In May 2026, Dell Tech delivered a presentation on bringing consumer chemical products to market in Canada, with one of the key focus areas being the Canadian Consumer Chemicals and Containers Regulations (CCCR), 2001. A key takeaway from the discussion was the continued level of non-compliance seen in the marketplace, particularly around hazardous ingredient disclosure on consumer product labels.
The CCCR, 2001 establishes the labeling requirements for consumer chemical products sold in Canada, including hazard classification, first aid statements, hazardous ingredient disclosure, and overall label content. These requirements are designed to ensure that both consumers and emergency responders have clear and accurate information about product hazards, and non-compliance can result in regulatory action, including product recalls.
Under Section 31(c), labels must include a list of hazardous ingredients in descending order of proportion, as further detailed in Section 32. Ingredients must be identified either by chemical identity or, where appropriate for complex mixtures, by a generic name. Health Canada guidance requires that substances be clearly and precisely identified using accepted systems such as IUPAC or CAS nomenclature, and vague descriptors such as “non-ionic surfactant” or “primary alcohol,” as well as trade names used alone, are not acceptable.
A frequent compliance issue involves the “Contains Statement” within the first aid section. Where required, it must list all hazardous ingredients present at 1% or greater, in descending order of concentration. In practice, common errors include missing ingredients, overly generic naming, and incorrect ordering, all of which reduce clarity and can impact emergency response effectiveness.
A key regulatory point under CCCR, 2001 is that there is no trade secret exemption for hazardous ingredient disclosure in consumer chemical products. All required hazardous ingredients must be disclosed, and they must be identified using clear chemical nomenclature or a suitable generic name where permitted. Trade names, CAS numbers alone, or internal codes are not acceptable substitutes. Ingredients must always be listed in descending order of concentration.
Although exact formulation percentages are not required, this does not reduce the obligation to properly identify hazardous ingredients when disclosure is required.
In summary, while hazardous ingredient disclosure represents only one part of the CCCR, 2001 framework, it remains one of the most commonly misunderstood areas, and non-compliant labeling continues to be frequently observed in the marketplace. There is a misunderstanding about keeping chemical names confidential and therefore this leads to improper disclosure on labels which can lead to issues with Health Canada. If assistance is needed in reviewing CCCR 2001 label compliance for consumer chemical products in Canada, regulatory support is available to help ensure alignment with current Health Canada requirements.
Blog Author
Kirsten Alcock, H.BSc.
Kirsten Alcock is the Director of Product Safety at Dell Tech, with over 25 years of experience in regulatory affairs and hazard communication. She specializes in safety data sheets, labeling, and chemical compliance across Canadian and U.S. regulations, and is an active leader in the chemical hazard communication community.
