Packaging Compliance For Chemical Products

Regulations Involved

Depending on the purpose and intended market of your product, the packaging compliance requirements will vary between regulation and country.

For chemical workplace products, GHS regulations establish what are required on labels for most countries. Examples of GHS implementation include Workplace Hazardous Materials Information System (WHMIS) for Canada; Occupational Safety and Health Administration (OSHA) for the U.S.A.; and the Classification, Labelling and Packaging (CLP) Regulation for the European Union (EU).

For chemical products used by consumers, separate regulations from GHS dictate the packaging requirements for many countries. Some examples include the Consumer Chemicals and Containers Regulations, 2001 (CCCR, 2001) and Consumer Packaging and Labelling Act and Regulations (CPLA) for Canada and the Federal Hazardous Substances Act (FHSA) and Fair Packaging and Labeling Act (FPLA) for the United States. Unlike Canada and the U.S.A., Europe does not have sperate regulations for consumer products and therefore must follow CLP regulations.

For other products that do not fall in the scope of hazardous chemicals, other regulations will outline the packaging compliance requirements. For cosmetics, the Cosmetic Regulations (C.R.C., c. 869) regulates these products in Canada; Federal Food, Drug, and Cosmetic Act (FD&C Act) for the U.S.A; and Regulation (EC) No. 1223/2009 for the EU.

For products being shipped, the transport regulations would outline packaging requirements. The Transportation of Dangerous Goods (TDG) regulates dangerous goods by all modes (road, rail, air, or water) in Canada, Department of Transportation (DOT) is for the U.S.A; and Dangerous Goods by Road (ADR) for the EU. The International Air Transport Association (IATA) and the International Maritime Dangerous Goods (IMDG) are international transport regulations.

Packaging is important as it protects its contents from any damage that could happen during transport, handling and storage. For transport, depending on the classification and packing group number (PG), some packaging materials and sizes may be prohibited.

For consumer products, 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 U.S.A., 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.

Packaging

What Products Do These Regulations Apply To?

Any products that will be handled, stored, or shipped should have their entire package evaluated prior to sale and distribution.

Is This Regulation Mandatory?

Packaging compliance differs by regulations/jurisdictions but overall, it is expected that the product is in the appropriate packaging with correct labelling to ensure the safe use and storage of the product.

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

If a products packaging is not compliant, it may increase the risk of injury or accidental poisonings due to improper storage or handling. The penalties for failing to meet packaging compliance could include recalls, cease of sales, or monetary penalties for the supplier and/or manufacturer.

How Can Nexreg Ensure Your Compliance?

Nexreg will first review the product information to determine the applicable hazards and/or statements for the packaging label of your product. We request that the full formula be provided, as well as other information including the current SDS, any known physical or test data and dimensions of the packaging. For cosmetic labels, we also request the International Nomenclature Cosmetic Ingredient (INCI) names be provided as well.

Once the product is evaluated, a label memo is generated in the required language and format for the requested country.

A consultant will then review the label to ensure accuracy. The final product will have all the required information and elements that must appear on the product and can be incorporated into your label artwork. For GHS, you can directly print this label for application to the product package.

For Canadian cosmetic labels, Nexreg can also fill out and submit a Cosmetic Notification Form (CNF) form on your behalf.

Nexreg also provides compliance consulting for transport packaging and labelling to ensure your product complies with the regulations. We can also review your label artwork to ensure the necessary symbols are listed and the required sizing is met.

Label checks of the final artwork can be performed by Nexreg. We advise clients take advantage of this service before printing their first labels.

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Customizable documents – Include Company Logos, Specialized Statements and Formatting

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.