Understanding Health Canada’s new labelling requirements for hand sanitizers, disinfectants & cleaning products, hand soap & body soaps

Effective June 8, 2020

Disinfectants:

• Importers of disinfectants 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 point of sale communication is not prescriptive – it remains open to the importer to decide how to inform the consumer about the website where the bilingual text is posted. 
• Health Canada has suggested possible options but not limited to a sticker applied directly to the products, or posters or signage with take-away pamphlets at the point of sale.
• Retailers, for example, may have bilingual signs in-store saying that bilingual labels are available on the respective company website. “Due to COVID-19 – consumers will find unilingual disinfectants, hand sanitizers, and cleaning products on store shelves. If you need a bilingual label, companies are required to post them on their Canadian websites.” The signage should be in close proximity to the impacted products.
• 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.
• All new Canadian manufacturers of disinfectants must use bilingual labelling.

Hand sanitizers:

• Importers of hand sanitizers 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 point of sale communication is not prescriptive – it remains open to the importer to decide how to inform the consumer about the website where the bilingual text is posted. 
• Health Canada has suggested possible options but not limited to a sticker applied directly to the products, or posters or signage with take-away pamphlets at the point of sale.
• Retailers, for example, may have bilingual signs in-store saying that bilingual labels are available on the respective company website. “Due to COVID-19 – consumers will find unilingual disinfectants, hand sanitizers, and cleaning products on store shelves. If you need a bilingual label, companies are required to post them on their Canadian websites.” The signage should be in close proximity to the impacted products.

• 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.
• All new Canadian manufacturers of hand sanitizers must use bilingual labelling.

Cleaning products (general purpose cleaners), hand soaps & body soaps:

• Importers of general purpose cleaning products and hand soaps and body soaps have always been required to post bilingual label text on their website and NOW need to provide sellers with a means to inform consumers, at the time of sale, of the website where bilingual label text is posted. This point of sale communication is not prescriptive – it remains open to the importer to decide how to inform the consumer about the website where the bilingual text is posted. 
• Health Canada has suggested possible options but not limited to a sticker applied directly to the products, or posters or signage with take-away pamphlets at the point of sale.
• Retailers, for example, may have bilingual signs in-store saying that bilingual labels are available on the respective company website. “Due to COVID-19 – consumers will find unilingual disinfectants, hand sanitizers, and cleaning products on store shelves. If you need a bilingual label, companies are required to post them on their Canadian websites.” The signage should be in close proximity to the impacted products.

• 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.

Cleaning products for the workplace:

• Importers of general purpose cleaners used, handled, or stored in workplaces have always been required to have bilingual labels and provide the product’s bilingual SDS on their website. NOW they are required to provide sellers with a means to inform employer buyers, at the time of sale, of the website where bilingual label text and SDS or SDS text is posted. This point of sale communication is not prescriptive – it remains open to the importer to decide how to provide sellers with the means to inform employers, at the time of sale, about the website where the bilingual text is posted. The interim policy also requires the importer to make bilingual label text and bilingual SDS or SDS text information available to employer buyers and workers, upon request.
• All new importers of these products through the interim measure must meet this requirement.

Product imported for company’s internal use:

If a company imports any of the above product through the interim approach to be used only within its respective facilities, and there is no intent for further sale or distribution, then the company must provide information to its employees on how they can access the information in the other official language. The company has flexibility in the mechanism it uses to impart this information as long as employees have access prior to using the product.Should the company import a hand sanitizer that has an NPN (i.e. is licensed for sale in Canada), then the NPN product should already have bilingual labelling on the label as per the interim policy, unless the product was imported in early May, 2020, and the facility where the product will be used is in a unilingual region.