Product Packaging Regulations in Canada: A Quick Guide

This guide serves as a quick introduction to compliance requirements for consumer product packaging and packaging labelling in Canada. We also share a methodology that you can use to identify relevant packaging acts and regulations for your products.

Consumer Packaging and Labelling Act

The Consumer Packaging and Labelling Act sets packaging and labelling requirements for consumer products sold in Canada. It specifically mentions prepacked products and provides the following definitions:

Prepackaged product means any product that is packaged in a container in such a manner that it is ordinarily sold to or used or purchased by a consumer without being re-packaged; (produit préemballé)

Product means any article that is or may be the subject of trade or commerce, but does not include land or any interest or right in land; (produit)

Note that certain product types are exempt from the Consumer Packaging and Labelling Act. Examples include food and medical devices. Note that such products can be subject to other packaging and packaging labelling requirements.

Who is covered?

The Consumer Packaging and Labelling Act refers to “dealers”, which includes the following entities:

• Retailers
• Manufacturers
• Processor and producers
• Importers
• Companies packaging or selling products

Prohibited practices

The Consumer Packaging and Labelling Act contains several prohibited practices concerning packaging and labelling. Below follows an overview:

1. Products cannot be sold or advertised unless the packaging label contains the net quantity based on the CPLA or either of the following:

• Numerical count, or
• Unit of measurement set out in Schedule I to the Weights and Measures Act

2. The label must contain any false or misleading claims, such as:

• Incorrect or misleading declaration of quantity
• Incorrect or misleading representation of the packed contents
• Incorrect descriptions or visual representations of the type, quality, performance, function, origin, or method of manufacture

Packaging labelling

Section 10 of the Consumer Packaging and Labelling Act specifies the following:

1. Net quantity must be specified according to the specified requirements

2. Manufacturer identity and principal place of business*

3. Product identity (common or generic name, or functionality)

4. Information related to the following (as may be prescribed):

• Nature
• Quality
• Age
• Size
• Material content
• Composition
• Geographic origin
• Performance
• Use
• Method of manufacture

*The Consumer Packaging and Labelling Act states that this can refer to the manufacturer of the product, or the company for whom the product was manufactured.

Consumer Packaging and Labelling Regulations

The Consumer Packaging and Labelling Regulations are made under the Consumer Packaging and Labelling Act and set more specific packaging and labelling requirements.

Here are some important requirements that can be found in the regulation:

Bilingual Requirements

---

(2) All information required by the Act and these Regulations to be shown on the label of a prepackaged product shall be shown in both official languages, except that the identity and principal place of business of the person by or for whom the prepackaged product was manufactured, processed, produced or packaged for resale may be shown in one of the official languages.

---

1. Label information (with some exceptions) must be shown in both official languages.

2. Official languages mean the English language and the French language.

Detailed requirements concerning English and French language packaging labelling can be found in section 6 of the Consumer Packaging and Labelling Regulations.

Label placement and information

1. The label must be affixed to the packaging that is displayed for sale to the consumer.

2. The following information must be displayed on the label:

• Net quantity
• Product identity (common or generic name, or functionality)
• Other information required by the act and regulations
• Company identity and principal place of business

Formats and units

Detailed requirements concerning label formats (i.e., sizes) and units can be found in the following sections:

14 – Size of Type in Which Information to Be Shown
17 – Declaration of Net Quantity
19 – Exemption from Metric Net Quantity Declaration and Type Size Requirement
21 – Manner of Declaring Net Quantity
24 – Units of Measurement

Imported products

---

(2) Where a prepackaged product that is wholly manufactured or produced in a country other than Canada has applied to it, whether in Canada or elsewhere, a label that shows the identity and principal place of business of the person in Canada for whom the prepackaged product was manufactured or produced for resale, the identity and principal place of business of that person shall be preceded by the words “imported by” (“importé par”) or “imported for” (“importé pour”), as the case may be, unless the geographic origin of the prepackaged product is stated on the label.

---

1. The label must specify if a product is imported and by which company.

2. Two terms can be used, and the statement must be written in English and French.

Note: Additional requirements related to product names and other terms can be found in sections 30 and 31, under name and other information. I also suggest that you read the Guide to the Consumer Packaging and Labelling Act and Regulations on the Government of Canada website.

Product Specific Packaging Regulations

Some products sold in Canada are subject to product-specific regulations that also set requirements concerning packaging. Here are two examples:

Consumer Chemicals and Containers Regulations

Containers that contain consumer chemicals must be child-resistant and meet one of the following standards:

• CSA-Z76.1
• ISO 8317
• 16 CFR 1700.20

Verifying compliance with these generally requires testing. Note that the regulation also sets additional requirements concerning containers.

Vaping Products Labelling and Packaging Regulations

Here are some examples of packaging requirements set under this regulation:

1. Ingredients must be listed on the packaging for all vaping substances in English and French

2. The ingredients list must be affixed to the display surface of the packaging

3. Certain containers containing nicotine must be child-resistant

FAQ

Do packaging labels need to be provided in English and French?

Yes, providing label information in both English and French is required under the Consumer Packaging and Labelling Regulations and various other product regulations that set packaging and packaging labelling requirements.

Note that some information, such as units, is not “translated”.

How do we know which packaging regulations apply?

This is a methodology that you can use as a starting point:

1. Are you selling a consumer product?

If yes, then the following may apply:

• Consumer Packaging and Labelling Act
• Consumer Packaging and Labelling Regulations

2. Is your product exempt from the Consumer Packaging and Labelling Act or Consumer Packaging and Labelling Regulations?

If yes, then you may need to comply with packaging and packaging labelling requirements in other regulations.

3. Is your product subject to one or more product-specific regulations?

If yes, then you need to determine if said regulations set packaging and packaging labelling requirements

Note that an individual product can be subject to packaging and packaging labelling requirements under more than one act and regulation.