Update to the Vaping Products Labeling and Packaging Regulations
By: Ivy Tang, Product Safety Specialist, email
In the months leading up to the coming into force of the Vaping Products Labelling and Packaging Regulations (VPLPR), the vaping industry has requested additional clarification and further guidance from Health Canada to ensure compliance, especially on the usage of tags for their products.
Health Canada published a letter outlining its intended approach to enforcing the new labeling requirements on June 1st. Due to COVID19, Health Canada recognizes that normal business operations have been impacted and will take this into account when assessing non-compliance with the new regulations. As a result, new key dates have been released:
July 1st, 2020 remains the coming into force date of the VPLPR. Health Canada expects the industry to continue making ‘best efforts’ to comply with the changes outlined in the regulations.
From July 1st to December 31st 2020¸ Health Canada intends to provide additional guidance and information to promote compliance with the VPLPR. It is during this time period that Dell Tech expects to receive further clarification on the usage of tags.
Beginning January 1st, 2021 Health Canada will begin a ‘progressive compliance monitoring regime’ to address and verify compliance with the VPLPR.
It is important to note that Health Canada retains full enforcement authority starting July 1st. Aspects of compliance interrupted by COVID19 will be taken into account, but Health Canada officials still have the ability to issue stop distribution, stop sale, or recall requests if deemed necessary.
While many businesses have begun to source tags for e-liquid bottles with a Main Display Area of < 45 cm², others may choose to wait for the release of further guidance. If your business wishes to wait, Dell Tech advises that the ingredient list continue to be printed on the product label.
Dell Tech encourages all vaping businesses to take efforts to comply with the VPLPR by July 1st. Labels following the CCCR 2001 interim regulations will effectively ‘expire’ on this date. The transition from CCCR 2001 to the VPLPR will require most labels and packaging to be reformatted; new label elements such as nicotine concentration, health statements, and first aid will be mandatory. If your company requires any assistance with this transition, please contact Dell Tech today.