Are Inolex CHA-containing products authorized for cosmetic use in Canada?

Yes. Inolex products containing Caprylhydroxamic Acid (CHA) are authorized for cosmetic use in Canada under Ministerial Condition (MC) 20655, issued to Inolex in February 2024.

What is a Ministerial Condition (MC)?

A Ministerial Condition is a permission issued by the Minister of the Environment under the Canadian Environmental Protection Act (CEPA), allowing a specific company to manufacture or import a substance not listed on Canada's Domestic Substances List (DSL). Each MC applies only to the company that filed it and reflects the data that company submitted. An MC is not a determination about the substance itself, and one MC does not override another.

Why did Inolex receive an MC for CHA in Canada?

CHA is not on Canada's Domestic Substances List (DSL), which means it is treated as a "new substance" under the Canadian Environmental Protection Act (CEPA). Companies importing a new substance at commercial volumes above New Substances Notification Regulations (NSNR) thresholds must notify the Minister of the Environment. Inolex filed that notification, and MC 20655 is the resulting authorization.

I've seen Ministerial Conditions for CHA that do not authorize cosmetic applications. How can that be?

Each MC is tied to the company that filed it and reflects that company's submitted data and intended uses. Different companies hold different MCs for the same substance. The substances database does not display notifier names in its public listings. Inolex's authorization is MC 20655 (Canada Gazette, February 24, 2024). Other companies hold MCs for CHA in Canada, none of which authorize cosmetic applications. Those MCs do not affect Inolex's authorization under MC 20655. At commercial volumes, Inolex is the only authorized supplier of CHA for cosmetic use in Canada.

Is CHA safe for use in cosmetics?

Yes. CHA has an established global safety profile, including the Cosmetic Ingredient Review (CIR) Expert Panel's 2020 conclusion that CHA is safe for cosmetic use at recommended levels up to 0.3%. Inolex CHA has been safely incorporated into more than 15,000 products globally.

Which Inolex products contain CHA?

Inolex offers CHA-containing products under the trade names Zeastat™, Spectrastat™, Duostat™, Phenostat™, Benzostat™, and Aromastat™.

I'm purchasing Inolex products containing CHA outside of Canada. Does MC 20655 affect me?

No. No special action is required, even if you later import your finished product into Canada. Inolex products containing CHA can be used in formulations worldwide.

I'm purchasing Inolex products containing CHA inside Canada. What do I need to do?

It depends on how you purchase.

• If youpurchase directly from Inolex and ship it into Canada yourself: you are subject to the restrictions, record-keeping, and reporting obligations established by MC 20655. Please refer to the Canada Gazette notice or your Inolex sales representative for guidance.

• If youpurchase through LBBS Canada, Inolex's authorized distributor in Canada: LBBS Canada manages the MC 20655 obligations on your behalf as the importer. You have no record-keeping or reporting requirements as their customer. LBBS Canada can be reached at www.lbbspecialties.com/lbbs-canada. Your Inolex sales representative can also introduce you directly.

Is MC 20655 a long-term authorization?

Yes. MC 20655 does not have a set expiration date and remains in effect on an ongoing basis. Inolex actively monitors Canadian regulatory developments so customers can confidently use Inolex CHA products in long-term formulations.

Additional resources to learn more about Ministerial Conditions

• Ministerial Condition No. 20655
• Cosmetic Alliance Canada, Regulatory Bites – Ministerial Conditions

If you have any further questions, please contact your Inolex representative or info@inolex.com.

This technical product information and suggestions for use, while believed to be accurate and reliable, is given without any guarantee or warranty of any kind expressed or implied. Purchaser assumes all risk in acting on this information provided by Inolex Inc. and its representatives. Since product specifications may have individual requirements based on customer’s specific needs, each purchaser is urged to perform their own tests, experiments, and investigations in the use of Inolex Inc. products and for purposes of determining compliance with applicable local laws and regulations. Inolex Inc. and its representatives assume no liability in connection with the use or utilization of the materials or the products described therein. Nothing stated herein is to be considered a recommendation or inducement of any use, manufacture, or sale that may infringe any patents or any other proprietary rights now or hereafter in existence. Moreover, no license is to be implied under any Inolex patents relating to the uses of the above.