Enabling you to identify and mitigate the intrinsic risk in your operations, supply chains and business processes.
Evaluating how your products and services meet and exceed quality, safety, sustainability and performance standards.
Validating the specifications, value and safety of your raw materials, products and assets.
Are you making or importing a Product? Are you sure?
A note of caution to all you formulators and importers out there – the regulatory definition of mixtures, manufactured items and products can differ depending on the jurisdiction, and there may be reporting requirements that apply to your material or substance of interest. In this last of a three-part series titled "Mixtures, Manufactured Items and Products", we look more closely at products and show that the definition of products is unique to Canada.
The term product is not defined within CEPA, 1999. A definition was introduced within the Notice with respect to certain substances identified in the Challenge, which was published in the Canada Gazette in 2006, and that definition (that a product excludes mixtures and manufactured items) has been limited to use under the Canadian Chemicals Management Plan. For the purposes of the Chemicals Management Plan, products can include, but are not limited to, the following examples:
Essentially the term product has been introduced within the Section 71 Surveys under the Chemicals Management Plan as a means of ensuring that all goods imported, manufactured and, in some cases, used in Canada are addressed in the data collection initiatives. Some key stakeholders, including retailers and companies regulated under the Food and Drug Act, better recognize the goods that they introduce into the Canadian marketplace as products. The Government of Canada wanted to ensure that all Canadians recognize that this program is not limited to industrial chemicals, i.e. drums, totes and tank cars, as may have been historically understood.
Within Europe, products and mixtures are captured by the same definition. For more information on the definition of Products in Europe, see Part 1 of this series.
Within the USA, products and mixtures are also captured by the same definition.
If your company is manufacturing, importing or using products in Canada, you may be subject to regulatory requirements. Carefully review all of the Section 71 Notices in the Canada Gazette to clearly understand whether the goods that you are importing, manufacturing or using in Canada require a response under these mandatory data call-ins. The risk assessment and risk management of toxic substances in Canada is no longer limited to industrial chemicals.
Today's expert blogger is Joyce Borkhoff. Joyce is the Director of the Intertek Chemicals Group and is well known for her ability to effectively characterize and communicate the impacts of the regulatory environment on the chemical industry. She is frequently invited to contribute to trade magazines and to present her advice and experience to a wide range of SME and large multi-national audiences. Her technical and regulatory experience and her deep knowledge of the Chemical Industry, makes Ms. Borkhoff uniquely qualified to provide practical, best-in-class service to help meet and understand Global Chemicals Management requirements.