By: Ivy Tang, Product Safety Specialist, email
What is a Consumer Product?
A consumer product is a manufactured good purchased for non-commercial purposes, such as household and personal uses. In the context of chemical consumer products, examples include dishwashing detergent, cleaners, air fresheners, paints, and mechanical lubricants- common items you can find on the shelf of a retail store.
Consumer products do not include products that require specific registrations, such as drugs, cosmetics, disinfectants, pesticides, and natural health products.
Why Do Consumer Chemical Products Require Their Own Regulation? What About GHS?
Since consumer products are sold and used in different environments than workplace products, separate regulations are required to address the hazards that may be unique to each setting. For example, toxic consumer products may require child- resistant packaging, which would not be necessary in a workplace.
GHS is an international standard used for workplace products. GHS and consumer regulations have their own hazardous material classification systems, use different test methods, and employ different labeling schemes. Average consumers are not trained to understand GHS label elements. Consumer regulations are meant to protect consumers by informing them of the potential hazards that a product may have.
It is important to note that these two regulations should not be used interchangeably.
Canada vs. USA
Canadian consumer products are regulated under the CCCR 2001 (Consumer Chemicals and Containers Regulations, 2001) which falls under the Canada Consumer Product Safety Act. American consumer products are regulated under the Consumer Product Safety Commission.
CCCR 2001 has five main regulated classifications: toxicity, flammability, corrosivity, quick skin-bonding adhesives, and pressurized containers. CCCR 2001 is very prescriptive. The regulations outline test methods, the classification procedure, label formatting, label requirements (hazard symbols, warning statements, first aid instructions, etc.), print specifications (e.g. minimum allowable text size), and special exemptions.
Health Canada has also published a CCCR 2001 Reference Manual which contains information on the enforcement of CCCR 2001 and provides a more in-depth discussion on various parts of the regulation.
Under the Federal Hazardous Substances (FHSA) Act and Poison Prevention Packaging Act (PPPA), hazardous consumer products may be toxic, corrosive, an irritant, a strong sensitizer, flammable, combustible, or any combination of the above. CPSC (Consumer Product Safety Commission) regulations for labelling requirements include a signal word, an affirmative statement of the principal hazard, precautionary measures, first aid instructions, and handling and storage statements. The language used is not formally prescribed. However, the CPSC has special labeling requirements for products containing specific substances, such as diethylene glycol at 10% or more by weight. The list can be found in 16CFR 1500.14.
Differences between CCCR and CPSC
The most prominent difference between the two countries’ consumer labeling regulations is the requirement for bilingual (French and English) labeling in Canada. CPSC includes a category for chronic hazards such as sensitizers and carcinogens, whereas CCCR 2001 does not. The two regulations also calculate type size differently. CCCR 2001 also uses a variety of symbols, compared to the one (skull and crossbones) used by CPSC.
Can I Combine The Two Into A Single US and Canadian Label?
Yes…but it is often extremely difficult due to the differences mentioned above, and therefore not advised. US consumers are not familiar with the Canadian consumer hazard symbols, and this may be a cause of confusion. A non-hazardous product which will require no hazard language or symbols may be combined. However, there is typically not enough space for a consumer label to be compliant in both countries due to the Canadian language requirements.