CCCR vs CPSC:

Canadian vs. US Consumer Labeling

dell tech laboratories ltd. 1

 Kirsten Alcock B.Sc. Ivy Tang B.S.c.
Manager, Product Safety Group Product Safety Specialist
kirsten@delltech.com itang@delltech.com
519.858.5074 519.858.5021 ext 2043

dell tech laboratories ltd. 2

 Dell Tech Laboratories Ltd.
Dell Tech Product Services
• US/CAN consumer labeling consultation
• Claims support and Performance Testing
• Green Seal, EcoLogo, EPA Safer Choice
• US/CAN GHS SDSs
• E-liquids and vaping devices
• Cannabis labeling and packaging
• Cosmetic Notifications, Pesticide registration, Medical Device labeling
• Non-prescription Drugs and NHP regulations
• Translation of Technical Documents
• Transportation Consulting

dell tech laboratories ltd. 3

 Disclaimer
The information provided in this webinar is not legal advice. If you are uncertain about the
interpretation of the CCCR and CPSC regulations, please contact Health Canada and the
Consumer Product Safety Commission directly. If you are concerned about confidentiality, Dell
Tech can contact these agencies on your behalf.

Health Canada
Address Locator 0900C2
Ottawa, Ontario
K1A 0K9

Email: Info@hc-sc.gc.ca
Telephone: 613-957-2991 Consumer Hotline and General
Toll free: 1-866-225-0709 Information

Phone: (800) 638-2772; TTY (800) 638-

8270
Hours: Mon.-Fri. 8 a.m. to 5:30 p.m.;
messages can be left anytime.
Fax: (301) 504-0124 and (301) 504-0025

dell tech laboratories ltd. 4

 Outline of Presentation
1. What is/is not a chemical consumer product
2. Consumer vs. workplace regulations- GHS, SDSs, retailers
3. CCCR regulation overview
4. CPSC regulation overview
5. Differences between US and CAN consumer regulations
6. Additional US consumer labeling requirements
7. CCCR ‘Checklist’
8. Question period

dell tech laboratories ltd. 5

 What Is A Consumer Product?
CANADA: Means a product, including its components, parts or accessories,
that may reasonably be expected to be obtained by an individual to be used for
non-commercial purposes, including for domestic, recreational and sports
purposes, and includes its packaging.

USA: Means any article, or component part thereof, produced or distributed

for sale to a consumer for use in or around a permanent or temporary
household or residence, a school, in recreation, or otherwise, or (ii) for the
personal use, consumption or enjoyment of a consumer in or around a
permanent or temporary household or residence, a school, in recreation, or
otherwise; but such term does not include.. [pesticides, drugs, food, firearms,
etc]

dell tech laboratories ltd. 6

 Chemical Consumer Products
Hockey puck- Manufactured
Article
Drug

Glass cleaner

Detergent
Sunscreen-
NHP or Drug

Detergent- pods

Diffuser
Hand soap- Cosmetic

Car wax Pesticide

Air freshener

dell tech laboratories ltd. 7

 Consumer vs. GHS Regulations

CCCR symbols GHS symbols

Hazard Language Hazard Language

Do not get in eyes. If in eyes, rinse Wear eye protection. IF IN EYES: Rinse
with water for 15 minutes. Keep out cautiously with water for several minutes.
of reach of children. Remove contact lenses, if present and easy
to do so.
dell tech laboratories ltd. 8
 Consumer vs. GHS Regulations
Packaging Packaging

Test Methods example

Test Methods example
Leak test Ignition distance test
Flame projection Heat of combustion

dell tech laboratories ltd. 9

 Canada vs. USA
Canadian consumer products are regulated under the CCCR 2001 (Consumer
Chemicals and Containers Regulations, 2001) which falls under the
Canada Consumer Product Safety Act.

American consumer products are regulated under the CPSC (Consumer

Product Safety Commission).

…two SEPARATE regulations!

dell tech laboratories ltd. 10

 CCCR
Five main classification categories:

1. Toxic (Very Toxic, Toxic, Harmful)

2. Corrosive (Very Corrosive, Corrosive, Irritant)
3. Flammable (Spontaneously combustible, Very Flammable, Flammable, Combustible)
4. Quick Skin-Bonding Adhesives
5. Pressurized Containers

CCCR is very prescriptive.

Once the classification is determined, simply use the prescribed hazard statements
and symbols on your label.

dell tech laboratories ltd. 11

 CCCR
CCCR 2001 has 62 sections followed by 4 Schedules, which include:

• General requirements (record keeping, data sources, hazard categories)

• Container performance, design. Includes requirements and exemptions for

child-resistant containers.

• Presentation of information (technical specifications such as print, language,

color contrast, label legibility, location and order of info on Main Display
Panel (MDP)

• Classification and determination for all five categories and sub categories

• Test methods

dell tech laboratories ltd. 12

 CCCR
Steps to Labeling Compliance

• Is the product exempt from CCCR 2001?

• Determine which hazard categories the product falls under, if applicable.

• Determine the main display panel (MDP) of the container.

• From here, simply refer to the regulations or reference manual to determine

the required labeling elements (symbols, statements) as well as the print
specifications (minimum size of font) for the require

dell tech laboratories ltd. 13

dell tech laboratories ltd. 14
dell tech laboratories ltd. 15
dell tech laboratories ltd. 16
 CPSC
Classification categories:

• Highly toxic (acute)

• Toxic (acute)
• Chronic toxic (carcinogen, developmental, reproductive)
• Corrosive
• Irritant
• Strong sensitizers
• Extremely flammable
• Flammable
• Combustible
• Pressurized container

CPSC is not as prescriptive as CCCR 2001.

dell tech laboratories ltd. 17

 CPSC
“Not prescriptive”…?

• Only 1 symbol is ever used, for “Highly Toxic” substances:

• DANGER is the only signal word required for extremely flammable, corrosive, or
highly toxic substances. CAUTION or WARNING can be use for all other
hazardous substances.

• You may create your own precautionary and first aid statements, as well as
instructions for handling and storage, if appropriate.

• Must have “Keep out of reach of children’ (or an equivalent) when appropriate.

• Must have instructions to read cautionary material elsewhere on the label if there
is more than one principal display panel.

dell tech laboratories ltd. 18

 CPSC
Products requiring special labeling

The CPSC has a Specific Toxic Substances list which necessitate additional labeling.
It includes:

• 10% w/w diethylene glycol, ethylene glycol

• 10% w/w petroleum distillates including mineral seal oil, gasoline, naphtha,
Stoddard solvent, etc.
• 4 % w/w methanol
• Charcoal
• Art materials
• ….and more

These must have the signal word DANGER, the statement “Harmful or fatal if
swallowed” and “Call physician immediately.”

dell tech laboratories ltd. 19

 CPSC
Minimum font requirements

Area of main display surface in 0-2 >2-5 >5-10 >10-15 >15-30 >30
square inches
Type size in inches   

Signal word 3/64 1/ 16 3/32 7/64 1/8 5/32

Statement of hazard 3/64 3/64 1/ 16 3/32 3/32 7/64

Other cautionary material  1/32 3/64 1/ 16 1/ 16 5/64 3/32

dell tech laboratories ltd. 20

 CCCR vs. CPSC: Some differences
Language Requirements
• Canada needs Canadian French labeling in addition to English.

Hazard Categories
• Chronic hazards (carcinogens, neurotoxins, developmental or reproductive) found
in CPSC but not CCCR
• Sensitizer classification not required for CCCR

Hazard labeling
• Canada uses Signal Words: EXTREME DANGER, DANGER, CAUTION
• US uses Signal Words: DANGER, WARNING, CAUTION
• Statements are prescribed for CCCR but not necessarily CPSC
• Symbol are different

dell tech laboratories ltd. 21

 CCCR vs. CPSC: Some differences
Determination of Toxicity
• Inhalation toxicity for CPSC uses units mg/L per ONE hour.
• Inhalation toxicity for CCCR uses units mg/L per FOUR hours.
• Oral toxicity for CPSC cuts off at 5000 mg/kg
• Oral toxicity for CCCR cuts off at 2000 mg/kg

Labeling exemptions
• CCCR: small container exemption based on MDP (< 35cm²)
• CPSC: no small container exemption. Suggests using fold-back labels, pull off tags, etc.
which is not allowed for CCCR.

Consumer vs. workplace GHS

• CCCR labeling can replace Canadian GHS IF in certain instances, but GHS cannot
replace CCCR.
• CPSC labelling can replace US GHS IF it can be proven that frequency and duration of
use in workplace is equivalent to that of a consumer (29 CFR 1910.1200(b)(6)(ix))

dell tech laboratories ltd. 22

 Can I Combine US/CAN Labels?
YES…but we do NOT recommend it.
• Very difficult unless product is non-hazardous

• US/CAN consumers are not familiar with the other’s language/symbols, thus
causing confusion and putting consumer safety in jeopardy

• Marketing issues for Canadian market due to chronic classification

• Bilingual requirement = less available space

• Run the risk of non compliance, potentially resulting in stop distribution or recall.

dell tech laboratories ltd. 23

 Additional US Consumer Labeling Requirements
• California Prop 65
• Chemicals found on the Prop 65 list must be disclosed
• New pictogram and signal word required
• Specific safe harbor statements required
• https://delltech.com/blog/california-prop-65-compliance-deadline-2/

• VOC/CARB regulations
• California Air Resources Board (CARB) has issued regulations on limiting VOCs in consumer
products
• Determine which category applies to your product and calculate VOC content to see if limit is
exceeded.

• New York (DEC) Product Information Disclosure Program

• Enforcement delayed until January 1st 2020
• Disclosure in question is for intentionally added ingredients other than fragrances, and for non-
functional ingredients present above trace quantities
• The regulation will cover products related to consumer cleaning (soaps, detergents, etc.)
• https://delltech.com/blog/ingredient-disclosure-regulations-update-ny-dec-household-cleansing-product-information-disclosur
e-program/

dell tech laboratories ltd. 24

 Joe McCarthy, B.Sc.
Manager, Laboratory Services Group
Senior Regulatory Affairs Specialist

jmccarthy@delltech.com | 519.858.5024

dell tech laboratories ltd. 25

 CCCR Checklist
A full, thorough review and justification of classification in accordance with the
CCCR 2001.

dell tech laboratories ltd. 26

 Question Period

dell tech laboratories ltd. 27

 Thank You!
100 Collip Cir #220, London, ON N6G 4X8
(519) 858-5021
delltech.com

dell tech laboratories ltd. 28