Consumer Packaging and Labelling
The general worksheet provides an outline to the basic packaging and labelling requirements for prepackaged non-food consumer products subject to the federal Consumer Packaging and Labelling Act and Regulations. The following sections are all mandatory considerations in the design of a label. Users of this worksheet should not omit studying any of the topics below.
Note that some products are exempt from the requirements of the Act and Regulations.
Worksheets for Different Types of Products
Additional worksheets have been tailored for specific kinds of products. Select the example below which best suits your product.
The product is a
The product is a solid and
If your product does not fall within any of the categories detailed above, then use the General Worksheet at the top of this page.
Product Safety Programme
Healthy Environments and Consumer Safety Branch (HECS)
Principal Display Panel
- The principal display panel of a label must be located on that part of the container normally displayed to the user.
The label must contain three basic mandatory statements which must, where applicable, appear in a prescribed manner:
- Product Identity Declaration.
- Net Quantity Declaration.
- Dealer Name and Principal Place Of Business.
The product identity and net quantity declarations must appear on the principal display panel.
The following sections will discuss these mandatory statements in detail.
What To Put on a Label
Product Identity Declaration (Common Name)
The Product Identity Declaration may not be required if:
- The product is usually sold by count and is packaged in such a way that it is visible and identifiable; or
- The product is usually sold by count and bears an accurate pictorial representation of the package contents.
- The label must identify the common name of the product in terms of its generic name or function.
- Except in cases where the product is a test market product, a local product, a specialty product, or a product for which knowledge of a specific language is required, the product identity must be given in both English and French.
- The product identity declaration must be located on the principal display panel.
- The product identity declaration must be clearly legible, and meet the requirements for minimum type height
Net Quantity Declaration
The Net Quantity Declaration is not required if:
- The quantity is usually measured by count, the count is one, and the product identity declaration is given in the singular form.
- The product is usually sold by count and is packaged so that the contents are visible and identifiable, and there are fewer than seven articles, or there are fewer than 13 articles which can be easily counted.
- The net quantity declaration must be located on the principal display panel.
- The net quantity must be displayed clearly and prominently in distinct contrast to any other information shown on the label.
- The numerical portion of the net quantity must be in bold face type and meet the minimum type height requirements.
- The choice of measurement unit employed in the net quantity declaration must be appropriate to the type of product.
- The net quantity must be declared in both English and French using a valid metric word or symbol as a unit of measurement. A valid metric symbol is deemed to be bilingual.
- The net quantity must be correctly rounded off and given to the required degree of precision.
Dealer Name and Place of Business (Dealer Identification)
The "dealer" is the person who is a retailer, manufacturer, processor, or producer of a product, or a person who is engaged in the business of importing, packing, or selling any product. In identifying the dealer, the label must be designed to meet the following requirements:
- The name and place of business of the producer, or of the person for whom the product was produced for resale, must be on the label. The address should be sufficient to ensure postal delivery.
- Except in the case of an ornamental container, the dealer identification must be located anywhere on the outside of the container, except on the bottom.
- The dealer identification must be given in either English or French.
- The dealer identification must be clearly legible, and printed in a font at least 1.6 mm (1/16") in height.
- If the product is wholly imported, the dealer identification must meet additional imported identification requirements.
Package Design and Fill
- The container for the product must be constructed, filled and displayed so that consumers are not misled about either the quality or quantity of the product.
Other Non-Mandatory Label Information
- No false or misleading information can be placed on the label. The product must conform with claims made on the label relating, for example, to type, quality, performance, function, origin, and method of manufacture. "Product of Canada" and "Made in Canada" claims are subject to specific assessment criteria.
Exemptions From the Consumer Labelling and Packaging Act
The following products are exempt from the requirements of the Consumer Packaging and Labelling Actand Regulations:
- Drugs and medical devices.
- Products for commercial, industrial, or institutional use only.
- Products for export only.
- Products sold only in a duty-free store.
- Prepackaged textile articles.
- Replacement parts for consumer durables (cars, appliances) if not displayed to the consumer.
- Certain artist's supplies.
A label is defined as any label, mark, sign, device, imprint, stamp, brand, ticket, or tag.
A Prepackaged Product means any product that is packaged in a container in such a manner that it is ordinarily sold to or used or purchased by a consumer without being re-packaged.
Bi-dimensional products are declared in metric units of area such as square centimetres (cm2) and square metres (m2). The units used depend on the net quantity amount.
- If the area of the product is less than 100 cm2(1 dm2), then the net quantity is declared in cm2.
- If the area of the product is 1 dm2or more, and less than 100 dm2, then the net quantity is declared in dm2.
- If the area of the product is 1 m2or more, then the net quantity is declared in m2.
Choice Of Measurement Unit
Generally the net quantity should be expressed:
- In metric units of volume when the product is a liquid, gas, or viscous substance.
- In metric units of weight when the product is a solid.
- In metric units of weight (propellant + ingredient) when the product is an aerosol.
- In metric units of length when a product, such as a garden hose or twine, is measured solely by length.
- In metric units of area, length and width, as well as the number of rolls or sheets, when the product is bi-dimensional such as wrapping paper, or aluminium foil.
- In metric units of length and width for each separate or perforated unit, number of rolls, number of perforated units per roll and the number of plys, for products such as toilet tissue paper towels and paper napkins.
The term Container refers to a receptacle, package, wrapper, or confining band in which a product is offered for sale. The term does notinclude package liners or shipping containers or any outer wrapping or box that is not customarily displayed to the consumer.
Fair Business Practices Branch will interpret the dealer identity and principal place of business to consist of a dealer name, city and postal code.
Degree of Precision
In general, the numbers used must be shown to 3 figures in the decimal system, thus requiring some net quantity figures to be rounded off. Any final zeroes to the right of the decimal point need not be expressed. The following table provides some examples.
|984.3 cm||984 cm|
|142.3 g||142 g|
Three exceptions to the Degree Of Precision requirement are permitted:
- If the net quantity is less than 100 grams, millilitres, centimetres, square centimetres, or cubic centimetres, then the figure may be shown to two decimal figures. Any final zeros to the right of the decimal point similarly need not be expressed.
Degree Of Precision requirement Incorrect Permissable Correct 53.592 cm 53.6 cm 54 cm 85.05 g 85.1 g 85 g
- If the net quantity is less than one, then the figure may be shown in either the decimal system with the figure zero preceding the decimal point, or in words.
Degree Of Precision requirement Correct Also Correct 0.5 g one-half gram/un demi gramme
- A specific variation of (ii) above permits 500 grams and 500 millilitres
to be shown as being one-half kilogram and one-half litre respectively.
declarations may also be declared in decimal figures or words.
Degree Of Precision requirement 500 grams 500 millilitres 500 g 500 mL 0.5 kg 0.5 L one-half kilogram/un demi kilogramme one-half litre/un demi litre one-half kg/un demi kg one-half L/un demi L
Import Requirements On Dealer Identification
Where a prepackaged product is wholly manufactured or produced in a country other than Canada, the application of any one of the following formats will satisfy the requirements of the Regulations:
- The name and address of a Canadian dealer preceded by the words "imported by/importé par" or "imported for/importé pour"; or
- The statement of geographic origin located immediately adjacent to the name and address of a Canadian dealer; or
- The name and address of the dealer outside Canada.
Length And Width (Linear Measure)
Products such as a garden hose or a ball of string are declared in metric units of length such as millimetres (mm), centimetres (cm), and metres (m). The units used depend on the net quantity amount.
- If the product measures less than 100 centimetres, then the net quantity is declared in millimetres or centimetres.
- If the product measures 100 centimetres or more, then the net quantity is declared in metres.
A Local Product is exempt from the bilingual labelling requirement if:
- The product is manufactured and sold in a local government unit or its adjacent units, in which one of the official languages is the mother tongue of less than 10 per cent of that unit's population; and
- The information required to be shown on the label is shown in the official language that is the mother tongue of at least 10 per cent of that unit's population.
Location of Product Identity and Net Quantity Declarations
Where there are one or more surfaces that are of equal size and prominence as the principal display panel, the product identity and net quantity declarations can be shown in one of the official languages on one of the surfaces, provided that the same information is shown in the other official language on one of the other surfaces.
"Product of Canada" and "Made in Canada" Claims
"Product of Canada" and "Made in Canada" claims are subject to specific assessment criteria. The enforcement guidelines entitled "Product of Canada" and "Made in Canada" Claims describe the Competition Bureau's approach in assessing these claims for non-food products under the Competition Act, the Consumer Packaging and Labelling Act and the Textile Labelling Act.
Minimum Type Height Requirements for Net Quantity Declaration
The type height requirements for the numerical portion of a quantity declaration are directly related to the size of the principal display surface. The type height must not be less than the minimum size outlined in the following table.
|Area of Principal Display Surface||Minimum Type Height|
|Less than or equal to 32 cm2(5 in2)||1.6 mm (1/16 in)|
|Greater than 32 cm2and less than or equal to 258 cm2(40 in2)||3.2 mm (1/8 in)|
|Greater than 258 cm2and less than or equal to 645 cm2(100 in2)||6.4 mm (1/4 in)|
|Greater than 645 cm2and less than or equal to 25.8 dm2(400 in2)||9.5 mm (3/8 in)|
|Greater than 25.8 dm2||12.7 mm (1/2 in)|
The type height for all other information in the net quantity declaration must be a minimum of 1.6 mm (1/16 inch) where upper case letters only are used or as measured in relation to the lower case 'o' if upper and lower case or only lower case letters are used.
Minimum Type Height Requirements For Product Identity Declaration
The type height must be a minimum of 1.6 mm (1/16 inch) where upper case letters only are used or as measured in relation to the lower case 'o' if upper and lower case or only lower case letters are used.
In certain cases where the container has a principal display surface of 10 square centimetres (1.55 square inches) or less, the minimum type height may be reduced to 0.8 mm (1/32 inch).
Return to Product Identity Declaration
An Ornamental Container is a container which, because of a design on its surface or because of its shape or texture, appears to be a decorative ornament and is being sold as such, as well as being sold as a container for the product.
Note that a label for an Ornamental Container may be applied to the bottom of the container or on to a tag attached to the container.
Principal Display Panel
The Principal Display Panel refers to that part of the label which occupies the principal display surface. The specific definition of the Principal Display Panel depends on the type of container being labelled:
- If a container is mounted on a display card, the Principal Display Panel means:
- The part of the label that is applied to all or part of the container's principal display surface; or
- The part of the label that is applied to the side of the display card which is normally visible; or
- Both of the above.
- If the container is an ornamental container,
the Principal Display Panel means:
- The part of the label that is applied to all or part of the bottom of the container; or
- The part of the label that is applied to all or part of the principal display surface; or
- All or part of the tag that is attached to the container.
- For all other containers, the Principal Display Panel means that part of the label that is applied to all or part of the principal display surface.
Principal Display Surface
The definition of the Principal Display Surface depends on the type of container being labelled.
- If a container has a side or a surface that is displayed or visible under normal or customary conditions of sale or use, the term means the total area of such side or surface excluding the top, if any.
- If a container has a lid that is part of the container displayed or visible under normal or customary conditions of sale or use, the term means the total area of the top surface of the lid.
- If a container does not have a particular side or surface that is displayed or visible under normal or customary conditions of sale or use, the term means any 40% of the total surface area of the container, excluding the top and bottom, if any, if such 40% can be displayed or visible under normal or customary conditions of sale or use.
- If the container is a bag with sides of equal dimensions, the term means the total area of one of the sides.
- If the container is a bag with unequal sides, the term means the total area of one of the largest sides.
- If the container is a wrapper or confining band that is so narrow that it can't reasonably be said to have any side or surface which is displayed or visible under normal or customary conditions of sale or use, then the term means the total area of one side of a ticket or tag attached to such a container.
Products For Which Knowledge Of A Specific Language Is Required
There are some products for which a knowledge of the language used is a basic factor essential to the use of the product. Examples of such products include:
- Greeting cards
- Talking toys
- Games designed for use in a specific language
In cases like these, product identity should be shown only in the language for whose use the product is intended.
Rounding Off Net Quantity
Where it is necessary to round-off the metric declaration to either three figures or two figures, depending on the requirements for degree of precision, the procedure is as follows:
- When the first digit to be discarded is less than five, the last digit retained should not be changed.
Rounding Off Net Quantity Original Number Rounded Number 984.3 984 101.239 101 68.4 68 7.32 7.3
- When the first digit to be discarded is exactly five, followed only be zeros, the final digit to be shown should be rounded up if it is an odd number, but no adjustment made if it is an even number.
Rounding Off Net Quantity Original Number Rounded Number 984.50 984 985.50 986 68.50 68 7.450 7.4 7.550 7.6
- When the first digit to be discarded is greater than five, or it is a five followed by at least one digit other than zero, the last digit to be retained should be increased by one.
Rounding Off Net Quantity Original Number Rounded Number 984.7 985 985.51 986 68.6 69 6.88 6.9 7.550 7.6
Dealers are advised that when the value is rounded up, there may be a need to increase the package contents to meet the new declared quantity.
Specialty products can be generally described as products which are not typically purchased by the public at large and which are:
- used at special times, such as religious seasonal products, or
- imported products for which there is no comparable substitute produced in Canada.
Specialty products must display mandatory labelling information in at least one of the official languages.
Test Market Products
Under certain conditions, products considered to be Test Market Products as defined by the Regulations (Section 6) may be exempted for up to one year from the bilingual labelling requirement. In order to qualify for such an exemption the dealer who intends to conduct the test marketing must ensure that:
- The product in question has not previously been sold in Canada.
- The product differs substantially from any other sold in Canada with respect to composition, function, state or packaging form.
- The existing labelling on the product complies with the detailed requirements of the legislation, except for those provisions related to bilingual labelling.
In addition, the dealer must file a "Notice of Intention" addressed to the Deputy Director, Fair Business Practices Branch, Competition Bureau, Industry Canada, Place du Portage, Phase I, 50 Victoria St, Hull, Quebec, K1A 0C9, and include the following:
- A description of the prepackaged product together with a sample, or an illustration of the package and label.
- The number of products to be distributed.
- The proposed period of time for test marketing (up to one year) and the proposed commencement date.
- The geographic area or region in which the test market is to be conducted.
- Information with supporting data, to verify that the product was not previously sold in Canada in that form and to establish that it differs substantially from any other product sold in Canada with respect to its composition, function, state, or packaging form.
Following receipt of the "Notice of Intention", department officials will evaluate the information and render an opinion as to whether or not the proposed test market product and plan are in accordance with the requirements of the Regulations. The dealer will then receive a letter outlining the Department's opinion and providing further guidance on proceeding with the test market or on correcting existing labels.
Products failing to meet the requirements for the test market exemption are most often not "substantially different" or do not comply with the detailed requirements of the regulations other than those provisions related to bilingual labelling and standardization of container sizes. It is the Department's position that slight changes in product formulation or package design would not qualify the product as being substantially different. New, unique products, or products which are packaged in unique delivery systems are often considered to be substantially different.
In cases where the Department is of the opinion that a product satisfies the regulations respecting test marketing, dealers are advised that during the one year period of test marketing, distribution of the product must be limited to local government units where the official language used on the label is the mother tongue of at least 10 per cent of the total number of persons residing in the unit and where the other official language is the mother tongue of less than 10 per cent of the total number of persons residing in the same local government unit.
It is also important to note that this exemption applies only to the bilingual labelling requirements of theConsumer Packaging and Labelling Regulationsand does not exempt the dealer from providing bilingual declarations by other federal or provincial statutes.
Unit Of Measurement
The use of either a word or symbol for the unit of measurement is acceptable. Column I in the following table shows the correct spelling of the unit of measurement in English and French, and Column II shows the acceptable symbol.
|millilitre||millilitre||mL, ml, ml|
|square centimetre||centimètre carré||cm2|
|square metre||mètre carré||m2|
|cubic centimetre||centimètre cube||cm3|
|cubic decimetre||décimètre cube||dm3|
|cubic metre||mètre cube||m3|
Note the following points about unit of measurement usage:
- The symbols in Column II are in themselves considered bilingual. If, however, a word from Column I is used in the net quantity declaration (e.g. "gram"), then the equivalent word ("gramme") must be shown in French.
- When using the symbols for litre or millilitre, the symbols "L" and "mL" are preferred.
- Except for the litre symbol, "L", all unit of measurement symbols (Column II) must be shown in lower case letters. Neither a period nor the letter "s" should be used after any symbol. The following table illustrates examples
of correct and incorrect usage.
Correct and incorrect usage (unit of measurement symbols) Correct Incorrect g g. g G g gm g gms
- A single space should be used to separate the number from the unit of measurement.
unit of measurement Correct Incorrect 500 g 500g
- Phrases such as "net", "net contents", or "net quantity" are unnecessary as part of the net quantity declaration. When such terms are used, it is preferable that they appear in both English and French.
Liquids, gases, viscous substances are declared in metric units of volume such as millilitres (mL) and litres(L). The units used depend on the net quantity amount.
- If the volume of the product is less than 1000 millilitres, then the net quantity is declared in millilitres.
- If the volume of the product is 1000 millilitres or more, then the net quantity is declared in litres.
Solids and most aerosols are declared in metric units of weight such as grams, or kilograms. The units used depend on the net quantity amount.
- If the product weighs less than 1000 grams, then the net quantity is declared in grams.
- If the product weighs less than 1000 grams, and if the product is a catchweight, or is prepackaged from bulk at retail, then the net quantity can be declared in grams, or in decimal fractions of a kilogram.
- If the product weighs 1000 grams or more, then the net quantity is declared in kilograms.
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