Health Canada’s Update on Interchangeable Terms for NHPs and NPDs

by | Sep 8, 2026 | Cosmetics, Health Canada Updates, Natural Health Products, OTC Drugs, Our View

On August 20, 2026, Health Canada announced an update to the List of Interchangeable Terms for natural health products (NHPs) and non-prescription drugs (NPDs). First published in November 2025, this list was designed to support more flexible on-pack labelling.

The recent revisions intend to broaden the list’s applicability, increase labelling flexibility, and reduce the overall administrative burden for companies.

​Key Changes in the August 2026 Update:

  • ​Transition to a Non-Exhaustive List: For NHPs and NPDs covered by List D (low-risk products used on the skin or in the mouth), the terms provided in Health Canada’s table are now treated as examples rather than a strict, exhaustive list. Companies may use other equivalent wording provided it conveys the exact same meaning and meets Health Canada’s requirements.
  • ​Flexibility in Product Claims: The revised guidelines now allow the application of interchangeable terminology directly to NHP claims and the uses or indications for List D NPDs.
  • ​Grammatical Adaptability: Companies have additional flexibility with grammar, such as using different verb tenses interchangeably (e.g., “ask” versus “asking”). This is permitted as long as the fundamental meaning of the sentence is not altered.

​Important Limitations to Keep in Mind:

  • ​While the updated guidance provides more freedom to create consumer-friendly labels, it is not a blanket authorization to rewrite product information.
  • ​Interchangeable terms must always convey the identical meaning of the authorized term and cannot be false or misleading.
  • ​Some term substitutions are unidirectional. For example, the term “avoid” can be substituted with the stricter “do not,” but “do not” cannot be weakened to “avoid”.

​This regulatory update presents a valuable opportunity for NHP and NPD companies to review their existing/upcoming labels and replace overly technical jargon with more accessible language for consumers.

​If you need assistance with reviewing your label claims, please reach out to us.