Written on: June 1, 2025 by Cassandra Taylor
In SPRAY’s April feature article discussing the North American regulatory landscape, I briefly touched on the fact that Health Canada is actively consulting on consumer product labeling initiatives under the Canada Consumer Product Safety Act (CCPSA) that could introduce new mandatory hazard labeling for chronic health risks. This month’s column will dive deeper into what these consultations look like, the outcomes so far and potential future impacts.
Label regulations for hazardous products sold to consumers in Canada fall under different laws than those for hazardous products used in workplaces. Consumer products are regulated under the Consumer Chemicals & Containers Regulations, 2001 (CCCR), known colloquially as “the triple CR.” The CCCR is part of the CCPSA and sets out safety requirements that address acute human health and physical hazards, including acute toxicity, corrosivity/irritation, flammability, pressurized containers and quick skin-bonding adhesives. The CCCR outlines labeling requirements, container standards, prohibitions and restrictions for dangerous chemical products sold to consumers.
The CCCR does not address certain human health hazards of concern (HHHOCs) associated with consumer chemical products. HHHOCs include carcinogens, mutagens, reproductive toxicants, specific target organ toxicity and respiratory and skin sensitizers.
On July 11, 2023, Health Canada published a Notice of Intent to consult stakeholders on a proposal to introduce requirements for HHHOCs linked to substances found in consumer products.
The Notice of Intent introduced two possible regulatory approaches. Option 1 would be a hybrid classification and labelling system that merges the existing CCCR requirements with elements of the Globally Harmonized System of Classification & Labeling of Chemicals (GHS). Option 2 would involve replacing the current labeling system with a risk-based GHS framework.
Seventy-one percent of stakeholders indicated that GHS is a reasonable and effective tool for addressing HHHOCs. About twice as many stakeholders expressed a preference for the risk-based GHS framework (Option 2) over the hybrid system (Option 1).
In addition to consulting with industry stakeholders, Health Canada commissioned a public opinion survey to assess consumer understanding and preferences regarding hazard symbols, the effectiveness of hazard statements and the importance of risk and hazard information. The results revealed low public knowledge of the two GHS pictograms representing HHHOCs—41% correctly identified the meaning of the health hazard symbol and just 18% correctly identified the exclamation mark symbol. These findings highlight the need for a robust public education campaign to support any transition to a new labeling framework.
After evaluating the feedback from stakeholders and the public opinion research, Health Canada indicated its intent to explore a risk-based framework for consumer chemical products based on GHS. This framework would address both acute health hazards and physical hazards, as well as HHHOCs. Health Canada is also considering the adoption of certain GHS guidelines for chronic hazard labeling, such as Annex 5, “Consumer Product Labeling Based on the Likelihood of Injury,” while retaining some of the risk-based exclusions currently found in the CCCR.
The push for a risk-based framework reflects the reality that consumer exposure to hazardous chemicals is generally less intensive than occupational exposure. For instance, a professional window cleaner may use a window cleaning product for 40 hours per week, while a consumer might only use the same product for 30 minutes once a week. This difference in usage patterns justifies differentiated approaches to hazard communication.
Health Canada has outlined several objectives for its proposal: to enhance health and safety protections for consumer chemical products by updating label requirements for acute hazards, physical hazards and HHHOCs; to explore improved alignment between consumer and workplace product requirements to reduce the regulatory burden for companies supplying both markets; to continue applying a consistent, risk-based approach for classifying and labeling hazardous chemicals; and to align more closely with international jurisdictions such the EU and UK that have already adopted GHS for consumer products. Alignment with the U.S. Federal Hazardous Substances Act (FHSA) was considered, but the FHSA’s limited emphasis on hazard symbols makes it less suitable, especially given the Canadian public’s support for the use of symbols in hazard communication.
It will be important to see how Health Canada balances its objectives with existing classification criteria. For example, adopting GHS cut-offs could reduce current protection levels. Under CCCR, the cut-off for classifying mixtures as irritants is 5%, whereas under GHS it is 10%, which could cause some “Irritant” mixtures to be de-classified. Additionally, when the median lethal dose (LD50 or LC50) of one or more ingredients in a chemical product is unknown and cannot be estimated, the additivity calculation must use the LD50 or LC50 of the most toxic known ingredient present at a concentration of 1% or greater as a substitute. This substitution method is not a requirement found under GHS, which could result in less stringent classification results compared to CCCR methods. On the other hand, the GHS does mandate on-label disclosure of the percentage of ingredients with unknown toxicity, which may be incorporated into the updated CCPSA scheme to enhance consumer protections.
Once the new system comes into force, companies selling products to consumers will need to re-evaluate the hazards of their existing stock, regardless of the current hazard classification. Products currently sold as unregulated may, in the future, fall under one or more of the new HHHOC categories, triggering additional label requirements. Further stakeholder consultations on various aspects of the proposed risk-based GHS framework are planned throughout 2025 and 2026. Health Canada is encouraging all interested parties to submit feedback. This significant regulatory overhaul will likely take several years to implement, and a transition period is expected to allow industry time to update consumer product labels and ensure compliance. SPRAY
