New Regulations on Mercury-Containing Products Coming into Force in June 2025

Canadian businesses that manufacture, import, or sell mercury-containing goods—especially lighting products—should prepare their operations now to ensure compliance ahead of the enforcement date.

Starting June 19, 2025, new rules targeting mercury-containing products will officially come into effect in Canada.

These include tighter controls on the manufacture and import of products containing mercury or any of its compounds, with limited exemptions for essential products that do not have technically or economically viable alternatives.

The new rules, established under the Canadian Environmental Protection Act, 1999 (CEPA), are published in the Products Containing Mercury Regulations.

The updates introduce new product prohibitions, reinforce labelling and reporting requirements, and clarify the process for obtaining permits for mercury-containing products that are not exempt.

They apply to importers, manufacturers, distributors, and retailers of lamps containing mercury, who will have until mid-2025 to prepare for these changes.

The revised requirements aim to reduce mercury releases and protect both the environment and public health. 

They also ensure that Canada meets its international obligations under the Minamata Convention while supporting the country’s domestic commitment to Canada’s National Strategy for Lamps Containing Mercury.

Phased-out lamps and new product bans

The most significant change introduced by the amendments is the phased prohibition of certain commonly used commercial and residential lamp types, which will face the following restrictions:

• As of January 1, 2026, the manufacture and import of screw-base compact fluorescent lamps (CFLs) will be banned.
  
  
• Pin-based CFLs, straight fluorescent lamps, and non-linear fluorescent lamps will be permitted for an additional two years. Their manufacture and import will be prohibited after December 31, 2027.
  
  
• Starting January 1, 2029, manufacturing and importing high-pressure sodium vapour lamps and metal halide lamps will be prohibited.

These timelines support the transition to more energy-efficient, mercury-free lighting technologies, such as light-emitting diode (LED).

Exemptions to the new regulations

Not all mercury-containing products are subject to the prohibitions. Several items remain exempt under the amended regulations, such as:

• Encapsulated dental amalgam
• Analytical reagents used in laboratories
• Lamps used for growing plants, water treatment, or air disinfection

Please refer to Section 3, Schedule 1, and Schedule 2 of the regulations for the complete list of exemptions.

Applying for a permit

Importers and manufacturers may apply for permits for non-exempt products.

Permit applications must demonstrate that there are no viable mercury-free alternatives and outline how the importer or manufacturer will mitigate potential health and environmental risks.

The service standard for responding to applications is 90 days from the date they are received. Businesses are encouraged to apply for permits well in advance to avoid delays. 

For detailed information on the permitting scheme, please refer to Sections 4, 5, and 6 of the regulations.

Labelling and reporting requirements

The amended regulations maintain the existing labelling requirements for all mercury-containing products, including those covered by exemptions or permits.

Products must display a clear bilingual label with the warning “Contains mercury / Contient du mercure,” along with instructions for safe handling, emergency procedures, and proper recycling or disposal.

In addition to labelling, the regulations mandate that manufacturers and importers submit their reports every third year. These reports must detail the type and quantity of mercury used in products sold or imported into Canada.

Upcoming reporting deadlines are:

• March 31, 2026, for activities during the 2025 calendar year
• March 31, 2028, for activities during the 2027 calendar year

These labelling and reporting requirements do not apply to replacement parts.

Record-keeping requirements

Importers and manufacturers of mercury-containing products are required to maintain detailed records of their activities.

These records must be retained for at least five years and made available upon request during inspections by Environment and Climate Change Canada (ECCC).

To demonstrate compliance, the following information should be readily accessible:

1. Information on all imports, manufacturing, and exports of products containing mercury, including for components and replacement parts, and on the products’ mercury contents.
   
   
2. Information on the remediation measures taken in the cases when an importer or manufacturer was ordered by a law enforcement officer to dispose of, recycle, or return a specific product to the facility from which it was imported.
   
   
3. For importers, the Harmonized Commodity Description and Coding System tariff classification number for the product, as set out in the schedule to the Customs Tariff. 

Providing information to demonstrate that the mercury content of exempted products is at or below the specified limits would also help show compliance.

This may include factory dosage details, company engineering specifications, quality assurance and control processes used during product manufacturing, and testing results from an accredited laboratory.

While labelling and triennial reporting requirements do not apply to replacement parts, businesses must maintain documentation proving that they qualify as replacements.

Preparing for compliance

Canadian importers and manufacturers are encouraged to start preparing for the transition before the June 19, 2025, deadline.

The recommended next steps include:

• Reviewing your product lines and supply chains to identify affected items
• Exploring mercury-free alternatives and phasing out banned products
• Initiating or renewing permit applications for non-exempt products
• Updating your labelling systems and compliance documentation
• Preparing for reporting deadlines and record-keeping requirements

How Cole International can help

At Cole International, we offer customs and compliance consulting services to help businesses navigate and comply with changing regulations.

We also provide timely and efficient customs brokerage services to facilitate the entry of goods into Canada.

If you import mercury-containing products, please reach out to one of our trade professionals to discuss how to best prepare for the transition and ensure compliance with the new regulations.