Mixing, Blending and Formulating: Salt does happen!

13 May 2013

Remember to keep an eye out for ingredient interactions that might produce a new substance right there in the vat.

A note of caution to all you formulators out there - when cold-mixing, blending or formulating (or whatever other name the activity goes by in your plant) your performance products for sale into Canada, remember to keep an eye out for ingredient interactions that might produce a new substance right there in the vat. For example, if your ingredient list includes both acidic and basic materials, check to see if you should expect them to form a salt, and if so, whether that salt is listed on the Domestic Substances List. If it isn't, then, by definition, it's a new substance, and is, therefore, notifiable.

The same consideration also should be given to polymers – during manufacture as well as formulation. Remember that Canada has no equivalent to the USEPA's TSCA "(h)(7)" exemption, so if you've neutralized your polymer at all, make sure that the CAS name and number you use to describe it adequately captures the counterions present, and are listed on the DSL.

Do you have questions about Canadian new substance notifications or other related topics? Share your comments or questions below and our expert, Joyce Borkhoff, will get back to you.