Treated articles are generally used for a product or material which is treated with a pesticide or biocide for a particular purpose, such as protecting the article or exerting certain desired effects. An ‘antimicrobial treated article’ refers to a product or material to which an antimicrobial preservative has been intentionally incorporated or applied to prevent degradation or damage to products or materials from micro-organisms (e.g. to inhibit bacterial growth). These include antimicrobial preservatives in water-based paints, certain plastic products, and wood construction or masonry materials. These preservatives used to treat products are regulated under the Pest Control Products Act. Only registered pesticides are permitted for manufacture, import, sale and use in Canada. For antimicrobial treated articles, the registration requirement is limited to the pesticide itself, the actual preservative. Antimicrobial ‘treated’ articles or products are not required to be registered as long as certain conditions are met such as any preservative contained within the product is registered, in accordance with approved uses and limited to prevention of degradation from microorganisms. The view on treated articles and how they are to be registered in future is being evaluated within the context of existing Canadian legislation.
Issues Tracking, Regulatory Updates & Canada Coatings HUB Resources
This issue is linked to the use of biocides in paint and as such CPCA is following it closely. There is also a lot of activity in other countries, especially the EU, which could impact the current policy in Canada. There will be no new policy proclaimed in Canada, rather the current agency responsible for the registration of biocides, PMRA, is seeking to clearly elaborate on what Canada’s policy is for treated articles under the Pest Control Products Act (PMRA). The goal here is to ensure that it is clearly stated and for the coatings industry that it does not directly impact paint products per se, only the ingredients used in those products. The policy applies to the products that make claims related to the treated ingredient contained in the product such as it is a mosquito repellent, etc. CPCA has seen a draft of the treated article policy statement and provided feedback as requested. The policy will be published as a guideline for industry. CPCA will continue to monitor this issue as it could have impacts in future in terms of any environmental product declarations (EPD) made by companies for their products.
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The table below outlines all activities conducted by CPCA related to the issues within the Chemicals Management Plan (CMP). Anything that is marked as "Member Action Required" within the table will display in your dashboard if you are subscribing and following this issue. Look for important compliance dates and deadlines within the Compliance Calendar.