Team Nexreg

Packaging and Labelling Requirements for Alcohol-based Hand Sanitizers in Beverage and Food Containers

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On October 2, 2020, Health Canada released a new policy for manufacturers that package their alcohol-based hand sanitizers in food and beverage containers. The policy aims to reduce accidental ingestion of alcohol-based hand sanitizers that are packaged in these containers.

 

Due to the COVID-19 pandemic, the high demand for hand sanitizer has led to significant shortages in both products and standard packaging. These shortages have resulted in the use of other types of containers such as beverage or food containers.

 

Beverage and food containers that are subject to this policy and requiring additional packaging and labelling:

  • Water bottles
  • Wine bottles
  • Beer and soda bottles
  • Other beverage or drinking containers

 

Some containers are unable to accommodate the required closure and thus should not be used for hand sanitizer packaging:

  • Beer and soda cans
  • Food and beverage pouches
  • Tetra packs
  • Vaping cartridges

 

Packaging

Containers should have closures that are obvious and not generally used on beverage contains (pump or dispensing cap). This will help consumers differentiate between hand sanitizer packaging and beverage/food packaging.

 

Acceptable closures include:

  • pumps
  • dispensing caps
  • other closures that are different from a beverage container and force consumer interaction

 

Unacceptable closures include:

  • drinking spouts
  • beer bottle caps
  • twist-off caps or lids
  • corks

 

Labelling

A warning statement on the front label is the most effective way to inform consumers that the product is not a beverage.

 

The warning must include:

  • The text “Do not drink / Ne pas boire”
    • English and French text on separate lines
  • The text “Health Canada / Santé Canada”
  • A red symmetrical octagon graphic symbol that precedes the warning statement

 

Enforcement

These measures must be put in place no later than 8 weeks after this policy comes into effect, allowing existing stock to be used up. Hand sanitizers packaged in beverage containers and distributed after November 27, 2020, must have an appropriate closure along with the warning statement and graphic. Distribution in Canada of alcohol-based hand sanitizers packaged in beverage containers without these measures must stop after this date.

To learn more about packaging and labeling requirements or to speak with a regulatory expert, contact us today.