Interim Labelling of products during COVID-19: Hand sanitizers, disinfectants, soaps and cleaning products

Author:  Preetha Prabhu

According to Statistics Canada, demand for hand sanitizer increased by 735% for the week ending March 14, 2020, relative to the same period last year. At the same time, the demand for disinfectants, household cleaners, hand and body soaps, and workplace cleaners rose considerably, as they are also effective in combating the spread of COVID-19.

In light of the unprecedented demand and urgent need for disinfectants and hand sanitizers during the COVID-19 pandemic, in March and April 2020, Health Canada implemented a number of interim policies to facilitate expedited and broad access to products that do not fully meet regulatory requirements (for example, labelling or package sizes) under the Food and Drugs Act, the Canada Consumer Product Safety Act and the Hazardous Products Act. A large number of companies that were not importing or manufacturing hand sanitizers and disinfectants have expressed interest in doing so to support the COVID-19 response efforts.

The interim policies, which have been updated over the last week, include facilitating the importation of disinfectants and hand sanitizers as well as cleaning products, hand soaps and body soaps.

Disinfectants and hand sanitizers

• In order to benefit from the interim measures, importers will be required to post bilingual label text on their website and provide sellers with a means to inform consumers, at the time of sale, of the website where bilingual label text is posted. This could be made available through a sticker applied directly to the products, or posters or signage with take-away pamphlets at the point of sale. Effective immediately, all new importers of these products through the interim measure must meet this requirement. All importers previously authorized must meet this requirement no later than June 8, 2020.
• Effective immediately, all new Canadian manufacturers of disinfectants and hand sanitizers must use bilingual labelling. Canadian manufacturers of hand sanitizers who are currently licensed and are using unilingual labelling under the interim measure will be required to adopt bilingual labeling no later than June 8, 2020.
• Health Canada will take a risk-based approach to addressing any non-compliance identified.

Cleaning products, hand soaps and body soaps

The interim policies apply to certain cleaning products (household and workplace), hand soaps and body soaps that are imported from the United States, and would ordinarily be non-compliant with Canadian label and safety information requirements, such as ingredient listing, unilingual labelling, imperial units of measure, and safety and cautionary wording.

• In order to benefit from the interim policies importers are required to provide sellers with a means to inform consumers or employers, at the time of sale, of the website where bilingual label text and, if applicable, bilingual safety data information is posted. This could be made available through a sticker applied directly to the products, or posters or signage with take-away pamphlets at the point of sale or use. Effective immediately, all new importers of these products through the interim policies must meet this requirement. All importers who have previously submitted a form are to meet this requirement no later than June 8, 2020.
• Canadian manufacturers of these products must use bilingual labels and safety information, if applicable.
• Health Canada will take a risk-based approach to addressing any non-compliance identified.

Reference:

Labelling of hand sanitizers, disinfectants, soaps and cleaning products in the context of the COVID-19 response - https://www.canada.ca/en/health-canada/services/drugs-health-products/natural-non-prescription/legislation-guidelines/statement-labelling-sanitizers-disinfectants-soaps-cleaners.html