applications may not even be targeted for regulation.

Industry wants none of these negative impacts to become a reality and alter a company’s business plan. CPCA’s work can save companies time and money, thereby providing a significant return on investment for members. In turn it also enables government officials to make facts-based decisions on the chemicals assessed and thereby protect the environment and human health of Canadians, which is the ultimate goal for both industry and government.