Retail/Consumer Label Review

Regulations Involved

For chemical products used by consumers, the regulations that govern retail/consumer labels vary depending on the country. These consumer products are often purchased in a retail store.

For some countries, retail/consumer labels for chemical products are subject to the same requirements as workplace labels and must conform to the jurisdiction’s Globally Harmonized System (GHS) labelling standards, with some modifications. The European Union is one which retail labels will need to follow the Classification, Labelling and Packaging (CLP) Regulations.

However, in countries like Canada, the United States, Mexico and Australia, retail/consumer labels are governed by a separate set of regulations.

In the United States, retail chemical products must be labelled according to the Code of Federal Regulations Title 16’s Federal Hazardous Substances Act (FHSA) and Fair Packaging and Labeling Act (FPLA) and are monitored by the Consumer Product Safety Commission (CPSC).

In Canada, retail chemical products are governed by the Consumer Chemicals and Containers Regulations, 2001 (CCCR), the Canadian Consumer Product Safety Act (CCPSA), and the Consumer Packaging and Labelling Act (CPLA).

It’s also important to remember that provincial or state level regulations may require labelling in addition to the federally mandated labelling mentioned above.

The intended users of consumer chemical products will not necessarily have the same knowledge or training for handling chemicals as someone using them in the workplace, so it is important that the labelling be adapted so that the product’s hazards and precautions are easily understood by users of varying literacy, age, and education.

Under some regulations, child-resistant (CR) packaging may be required to prevent children from opening and being exposed to a hazardous product. In Canada, consumer products that are classified as “toxic”, “very corrosive”, “corrosive” and “quick skin-bonding adhesives” will require CR packaging. In the United States, CR packaging is only required for specific substances. For example, liquid products that contain 10% or more of turpentine or ethylene glycol will require CR packaging.

Some countries have requirements for minimum text sizes, standardized formatting, and restrictions on the type of fonts and colours that can be used. Pictograms and statements may also be required to be listed on the package label.

Who Does This Apply To?

Retail/consumer labels are required for any chemical product that is available for purchase by the public and is typically used for domestic or household use. These are often called “consumer chemical products” and include products like automotive fluids, household cleaners, adhesives, or paints.

Sometimes a consumer chemical product is available to both the public and workplaces, in which case the supplier must ensure the product is labelled complying with both retail and workplace regulations.

Is This Regulation Mandatory?

All hazardous retail/consumer products will require a label that identifies the product’s net quantity, hazards, handling and storage precautions, and first aid measures, if necessary.

Specific requirements depend on the country, which may require additional information including but not limited to the country of origin, other markings or pictograms and/or information regarding the packaging.

What are the risks if a company chooses not to comply?

If a retail/consumer label is not compliant, it may increase the risk of injury or accidental poisonings due to improper storage or handling. The penalties for a non-compliant label could include recalls, stop sale orders, or monetary penalties for the supplier and/or manufacturer.

If a recall takes place, the product and distributor information could be posted online for the public to see like on Health Canada’s website.

How Can Nexreg Ensure Your Compliance?

For jurisdictions where retail-specific regulations are in force, Nexreg can issue a Consumer Label Review Memo outlining the information that is required to appear on the label in the official language(s) of the jurisdiction.

To complete the memo, we request that the following information be provided:

The full formula, to determine the product hazards;
Known physical data, to aid in hazard classification and determine if any exemptions or prohibitions apply;
Container dimensions, to calculate the minimum required size of some label elements, and;
Current label artwork, if available.

Since retail/consumer label requirements can significantly vary by jurisdiction, we recommend having separate labels for each country. However, for products that do not have many hazards and a large enough container, it may be possible to create a single label that will be compliant in multiple countries, such as a US CPSC + Canada CCCR combination label.

Once the label artwork has been prepared according to the requirements in the Consumer Label Review Memo, Nexreg can review your draft label artwork to ensure it is in compliance. We advise clients take advantage of this service before printing their first labels. For more information about our label services click here.

Nexreg is constantly expanding our retail/consumer label portfolio. If your company is looking to branch sales to a new country and are unsure which regulations may apply to your product, Nexreg’s regulatory consulting services can investigate on your behalf.

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The Nexreg Advantage is a guarantee that your products will have the proper safety documentation, correct format, and compliance with specific country regulations. Contact us to learn more about MSDS services.