Classification of Nicotine as a hazardous substance under CCCR 2001.
Gone are the days when E-Cigarette Vendors could supply copious amounts of raw nicotine to eager do-it-yourself-ers. Since the implementation of the Canadian Chemicals and Containers regulations (CCCR 2001) any vaping product which contains over 66mg/g of nicotine is considered a very toxic substance and is illegal to manufacture, import, and sell in Canada. Not only do products need to be below the “very toxic” threshold for use in Canada, but they also need to be properly identified as a Toxic substance by CCCR 2001 standards. But what does that mean, exactly?
CCCR-2001 differs from CCPSA in that it applies only to products which contain Nicotine and focuses primarily on the proper identification of the hazard of that product. CCPSA focuses on the traceability of all vaping products sold within Canada, and proper labeling of consumer information such as manufacturers address and batch code, and CCCR 2001 ensures that the risk associated with product use and accurately and clearly identified on the label of each product.
To be considered compliant under CCCR 2001, manufacturers and importers must be extremely diligent when preparing the labels for their products. The first step is to ensure each container used for holding e-liquids has a child proof certification from one of the three approved certification bodies stated in the CCCR documentation. If an officer were to enter a store and request the certification of a specific bottle sold at that location, the store has 15 days to produce both the certificate as well as the accompanying study report to prove those bottles are child proof and therefore legal for sale in Canada. If a certificate and report cannot be produced, the bottles will be subject to recall. The reason behind this rule is rather straight forward – by ensuring the bottles are child proof, the risk of a child ingesting the toxic product is reduced significantly.
Once approved bottles are in use, they then must be properly labelled with all CCCR 2001 elements. There are two sets of elements that may be required depending on bottle size – for bottles that have a main display panel of 35cm2 or more, the label will require the works. Hazard symbol, signal word, primary and secondary hazard statements, and first aid instructions are all on the list of minimum requirements for this bottle. But be careful here – the display panel is not calculated the way most would think. Make sure to check the CCCR 2001 guidelines to obtain the proper calculation.
The second option for labeling is anything which would be considered a “small bottle exemption”. This applies to all bottles with a main display panel that is less than 35cm2, and only requires the hazard symbol & signal word (note: this list applies to CCCR 2001 elements only. Other labeling requirements are still required under CCPSA and CPLA). On top of these elements, the nicotine concentration must be listed clearly using proper scientific notation such as mg/mL. If there is no Nicotine, then the bottle must be labelled as such. Many vendors opt to remove the hazard identifications given that a 0mg/mL product does not contain a hazardous substance. This is a tricky system to work with, as anything labelled as 0mg/mL absolutely must be Nicotine Free otherwise some major charges could be laid. The toxic category which Nicotine falls under applies to all e-liquid products that range from 0.1mg/g to just below 66mg/g, meaning that if a product has even 0.1mg/g of Nicotine then it must be labelled properly. A quick and easy way to check this during the manufacturing process or even in-store is to purchase a small container of nicotine test-strips. Similar to pH strips, nicotine strips can be placed in the e-liquid and are excellent for quick confirmation of the presence of nicotine. They are easier to use than titration kits, and excellent for qualitative analysis.
While the liability for improperly labelled products fall on the manufacturer or importer of the e-liquid in questions, it is also the responsibility of store owners to ensure they are putting compliant products on their shelves. Even if they won’t be fined directly, they still hold responsibility for supplying a hazardous product to a customer without properly notifying that customer of the risks associated with the product. Store owners should never be afraid to contact their suppliers to discuss compliance, as they are the last check before the product reaches the consumer. By working together, we can create an industry that supports informative purchases and safety for all.
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