By: Ivy Tang, Product Safety Specialist, email
The answer to the question “Can I use a single label for the United States (US) and Canada?” can be a yes, no, or maybe. The answer depends on the hazard classification of the product, which requires an understanding of the differences between the two regulations: the Consumer Chemicals and Containers Regulations (CCCR, 2001) and the Consumer Product Safety Commission (CPSC). In this article, we review several differences.
The CCCR 2001 requires that labels disclose hazardous ingredients present at ≥ 1 %, in descending order of proportions. The CPSC, however, does not have a % threshold requirement nor does it require ingredients to be disclosed in a particular order. If you want to create a combined US-CAN label, make sure to align it with the stricter requirements.
Another difference between US and Canadian consumer ingredient disclosure is the chemical identity. The CCCR requires that the precise chemical identity be used. This may refer to a nomenclature system developed by the International Union of Pure and Applied Chemistry (IUPAC) or the Chemical Abstracts Service (CAS). The CPSC, however, does not have a similar mandate. A US label can disclose generic or common names of ingredients. Note that a function (e.g. ‘surfactant’) would not be allowed.
Lastly, US products may be classified under the Chronic Toxicity category- that is, a reproductive, carcinogenic, or mutagenic hazard. The CCCR does not have chronic toxicity as a category. As a result, a combined US-CAN label must display cautions, first aid statements, and ingredients pertaining to chronic toxicity even if it is not necessary under Canadian regulations.
Dell Tech consultants are experts in US and Canadian consumer regulations. If you want to classify your product properly, or need a label reviewed, contact us today.
Contact:
Dell Tech Laboratories
Ivy Tang, B.Sc.
Product Safety Specialist
itang@delltech.com
519-858-5021 ext 2043
Dell Tech has provided professional, confidential consulting services to the chemical specialty
industry in Canada, the USA, Europe, and Asia for the last 40 years.
Contact us today for more information.
www.delltech.com
