The keys to labelling requirements in Canada
Cosmetic Labeling Obligations
Contact Information on Internal Labels: Requirements adjusted in April 2024 to include complete contact details.
Mandatory Notification to Health Canada: Every cosmetic product must be notified within ten days of its sale or any modification, including:
- Contact details on the internal label.
- The function of the cosmetic (whether it is to be rinsed off or left on).
- List of ingredients according to the INCI nomenclature.
- Name and address in Canada of the manufacturer or importer.Ensure all information is available in both French and English.
Prohibition of Sale Without Complete Information: It is prohibited to sell a cosmetic unless its internal label contains a phone number, an email address, a website address, a postal address, or any other information that enables communication with a contact person.
Want to learn more about the 2024 Canadian law updates?
Check out the regulatory amendment for cosmetics in Canada.
Principal Display Panel (PDP)
The displayed portion of the label, or the Principal Display Panel (PDP), must have the following information:
- Identity Statement
- Net Quantity of Contents
The remainder of the required cosmetic labelling information can be displayed on portions of the label other than the PDP, specifically, the Information Panels. The Information Panels must include:
- Name and Place of Business
- Warnings and Precautions
- Ingredients Declaration
Product Name or Identity
The identity statement indicates the nature and the use of the product.The product identity can be on the PDP in either English or French, as long as the other language is on one of the other panels.
Net Quantity
The net quantity declaration provides a weight, measure, or a numerical count of the product’s contents. Although the Cosmetic Regulations do not require a net quantity declaration, there are several requirements in the more general Consumer Packaging and Labelling Act and Regulations that still need to be adhered to.
Business Name
A cosmetic label should include the name and business address of the manufacturer or dealer. The name and address on the label must correspond to the name and address submitted with the Cosmetic Notification Form (CNF).
In the case where a product is manufactured or produced outside of Canada, there are several options for listing the identification of the manufacturer or dealer:
- Listing the manufacturer outside of Canada
- Listing the Canadian importer, preceded by “Imported by/Importé par” or “Imported for/Importé pour”
- Listing the geographic origin of the product adjacent to the Canadian dealer
Warnings and Precautions
When a cosmetic product can be associated with an avoidable hazard, the product can be sold under the condition that it includes warnings. These cosmetic warnings should describe how to use the product and when not to use it.
Most warnings are not explicitly prescribed in the Cosmetic Regulations. However, there are also specific regulations regarding warning statements for some specific products. These products include:
- Hair Dyes, Mercury-containing products, and Genital deodorants in pressurised containers
- Products in pressurised metal containers
- Flammable products in pressurised metal containers
- Mouthwashes
Ingredient Declaration
A cosmetic label must include an ingredients declaration, with the ingredients listed according to their INCI (International Nomenclature of Cosmetic Ingredients) name. In addition, Health Canada has set out specific requirements for Botanical ingredients.
In some specific cases, where it may be difficult to include the Ingredient Declaration on the product packaging, a tag, tape or card may be affixed.
Additional considerations regarding cosmetic labelling in Canada
The Food and Drugs Act and the Cosmetic Regulations govern the classification, composition, safety, and labelling of cosmetic products. These regulations also allow for a designated Health Canada inspector to inspect:
- Cosmetic Products
- The locations where cosmetic products are manufactured or stored
- Any labelling and advertising material related to a cosmetic product
It is important to note that, in Canada, the term “labelling” does not just refer to the sticker on a package, or the box it may come in. A product’s labelling also includes other written, printed, or graphic matter related to the product. This ranges from a product’s physical packaging to the content on a brand’s website.
Other things need to be considered when labelling a cosmetic product:
- Expiration Dating
There is currently no requirement to list an expiration date on a Canadian cosmetic product. However, cosmetic companies are responsible for the safety of their product. In order to ensure that their cosmetic product is being safely used, many brands choose to list an expiration date.
- Language
Canada is a French and English bilingual country, as such, there are specific language requirements that reflect this. The Consumer Packaging and Labelling Act and Regulations describe which portions of the label must be listed in both French and English. This includes:
- The product’s identity
- The net quantity declaration
- The identity and place of business of the importer or manufacturer
However, it is also worth noting that the Quebec Charter of the French Language defines French as the only official language of Quebec. This bill creates the requirement for all information on a product label to be available in French, and further specifies that the French portion of the label must be of equal or greater prominence to other languages.
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