October 1999
1. Exemptions
2. Definitions
1. False and Misleading Representations
2. Mandatory Label Information
1. Fill Level
This guide provides an outline to the packaging and labelling requirements for prepackaged non-food consumer products subject to the federal ConsumerPackagingandLabellingAct and the ConsumerPackagingandLabelling Regulations. The full text of the Act and Regulations should be consulted for a more detailed understanding of these provisions.
The administration and enforcement of the Act and Regulations, as they relate to non-food products, is the responsibility of the Competition Bureau, Industry Canada. Administration and enforcement of the Act and Regulations, as it relates to food products, is the responsibility of the Canadian Food Inspection Agency (CFIA). For information on the labelling of food products, contact the CFIA at 1-800-442-2342.
For further clarification of the requirements, contact the Competition Bureau:
Information
Centre
E-mail: compbureau@cb-bc.gc.ca
1. Exemptions | Subsection3(2)Act Section3Regulations |
The following products are exempt from all requirements of the ConsumerPackagingandLabellingAct and Regulations:
Product | Section Reference | ||
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Act 3(2) | ||
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Regs 3(1) | ||
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Regs 3(2) | ||
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Regs 3(2) | ||
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Regs 3(3) | ||
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Regs 3(4) | ||
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Regs 3(5) |
2.1 Container |
Section2Act |
The term "container" means a receptacle, package, wrapper or confining band in which a product is offered for sale but does not include package liners or shipping containers or any outer wrapping or box that is not customarily displayed to the consumer.
2.2 Dealer |
Section2Act |
The "dealer" is the person who is a retailer, manufacturer, processor or producer of a product, or a person who is engaged in the business of importing, packing or selling a product.
2.3 Label |
Section2Act |
A "label" is any label, mark, sign, device, imprint, stamp, brand, ticket or tag.
2.4 Prepackaged Product |
Section2Act |
The term "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.
2.5 Principal Display Panel |
Section2Regulations |
The term "principal display panel" means,
2.6 Principal Display Surface |
Section2Regulations |
The term "principal display surface" means,
1. False and Misleading Representations |
Section7Act |
Section 7 of the Act prohibits false and misleading representations relating to prepackaged products. All information on a package, whether in symbols or words, must be neither falsenor misleading to the consumer.
Misleading representations can come in many forms. These include, but are not limited to, the following:
1.1 Net Quantity Representations |
Subsections7(2)(a),7(3)Act Sections 38,39(4),Schedule I Regulations |
Any representation which gives the impression that a package contains more product than is actually contained in it may be a violation of this section.
1.2 Product Composition Representations
Any representation which deceives a consumer with respect to the composition of a product may be a violation of this section.
1.3 Other Descriptions or Illustrations
The product must conform with any other claims made which may, for example, relate to its type, quality, performance, function, origin, or method of manufacture. Some examples of claims include:
Quality
- Refurbished telephones being represented as "new"
Method of Manufacture
- A product being represented as "hand made"
Origin
- "Made in Canada"
Function
- Environmental claims such as biodegradable, recyclable
Performance
- A product which claims to improve gas mileage in a car
-
Minimum system requirements to run a software package
- Freezing point of
windshield washer antifreeze
Capacity
- A 2 litre kettle
2. Mandatory Label Information | Section10Act |
There are three mandatory statements which must be shown on a label. The regulations specify the manner and location in which the following statements must appear:
Example of Liquid and Viscous Products with Mandatory Label Information:
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2.1 Product Identity Declaration
The product identity declaration is a statement of the product's common or generic name, or it may be defined in terms of its function.
2.1.1 Definition | Section10Act Section30Regulations |
The product indentity declaration is a statement of the product's common or generic name, or it may be defined in terms of its function.
2.1.2 Language | Subsection6(2)Regulations |
The product identity must be shown in English and French. In some cases a product identity declaration is bilingual in and of itself, such as "cologne" or "serviettes".
2.1.3 Location | Section12Regulations |
The product identity must be shown on the "principal display panel" of the package. Refer to Section 2.5 for the definition.
Where there are two or more principal display surfaces that are of equal size and prominence as the principal display panel, the product identity and net quantity declarations can be shown in only one of the official languages on one surface if such information is shown in the other official language on one of those other surfaces.
2.1.4 Type Face | Section15Regulations |
There is no restriction on the type face which may be used. However, this information must be easily legible to the consumer.
2.1.5 Type Height | Sections14,15&16Regulations |
The type height must be a minimum of 1.6 mm (1/16 inch) where upper case letters only are used. If upper and lower case, or only lower case letters are used, the type height should be measured in relation to the lower case "o". For example, whether the product identity is shown as "SHAMPOO", "Shampoo" or "shampoo", the type height for the letter "o" must be a minimum of 1.6 mm.
In certain cases, where the container has a principal display surface of 10 square centimetres (1.55 square inches) or less, the minimum type height may be reduced to 0.8 mm (1/32 inch). Refer to section 16 of the Regulations for details.
2.1.6 Exemptions | Subsections5(1)&5(3Regulations |
Under certain conditions, when the product is usually sold by count and is packaged in such a way that it is visible and identifiable, or the label has an accurate pictorial representation of the package contents, an exemption from declaring the product identity may apply. Please refer to subsections 5(1) and 5(3) of the Regulations for details.
2.2.1 Manner of Declaring | Subsection4(1)Act Sections21,22,23& 36Regulations |
Generally the net quantity should be expressed:
However, if there exists an established trade practice with respect to the manner of declaring the net quantity, it must be expressed in accordance with such established trade practice.
Example of Product Sold by Length:
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Where a product is declared by count, and the package contains only one unit, the net quantity may be considered declared by the product identity declaration in its singular form. Where this option is exercised, it is advisable to display the product identity using the minimum type height specified for the net quantity declaration (Please refer to Table 1).
Example of Label for a Product not Requiring Net Quantity Declaration:
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Certain exceptions to these general rules are also prescribed by the Regulations:
Example of Aerosol Label:
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Examples of Labels for Products Sold by Sheets and Rolls:
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The use of an additional non-metric quantity declaration is permitted providing that it is not false or misleading to the consumer.
2.2.2 Language | Subsection 6(2) Regulations |
The net quantity declaration must be in English and French. Please note that a net quantity declaration using only numbers and metric symbols is considered bilingual.
2.2.3 Location and Manner of Presentation | Subsection4(2)Act Sections12&17 Regulations |
The net quantity declaration must be displayed clearly and prominently on the "principal display panel" (refer to Section 2.5 for definition) of the label and must be easily legible and in distinct contrast to any other information or representation shown on the label. See also Section 2.1.3.
Example of Label on Principal Display Panel:
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2.2.4 Type Face | Section14Regulations |
The numerical portion of the net quantity declaration must be in bold face type. There is no restriction on type face for any other information included in the net quantity declaration (i.e. units of measurement statements, abbreviations, symbols, etc.) However, this information must be easily legible to the consumer.
2.2.5 Type Height | Section14Regulations |
The numerical portion of the net quantity declaration must have a type height not less than the minimum size outlined in Table 1.
(a) Table 1 - Minimum
Type Heights
Area of Principal Display Surface* |
Minimum Type Height |
Not more than 32 cm2 (5 in2) | 1.6 mm (1/16 in) |
More than 32 cm2 (5 in2) but not more than 258 cm2 (40 in2) | 3.2 mm (1/8 in) |
More than 258 cm2 (40 in2) but not more than 645 cm2 (100 in2) | 6.4 mm (1/4 in) |
More than 645 cm2 (100 in2) but not more than 25.8 dm2 (400 in2) | 9.5 mm (3/8 in) |
More than 25.8 dm2 (400 in2) | 12.7 mm (? in) |
*Refer to Section 2.6.
All other information in this declaration must have a type height of not less than 1.6 mm (1/16 inch) where upper case letters only are used. If upper and lower case, or only lower case letters are used, the type height should be measured in relation to the lower case "o".
2.2.6 Units | Section27Regulations |
The use of a word or symbol for the unit of measurement is acceptable. To ensure uniformity, the following table has been provided. Column 1 of Table 2 shows the correct spelling of the unit of measurement in English and French. Column 2 shows the acceptable symbol. Note that the symbols are considered bilingual. However, if a word is used (e.g. gram), then it is necessary to show the equivalent word (gramme) in French.
(a) Table 2 - Units of Measurement
COLUMN 1 | COLUMN 2 | |
English | French | Symbol |
gram | gramme | g |
kilogram | kilogramme | kg |
litre | litre | L, l, l |
millilitre | millilitre | mL, ml, ml |
centimetre | centimètre | cm |
metre | mètre | m |
square centimetre | centimètre carré | cm2 |
square metre | mètre carré | m2 |
cubic centimetre | centimètre cube | cm3 |
cubic decimetre | décimètre cube | dm3 |
cubic metre | mètre cube | m3 |
* the use of the symbols "L" and "mL" is preferred.
Examples: | |||
Correct |
Incorrect |
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g | g. | ||
g | G | ||
g | gm | ||
g | gms |
Example: |
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Correct |
Incorrect |
Incorrect |
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500 g | 500g | 500 g |
The type of unit which should be used depends on the net quantity of product. Table 3, which follows, indicates the correct unit to use for a variety of measures and sizes.
Type of Measure |
Net Quantity of Product |
Units |
volume | less than 1000 mL | mL, ml, ml |
1000 mL or more | L, l, l | |
weight | less than 1000 g | g |
less than 1000 g (catchweights or products prepackaged from bulk at retail) | g or decimal of a kg | |
1000 g or more | kg | |
length | less than 100 cm | cm or mm |
100 cm or more | m | |
area | less than 100 cm2(1 dm2) | cm2 |
1 dm2 or more but less than 100 dm2 (1 m2) | dm2 | |
1 m2 (100 dm2) or more | m2 | |
cubic | less than 1000 cm3 (1 dm3) | cm3 |
1 dm3 or more but less than 1000 dm3 (1 m3) | dm3 | |
m3 (1000 dm3) or more | m3 |
2.2.7 Precision of number | Sections25&26Regulations |
In general, the number used must be shown to three figures in the decimal system. Any final zeros to the right of the decimal point, however, need not be expressed. There are three exceptions permitted:
(a) quantities below 100 grams, millilitres, cubic centimetres, square centimetres, or centimetres may be shown to two figures. Any final zeros to the right of the decimal point similarly need not be expressed.
Examples:
Correct |
Permissible |
Incorrect |
454 g | 85.1 g | 53.592 g |
85 g | 85.05 g |
(b) if the quantity is less than one, it may be shown in either the decimal system with the figure zero preceding the decimal point, or in words.
(c) a specific variation of (b) permits 500 grams and 500 millilitres to be shown as being one-half kilogram and one-half litre respectively. These declarations may also be declared in decimal figures or in words.
500 grams may be shown correctly as: | |
500 g 0.5 kg |
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one-half
kilogram one-half kg |
un demi
kilogramme un demi kg |
500 millilitres may be correctly shown as: | |
500 mL 0.5 L |
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one-half
litre one-half L |
un demi
L un demi litre |
Rounding off numbers - Where it is necessary to round-off the metric declaration to the specified number of figures, the procedure is as follows:
Example:
984.50 | becomes | 984 |
985.50 | " | 986 |
68.50 | " | 68 |
7.450 | " | 7.4 |
7.550 | " | 7.6 |
Example:
984.7 | becomes | 985 |
984.51 | " | 985 |
68.6 | " | 69 |
6.88 | " | 6.9 |
Note: Dealers are advised that when the value is rounded up, there may be a need to increase the package contents to meet the new declared quantity.
2.2.8 Exemptions | Subsections5(2),5(3)&19(2)Regulations |
A prepackaged non-food product that is visible, identifiable and sold by count, may be exempted from the net quantity declaration. Similarly, a non-food product that is normally sold by count and is packaged as a set, may be exempt from the net quantity declaration if there is an accurate pictorial representation of the product's contents on the principal display panel. Please refer to sections 5(2) and 5(3) of the Regulations for details.
Examples of Visible, Identifiable, and Easily Counted Products:
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Non-food prepackaged products that are packaged from bulk on a retail premise with the net quantity of the product shown clearly on the principal display panel of the label in terms of a Canadian unit, are exempt from the metric net quantity declaration and size of type requirements. Please refer to section 19(2) of the Regulations for details.
2.3 Dealer's Name and Principal Place of Business
2.3.1 Definition | Section10Act |
A declaration showing the identity and principal place of business of the person by or for whom the prepackaged product was manufactured or produced for resale is required. This is interpreted to mean a name and address sufficient for postal delivery.
2.3.2 Language | Subsection6(2)Regulations |
The dealer's name and principal place of business may be shown in either English or French.
2.3.3 Location | Section13Regulations |
This declaration can be located anywhere on the outside surface of the package except the bottom.
2.3.4 Type Face | Section15Regulations |
There is no restriction on the type face which must be used, but it must be easily legible to the consumer.
2.3.5 Type Height | Section15Regulations |
Must be a minimum of 1.6 mm (1/16 inch) when upper case letters only are used. If upper and lower case, or only lower case letters are used, the type height should be measured in relation to the lower case "o".
2.3.6 Imported Goods | Section31Regulations |
Where a prepackaged product is wholly manufactured or produced in a country other than Canada, the application of any one of the following formats will satisfy the requirements of the Regulations:
Example of Label for an Imported Product:
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(a) Bulk Imports
Where a product is wholly produced in a country other than Canada, imported into Canada in bulk, packaged in Canada (other than by a retailer) and then labelled, it must be labelled in the same manner as described in any one of the above formats.
Country of origin marking is not a requirement of the ConsumerPackagingandLabellingAct, however, the Canada Customs and Revenue Agency requires a country of origin marking on specific goods. For further information, prospective importers should contact their local customs office. A listing of the customs offices can be found on the Canadian Border Services Agency.
2.3.7 Other | Subsection 31(1) Regulations |
Where any reference, direct or indirect, is made on a label to the place of manufacture or printing of the label or container and not to the place of manufacture of the product, the reference must be accompanied by an additional statement indicating that the place of manufacture refers only to the label or container.
2.4.1 Bilingual Labelling | Section 6 Regulations |
Subsection 6(2) of the ConsumerPackagingandLabellingRegulations requires that "all" mandatory label information be shown in English and French except the dealer's name and address which can appear in either language.
Any label information in addition to the mandatory requirements discussed above (i.e. directions for use, promotional statements, etc.) does not have to appear in a bilingual manner. Dealers are, however, encouraged to include such information in English and French.
Limited exemptions from the bilingual labelling requirement are provided in subsections 6(3) and 6(7) of the Regulations for test market products (temporary exemption of up to one year; see Section 2.4.2 below), local products, and specialty products. In such instances, the applicable mandatory label information may appear in either official language.
Subsection 6(9) of the Regulations provides an exemption from the bilingual labelling requirements when the product requires knowledge of a language for its proper use (i.e. greeting cards, books, talking toys, and games). The label information for these products may be displayed in the language appropriate to the use of the product.
The province of Quebec has additional requirements concerning the use of the French language on all products marketed within its jurisdiction. Information on these requirements may be obtained from the:
Office de la langue française
125 Sherbrooke Street
West
Montreal, Quebec
H2X 1X4
Telephone: (514) 873-6565
Toll
free: 1-888-873-6202
2.4.2 Test Market Products | Section6Regulations |
Under certain conditions, products considered to be "test market products", as defined by the Regulations, may be exempted for up to one year from the bilingual labelling requirements. In order to qualify for such an exemption, the dealer who intends to conduct the test marketing must ensure that:
In addition, the dealer must file a notice of intention to:
Deputy Commissioner of Competition
Competition Bureau, Fair Business
Practices Branch
Place du Portage, Phase I
50 Victoria Street
Hull,
Quebec, K1A 0C9
A notice of intention must include the following:
Following receipt of the "Notice of Intention", Bureau officials will evaluate the information and render an opinion as to whether or not the proposed test market product and plan are in accordance with the requirements of the Regulations. The applicant will then receive a letter outlining the Bureau's opinion and providing further guidance on proceeding with the test market or on correcting existing labels.
Products failing to meet the requirements for the test market exemption are most often not "substantially different" or do not comply with the detailed requirements of the regulations other than those provisions related to bilingual labelling. It is the Bureau's position that slight changes in product formulation or package design would not qualify the product as being substantially different. New, unique products or products which are packaged in unique delivery systems are often considered to be substantially different.
In cases where the Bureau is of the opinion that a product satisfies the regulations respecting test marketing, dealers are advised that during the one year period of test marketing, distribution of the product must be limited to local government units where the official language used on the label is the mother tongue of at least 10 per cent of the total number of persons residing in the unit and where the other official language is the mother tongue of less than 10 per cent of the total number of persons residing in the same local government unit.
In many circumstances, dealers investigating the possibility of a test market exemption are seeking a means of importing unilingually labelled products for a short period of time in order to test the potential demand for the product before undertaking to re-design the labels to meet the Canadian regulations. However, due to the fact that in most cases it is only the mandatory product identity and net quantity declarations which must be shown in French and English, dealers have the option of providing the additional information by applying pressure sensitive stickers bearing the proper translation. This alternative would bring the packages into compliance with the regulations and eliminate the need for the above-mentioned test market procedure and its inherent restrictions. Dealers considering this alternative may wish to check with the Bureau for further guidance on proposed label changes.
Subsection4(1)Regulations | ||
2.4.3 Exemption From the Detailed Labelling Requirements |
Prepackaged products that are subject to the labelling requirements of the FeedsAct, FertilizersAct, PestControlProductsAct or the SeedsAct are exempt from the detailed labelling requirements (sections 4, 5, 6, 8 and 10) of the ConsumerPackagingandLabellingAct.
To obtain information concerning the labelling requirements for products under the FeedsAct, FertilizersAct or SeedsAct, contact the Agriculture and Agri-Food Canada office in your area or the head office in Ottawa at (613) 952-8000.
To obtain information concerning the labelling requirements for products under the PestControlProductsAct, contact the Pest Management Regulatory Agency of Health Canada in Ottawa at 1-800-267-6315 within Canada and 1-613-736-3799 outside Canada (long distance charges apply).
1. Fill Level | Section 9 Act |
Packages must be filled in such a manner that a consumer may not reasonably be misled with respect to the quantity of product it contains.
2. Package Design and Display | Section9Act |
Packages must be manufactured, constructed, or displayed in such a manner that a consumer is not misled with respect to the quality or quantity of product it contains.
3. Standard Package Sizes | Section36Regulations |
The Regulations prescribe standardized container sizes only for wine, peanut butter, glucose syrup and refined sugar syrup. Complete information concerning the labelling of prepackaged food products may be obtained from the Canadian Food Inspection Agency office in your area or from the head office in Ottawa at 1-800-442-2342.
Cosmetic products are subject to the requirements of the CosmeticRegulations under the FoodandDrugsAct, as well as the ConsumerPackagingandLabelling Act. For further information regarding the CosmeticsRegulations, contact the office of the Consumer Product Safety Bureau, Health Canada in your area or the following:
Consumer Product Safety Bureau
Product Safety Programme
Health
Canada
MacDonald Building, 4th Floor,
123 Slater Street
Address
Locator: 3504D
Ottawa, Ontario
K1A 0K9
Tel: (613) 957-4467
Fax:
(613) 952-3039
e-mail: CPS-SPC@hc-sc.gc.ca
The Competition Bureau is responsible for the administration of the ConsumerPackagingandLabelling Act and Regulations regarding all consumer pet food products.
Foreign dealers exporting consumer pet food containing animal and/or plant products to Canada are reminded that an original official zoosanitary export certificate is required under the AnimalDiseaseandProtectionAct administered by the Canadian Food Inspection Agency (CFIA). For further information or assistance in regard to the export certificate, dealers should contact the CFIA office in their area or the following:
Chief, Imports
Animal Health Section
Animal Health and Production
Division
Animal Products Directorate
Canadian Food Inspection
Agency
59 Camelot Drive
Camelot Court Bldg.
Nepean, Ontario, K1A 0Y9
Telephone: (613) 225-2342
Fax: (613)
228-6631
Dealers are also advised that all containers for certified and imported inedible meat shipments destined for further processing in Canada have to be labelled in accordance with the requirements of the MeatInspectionAct and Regulations. For further information in this regard, contact the Canadian Food Inspection Agency office in your area or the following:
Chief, Import Program
Food of Animal Origin Division
Animal Products
Directorate
Canadian Food Inspection Agency
59 Camelot Drive
Camelot
Court Bldg.
Nepean, Ontario, K1A 0Y9
Telephone: (613) 225-2342
Fax:
(613) 228-6636