If your business or facility is in Toronto you may have to submit a ChemTRAC report to Toronto Public Health each year to comply with the Environmental Disclosure and Reporting Bylaw. The amounts of chemicals your facility releases, manufactures, processes or otherwise uses may change from year to year. Therefore, some years you may not meet the reporting thresholds, which means you would not have to report for those years. It is important to check every year if you need to report or not. Review ChemTRAC’s Guide to Reporting for more information.

Businesses & Facilities That Need to Submit a Report

  • Business/facility is located in Toronto, and;
  • In the past year, your business/facility released, manufactured, processed or otherwise used any of the 25 priority substances (chemicals) listed in the bylaw, and;
  • In the past year, any amount of one of these chemicals met or exceeded the reporting thresholds.

*Note: some businesses/facilities are exempt from the bylaw, listed below. If you own or operate more than one business/facility in Toronto, you must review each and report them separately as required.

Businesses & Facilities Exempt from the Bylaw

Exempt businesses and facilities are described by their North American Industry Classification System (NAICS) codes and include:

  • Facilities engaged solely in retail sales 
    • the retail sector (NAICS code 44 and 45) is involved in selling merchandise only and doesn’t change or alter the merchandise. Retail sales is the final step in the distribution of merchandise, which means that retailers receive merchandise and sell it as it was received. Included in this category are retail bakeries primarily engaged in manufacturing bakery products for retail sale (NAICS code 311811) and facilities primarily engaged in retailing confectionery goods and nuts (NAICS code 3113) made on the premises that are sold to the general public on the same premise. Retail paint stores and hardware stores that sell paint (NAICS code 4441) are also exempt.
    • If you are a retailer and some of your customers are other businesses who buy products or obtain services from your facility, then your facility is considered a retail facility under the bylaw. However, if you are a wholesaler or a manufacturer who also sells some of your products directly to the consumer, you are not exempt.
  • Medical or dental offices
    • This sector consists of facilities that provide out-patient health services. The offices of physicians (NAICS 6211), dentists (NAICS 6212), and other health care providers such as chiropractors, optometrists, mental health practitioners, occupational therapists (NAICS 6213), and out-patient care centers (NAICS 6214) do not have to report.
    • Medical and diagnostic laboratories (NAICS 6215) and hospitals (NAICS 622) are not exempt.
  • Construction and building maintenance sites
    • Facilities involved solely in construction, building maintenance and renovation activities are exempt from the bylaw.
  • Food and accommodation services
    • A hotel bed, bed and breakfast, home for the aged, catering business, restaurant, coffee shop, bar, mobile food vending, or traveller accommodation (NAICS code 7211, 7221, 7222, 7223, or 7224) is exempt from the bylaw.
    • However, laundry and dry cleaning facilities located within any of these facilities are not exempt (NAICS code 8123). If your laundry or dry-cleaning service meets the criteria outlined in the bylaw, you are required to report this activity.
  • Facilities that distribute, store or sell fuels
    • Gasoline stations (NAICS code 4471) and other facilities that store and distribute fuels (for example, petroleum product distributors, NAICS code 412) are exempt from the bylaw.
  • Facilities that maintain and repair vehicles
    • Any facility that maintains and repairs vehicles such as cars, trucks, locomotives, ships or aircraft are exempt only if the facility does not paint or strip vehicles or their components, rebuild or remanufacture vehicle components. This means that you are not required to report if your facility only does general mechanical and electrical repair and maintenance services for motor vehicles, such as engine repair and maintenance, exhaust system replacement, transmission repair and electrical system repair, oil change, lubrication, washing, or tire repair.
    • If your facility is an auto body shop or similar facility then you may need to report to ChemTRAC. Auto body shops include facilities that repair and paint vehicles after a collision. Facilities that strip vehicles, rebuild or remanufacture vehicle parts in your facility are also not exempt.

Sources of Chemicals Exempt from the Bylaw

The chemicals listed in the bylaw come from many different sources, and certain sources are exempt from reporting. This means chemicals from these sources are not included in calculations:

Exempt chemical source Example
An article (an item that already contained a toxic chemical before it entered your facility and that doesn’t release any of the chemical when it is used or processed) A tool or part of a machine
A structural component of a facility A wall or floor
A product used for routine cleaning, facility and grounds upkeep Washroom sanitizer
The personal items of the people in the facility Hairspray
Vehicle emissions Dump truck emissions
Intake water or air Compressed air, cooling water
Road dust From the movement of vehicles
Emissions from space heaters or hot water heaters that are not part of the process equipment Emissions from a furnace to heat a building or water boiler for hot water used in washrooms. Note: only exempt if not used in the manufacturing process
Materials used for the purpose of maintaining motor vehicles operated by the facility

The bylaw requires you to report every year for both use and release amounts of all chemicals that meet or exceed the reporting threshold. The amounts or types of chemicals your facility uses or releases may change from year to year. Because of this, you should review your reporting requirements each year to determine whether or not you need to report. If your facility is not exempt from the bylaw, you need to:

  1. Identify if you use, manufacture, process or release any of the chemicals listed in the bylaw. There are many sources of information that can help you identify the chemicals in your facility. Be sure to check all of them, including:
    • Purchase records
    • Material Safety Data Sheets
    • Raw materials
    • Year-end inventory
    • Certificate of Approval or Environmental Compliance Approval
    • Correspondence with supplier
    • Purchase records
  2. Track the chemicals in your facility every year (January 1st to December 31st).
  3. Determine which (if any) chemicals meet or exceed the reporting thresholds. Chemicals are divided into three groups, A, B and C. The reporting thresholds for each of these groups are different.

We have many tools, tips and guides to help you prepare for reporting.

Submit a ChemTRAC report

Here are some points to get you started:

  • If you own/operate more than one, submit a separate report for each business/facility in Toronto.
  • Report both the use and release amounts of all chemicals that meet or exceed the reporting thresholds.
  • Estimate the use and release for all sources and processes in your facility.
    • This includes processes such as heating by natural gas combustion, welding, equipment cleaning, drilling, grinding, crushing, sanding, and blending.
    • Review the exemptions in the bylaw, such as building heating, and do not include amounts related to these sources in your calculations.
  • The following chemicals are Volatile Organic Compounds (VOCs). Be sure to report them separately and also include them in your VOC estimation:
    • Acetaldehyde
    • Acrolein
    • Benzene
    • 1.3-butadiene
    • Carbon Tetrachloride
    • Chloroform
    • 1,4-Dichlorobenzene
    • 1,2-Dichloroethane
    • Formaldehyde
    • Trichloroethylene
    • Vinyl chloride
    • Polycyclic Aromatic Hydrocarbons (PAHs) (Group B)
  • Make sure you have considered all activities and sources within your facility that may be using or releasing the chemicals.
  • When reporting your use data, review the definitions of “Manufacture”, “Process” and “Other use” in the bylaw to enter the use amount of a chemical in the correct column (category).
  • When reporting metals, you are required to report metals and their compounds. When determining whether or not you use a metal, do not simply search for the associated CAS numbers listed in Schedule A of the bylaw because individual metal compounds also have their specific CAS numbers.
  • When reporting Group C chemicals (NOx, PM2.5, VOCs) as a result of natural gas combustion, you are required to report them as manufactured and released.

Submit your data online by June 30 each year

Before you submit a ChemTRAC report, ensure that you have the following information ready:

  • Quantities of chemicals that were used and released for the reporting year, in kilograms, and the method you used to estimate or measure these quantities;
  • Up-to-date information on your business/facility name, address, number of employees and contact person,
  • Your North American Industry Classification System (NAICS) code that best describes the type of business/facility for which you are reporting.
  • Information on your business/facility’s environmental goals, programs or achievements, should you choose to submit that data; and
  • Your First Time Access Code for new users or Registration ID for businesses/facilities already in the system. Call 311 if you did not receive a First Time Access Code from the City by mail.

If you are reporting data under the bylaw, the ChemTRAC Online Reporting System allows you to:

  • Submit required data on chemicals; and
  • Provide voluntary information on your business/facility’s environmental activities.

If you do not report data under the bylaw, you can use the system to:

  • Identify yourself as a non-reporter; and/or
  • Provide voluntary information on your business/facility’s environmental activities.

Keep your records that describe how you estimated your chemical amounts, whether or not you are required to report. The City may request this information for bylaw enforcement purposes.

Tracking and reporting to ChemTRAC helps businesses and facilities identify the major sources of chemicals in their facility. This information can be used to develop plans to reduce the use and release of chemicals.

This is also an opportunity for businesses to share the pollution prevention efforts they are making and to explain how their business works through the voluntary Environmental Statement in the ChemTRAC Disclosure Report.

Why Businesses Go Green

Going green improves Toronto’s environment and people’s health but it also can make good business sense. Some of the reasons include:

  • Profitability
  • Improving efficiencies
  • Reducing business risk
  • Employee retention
  • Improved community relations
  • Product or service stands out from the crowd

How Businesses Go Green

Pollution prevention is the most effective way for a facility to reduce its impact on the environment and health. Pollution prevention includes:

  • Replacing hazardous materials with less-toxic ones
  • Changing how waste is managed
  • Installing new technology
  • Maintaining equipment to ensure that leaks and general efficiencies are managed
  • Training staff on processes to reduce the use and release of chemicals

Green Guides for Businesses

Pollution Prevention Programs & Case Studies