• Claims must remain cosmetic – In Canada, cosmetic claims are regulated under the Food and Drugs Act and the Cosmetic Regulations. While products may claim to moisturize, improve the appearance of skin or enhance radiance, claims suggesting tissue regeneration, stimulation of collagen production or cellular repair may imply a therapeutic purpose and could shift a product into the drug and natural heath product category, depending on the overall presentation.

• Scientific evidence matters – Many marketing materials reference in-vitro studies or clinical research involving injectable PDRN. Companies should ensure that any efficacy claims made for topical cosmetic products are supported by evidence relevant to the finished formulation and intended route of application. Extrapolating results from injectable products to cosmetics may not be considered appropriate substantiation.

• Ingredient sourcing and transparency – Since PDRN is commonly derived from salmon DNA, manufacturers should maintain appropriate documentation regarding ingredient identity, purity, manufacturing controls and supplier quality.

• Cross-border compliance – PDRN products originating from international markets may require claim adjustments before entering the Canadian market. Marketing language that is acceptable in one jurisdiction may trigger different regulatory classifications elsewhere, particularly when references are made to regeneration or DNA repair.

PDRN represents both an exciting innovation and a reminder that emerging ingredients require careful regulatory review. Companies introducing these products should evaluate ingredient documentation, product classification, claim substantiation, and advertising language early in the development process to support compliance while minimizing regulatory risk. If you wish to have your cosmetic ingredients or claims reviewed prior to market entry, please contact us.

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