Thursday, June 25, 2009

Are there any exemptions under the CCCR?

There are a number of classes of products that are not required to have their labels be CCCR compliant in Canada.
The first set of products are those which are given an exemption undersection 3 of the Hazardous Products Act. They are as follows:
- cosmetics
- drugs
- explosives
- food
- medical devices
- nuclear substances
- pest control products
- tobacco products
Section 2 of the CCCR-2001 lists 3 classics of products that arespecifically exempt because they follow under other regulations:
- portable petroleum containers
- lighters
- fire extinguishers.
Under section 2, products are also exempt if there is no reasonableexpectation that the consumer could be exposed to the hazardous chemicalsinside.
Finally, products are excluded if they are used exclusively in theworkplace, as workplace chemicals are governed under WHMIS. Note thatif a product is available for sale to the general public, then it must meetthe CCCR-2001 requirements, even if it is primarily used in a workplacesetting. The Health Canada Guide to the CCCR-2001 notes that "[s]tatementssuch as "For Industrial Use Only" on the label do not remove consumerproducts from the requirements of the CCCR-2001."

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