May 9 – Reference Manual for the Consumer Chemicals and Containers Regulations, 2001

An invaluable resource for anyone who sells consumer chemical products in Canada: Reference Manual for the Consumer Chemicals and Containers Regulations, 2001 of the Hazardous Products Act.

A recent update to the manual (page 25) is a section on spray containers packaged with spray tubes:

New: Tube Attachments

Certain spray containers, such as automotive lubricants, are packaged with a tube that is intended to be inserted into the nozzle to confine the application of the product. Without the tube, the spray is a mist and the product qualifies for the exemption of paragraph 40(2)(a). However, with the tube inserted, the product is released as a stream and, if the user leaves the tube in the nozzle, the contents are readily available to a child. In order to maintain the exception of paragraph 40(2)(a), the container must be designed so that the tube can stored when the lid is closed. In addition, the label should include instructions to remove the tube from the nozzle when storing. For example, the following instructions could be used:

“THIS CONTAINER IS NOT CHILD-RESISTANT WHEN THE TUBE IS USED. REMOVE AND STORE TUBE IN THE HOLDER PROVIDED.”

“AVEC LE TUBE, LE CONTENANT N’EST PLUS UN CONTENANT PROTÈGE-ENFANTS. RETIRER LE TUBE ET LE PLACER DANS LE SUPPORT FOURNI.”

Although such a regulation does not exist in Canada (as seen by the terms “should include” and “could be used”) we are recommending to our clients that they, if at all possible, follow these instructions as if they are law and include the exact phrase listed above.

Nexreg authors and reviews consumer chemical reviews for Canadian compliancy. More information is available at:

To discuss Canadian consumer chemical labeling (CCCR) issues please call or e-mail Nexreg at:

Nexreg Canada: (519)488-5126 (London, ON)
Nexreg UK: +44 020 7993 5893 (London, UK)
Nexreg USA: (206)418-6663 (Seattle, WA)
E-mail:info@nexreg.com

/by