CCCR vs CPSC: Canadian vs US Consumer Labelling
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This document provides an overview of the differences between Canadian (CCCR) and US (CPSC) consumer product labeling regulations. It summarizes the key hazard categories and requirements under each regulation. The CCCR is more prescriptive, requiring specific hazard statements and symbols, while the CPSC allows custom statements. Differences include language requirements, hazard determination methods, and exemptions. Combining US and Canadian labels is not recommended due to potential non-compliance issues. Additional details are provided on California Prop 65, VOC regulations, and New York ingredient disclosure rules.
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CCCR vs CPSC: Canadian vs US Consumer Labelling
- 1. dell tech laboratories ltd. 1 CCCR vs CPSC: Canadian vs. US Consumer Labeling
- 2. dell tech laboratories ltd. 2 Kirsten Alcock B.Sc. Manager, Product Safety Group kirsten@delltech.com 519.858.5074 Ivy Tang B.S.c. Product Safety Specialist itang@delltech.com 519.858.5021 ext 2043
- 3. dell tech laboratories ltd. 3 Dell Tech Laboratories Ltd. Dell Tech Product Services • US/CAN consumer labeling consultation • Claims support and Performance Testing • Green Seal, EcoLogo, EPA Safer Choice • US/CAN GHS SDSs • E-liquids and vaping devices • Cannabis labeling and packaging • Cosmetic Notifications, Pesticide registration, Medical Device labeling • Non-prescription Drugs and NHP regulations • Translation of Technical Documents • Transportation Consulting
- 4. dell tech laboratories ltd. 4 Disclaimer The information provided in this webinar is not legal advice. If you are uncertain about the interpretation of the CCCR and CPSC regulations, please contact Health Canada and the Consumer Product Safety Commission directly. If you are concerned about confidentiality, Dell Tech can contact these agencies on your behalf. Health Canada Address Locator 0900C2 Ottawa, Ontario K1A 0K9 Email: Info@hc-sc.gc.ca Telephone: 613-957-2991 Toll free: 1-866-225-0709 Consumer Hotline and General Information Phone: (800) 638-2772; TTY (800) 638-8270 Hours: Mon.-Fri. 8 a.m. to 5:30 p.m.; messages can be left anytime. Fax: (301) 504-0124 and (301) 504-0025
- 5. dell tech laboratories ltd. 5 Outline of Presentation 1. What is/is not a chemical consumer product 2. Consumer vs. workplace regulations- GHS, SDSs, retailers 3. CCCR regulation overview 4. CPSC regulation overview 5. Differences between US and CAN consumer regulations 6. Additional US consumer labeling requirements 7. CCCR ‘Checklist’ 8. Question period
- 6. dell tech laboratories ltd. 6 What Is A Consumer Product? CANADA: Means a product, including its components, parts or accessories, that may reasonably be expected to be obtained by an individual to be used for non-commercial purposes, including for domestic, recreational and sports purposes, and includes its packaging. USA: Means any article, or component part thereof, produced or distributed for sale to a consumer for use in or around a permanent or temporary household or residence, a school, in recreation, or otherwise, or (ii) for the personal use, consumption or enjoyment of a consumer in or around a permanent or temporary household or residence, a school, in recreation, or otherwise; but such term does not include.. [pesticides, drugs, food, firearms, etc]
- 7. dell tech laboratories ltd. 7 Hand soap- Cosmetic Chemical Consumer Products Detergent Glass cleaner Diffuser Detergent- pods Air freshener Car wax Drug Hockey puck- Manufactured Article Sunscreen- NHP or Drug Pesticide
- 8. dell tech laboratories ltd. 8 Consumer vs. GHS Regulations CCCR symbols GHS symbols Hazard Language Hazard Language Do not get in eyes. If in eyes, rinse with water for 15 minutes. Keep out of reach of children. Wear eye protection. IF IN EYES: Rinse cautiously with water for several minutes. Remove contact lenses, if present and easy to do so.
- 9. dell tech laboratories ltd. 9 Consumer vs. GHS Regulations Packaging Test Methods example Leak test Flame projection Packaging Test Methods example Ignition distance test Heat of combustion
- 10. dell tech laboratories ltd. 10 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 CPSC (Consumer Product Safety Commission). …two SEPARATE regulations!
- 11. dell tech laboratories ltd. 11 CCCR Five main classification categories: 1. Toxic (Very Toxic, Toxic, Harmful) 2. Corrosive (Very Corrosive, Corrosive, Irritant) 3. Flammable (Spontaneously combustible, Very Flammable, Flammable, Combustible) 4. Quick Skin-Bonding Adhesives 5. Pressurized Containers CCCR is very prescriptive. Once the classification is determined, simply use the prescribed hazard statements and symbols on your label.
- 12. dell tech laboratories ltd. 12 CCCR CCCR 2001 has 62 sections followed by 4 Schedules, which include: • General requirements (record keeping, data sources, hazard categories) • Container performance, design. Includes requirements and exemptions for child-resistant containers. • Presentation of information (technical specifications such as print, language, color contrast, label legibility, location and order of info on Main Display Panel (MDP) • Classification and determination for all five categories and sub categories • Test methods
- 13. dell tech laboratories ltd. 13 CCCR Steps to Labeling Compliance • Is the product exempt from CCCR 2001? • Determine which hazard categories the product falls under, if applicable. • Determine the main display panel (MDP) of the container. • From here, simply refer to the regulations or reference manual to determine the required labeling elements (symbols, statements) as well as the print specifications (minimum size of font) for the require
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- 17. dell tech laboratories ltd. 17 CPSC Classification categories: • Highly toxic (acute) • Toxic (acute) • Chronic toxic (carcinogen, developmental, reproductive) • Corrosive • Irritant • Strong sensitizers • Extremely flammable • Flammable • Combustible • Pressurized container CPSC is not as prescriptive as CCCR 2001.
- 18. dell tech laboratories ltd. 18 CPSC “Not prescriptive”…? • Only 1 symbol is ever used, for “Highly Toxic” substances: • DANGER is the only signal word required for extremely flammable, corrosive, or highly toxic substances. CAUTION or WARNING can be use for all other hazardous substances. • You may create your own precautionary and first aid statements, as well as instructions for handling and storage, if appropriate. • Must have “Keep out of reach of children’ (or an equivalent) when appropriate. • Must have instructions to read cautionary material elsewhere on the label if there is more than one principal display panel.
- 19. dell tech laboratories ltd. 19 CPSC Products requiring special labeling The CPSC has a Specific Toxic Substances list which necessitate additional labeling. It includes: • 10% w/w diethylene glycol, ethylene glycol • 10% w/w petroleum distillates including mineral seal oil, gasoline, naphtha, Stoddard solvent, etc. • 4 % w/w methanol • Charcoal • Art materials • ….and more These must have the signal word DANGER, the statement “Harmful or fatal if swallowed” and “Call physician immediately.”
- 20. dell tech laboratories ltd. 20 CPSC Minimum font requirements Area of main display surface in square inches 0 - 2 >2-5 >5-10 >10-15 >15-30 >30 Type size in inches Signal word 3/64 1/ 16 3/32 7/64 1 / 8 5/32 Statement of hazard 3/64 3/64 1/ 16 3/32 3/32 7/64 Other cautionary material 1/32 3/64 1/ 16 1/ 16 5/64 3/32
- 21. dell tech laboratories ltd. 21 CCCR vs. CPSC: Some differences Language Requirements • Canada needs Canadian French labeling in addition to English. Hazard Categories • Chronic hazards (carcinogens, neurotoxins, developmental or reproductive) found in CPSC but not CCCR • Sensitizer classification not required for CCCR Hazard labeling • Canada uses Signal Words: EXTREME DANGER, DANGER, CAUTION • US uses Signal Words: DANGER, WARNING, CAUTION • Statements are prescribed for CCCR but not necessarily CPSC • Symbol are different
- 22. dell tech laboratories ltd. 22 CCCR vs. CPSC: Some differences Determination of Toxicity • Inhalation toxicity for CPSC uses units mg/L per ONE hour. • Inhalation toxicity for CCCR uses units mg/L per FOUR hours. • Oral toxicity for CPSC cuts off at 5000 mg/kg • Oral toxicity for CCCR cuts off at 2000 mg/kg Labeling exemptions • CCCR: small container exemption based on MDP (< 35cm²) • CPSC: no small container exemption. Suggests using fold-back labels, pull off tags, etc. which is not allowed for CCCR. Consumer vs. workplace GHS • CCCR labeling can replace Canadian GHS IF in certain instances, but GHS cannot replace CCCR. • CPSC labelling can replace US GHS IF it can be proven that frequency and duration of use in workplace is equivalent to that of a consumer (29 CFR 1910.1200(b)(6)(ix))
- 23. dell tech laboratories ltd. 23 Can I Combine US/CAN Labels? YES…but we do NOT recommend it. • Very difficult unless product is non-hazardous • US/CAN consumers are not familiar with the other’s language/symbols, thus causing confusion and putting consumer safety in jeopardy • Marketing issues for Canadian market due to chronic classification • Bilingual requirement = less available space • Run the risk of non compliance, potentially resulting in stop distribution or recall.
- 24. dell tech laboratories ltd. 24 Additional US Consumer Labeling Requirements • California Prop 65 • Chemicals found on the Prop 65 list must be disclosed • New pictogram and signal word required • Specific safe harbor statements required • https://delltech.com/blog/california-prop-65-compliance-deadline-2/ • VOC/CARB regulations • California Air Resources Board (CARB) has issued regulations on limiting VOCs in consumer products • Determine which category applies to your product and calculate VOC content to see if limit is exceeded. • New York (DEC) Product Information Disclosure Program • Enforcement delayed until January 1st 2020 • Disclosure in question is for intentionally added ingredients other than fragrances, and for non- functional ingredients present above trace quantities • The regulation will cover products related to consumer cleaning (soaps, detergents, etc.) • https://delltech.com/blog/ingredient-disclosure-regulations-update-ny-dec-household-cleansing-product-information-disclosure- program/
- 25. dell tech laboratories ltd. 25 Joe McCarthy, B.Sc. Manager, Laboratory Services Group Senior Regulatory Affairs Specialist jmccarthy@delltech.com | 519.858.5024
- 26. dell tech laboratories ltd. 26 CCCR Checklist A full, thorough review and justification of classification in accordance with the CCCR 2001.
- 27. dell tech laboratories ltd. 27 Question Period
- 28. dell tech laboratories ltd. 28 Thank You! 100 Collip Cir #220, London, ON N6G 4X8 (519) 858-5021 delltech.com
Editor's Notes
- What services we offer Focus on consumer labeling services Brief overview of the presentation- what we will cover, length of presentation (20 min) + 10 min Q/A
- 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. Note that consumer products may also fall under additional regulations. For example, the paint set may be subject to art materials regulations, or a candle would be subject to the candle regulations.
- 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.
- Talk about the two regulatory bodies, CCPSA vs CPSC Perhaps brief couple sentences on history (when they were established) Emphasize that they are TWO separate regulations- a bottle of x in Canada must be labeled different than the same bottle of x in the US, even if they are sold at the same store (eg. Walmart)
- 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 Consumer Product Safety Act, hazardous consumer products may be toxic, corrosive, an irritant, a strong sensitizer, flammable, combustible, or any combination of the above. CPSC 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.
- The most prominent different between the two countries’ consumer labeling regulations is the requirement for bilingual (French and English) labeling in Canada. Note that Parisian French is different. Ensure you are using a translator knowledgeable in Canadian French. 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.
- Dell Tech logo and contact information Slides will be put on slide share Will slides be available/audio recorded? Email us for any further questions or a quote.