The digital and physical labelling principles in the guide apply to specific product details. These include product identification, manufacturer or responsible party contact information, product composition, weight or net content, and warning statements or safe-use instructions. The scope also covers any other use instructions and legally required statements for the specific region.

For digital labels: Access should be provided via a single data carrier (e.g., a QR code) per product. There should be no additional text or pictograms placed next to the carrier to avoid operational complexity. Duplication of mandatory information across physical and digital formats should be minimized where permitted.

Points to note:

• To ensure a seamless consumer experience, digital information must be highly accessible and transparent.
• There should be Barrier-Free Access: Consumers must be able to access mandatory digital information quickly, without needing to register, provide personal data, or download any specialized apps.
• Language Compliance should be maintained: Digital labels must be viewable in the languages required for physical labels in the target market.
• There should be clear visual separation: Mandatory digital information must be visually separated from voluntary marketing or brand communications.
• For uninterrupted viewing: Regulatory information must be prominent and cannot be obscured by promotional screens. Furthermore, consumers should not be redirected away from mandatory details prior notification.
• Companies maintain full responsibility for their data and the technological mechanisms used to deliver it.
• Security & Privacy: Companies are required to implement cybersecurity measures to prevent data breaches. They must also protect consumer privacy and any personal data collected through the digital interface.

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Passed in May 2023, this legislation mandates that businesses must report intentionally added per- and polyfluoroalkyl substances (PFAS) in products sold within Minnesota and pay an associated fee.

​Products manufactured prior to July 1, 2023, are strictly excluded from these reporting requirements.

Companies should be aware that after a formal review period, all submitted data will become publicly accessible, with the exception of verified trade secrets.

​Critical 2026 Reporting Deadlines:

​Because the initial reporting deadline is approaching rapidly, manufacturers are highly encouraged to begin their data entry and submit any necessary technical support requests immediately. Please ensure your compliance teams track the following key dates:

• ​September 15, 2026: Initial PFAS reports are officially due.
• ​November 14, 2026: For manufacturers who previously secured a due date extension, requests for waivers must be postmarked or mailed by this date.
• ​December 14, 2026: Initial reports are due for manufacturers operating under an approved extension.
• ​February 1 (Annually): Moving forward, subsequent annual updates will be required each year on this date.

​

If you have any questions regarding how this update may affect your business, do reach out to us today.

The post Upcoming Deadlines for Minnesota’s PFAS Reporting appeared first on Focal Point.

​Key Provisions of RI HB 7734:

• The law strictly prohibits the sale of covered products (including cosmetics) that contain intentionally added PFAS.
• ​This prohibition will officially take effect beginning January 1, 2027.

​Considering the upcoming deadline, contact us today to review your product formulations to ensure full compliance before enforcement begins.

The post Rhode Island Enacts PFAS Ban on Covered Products appeared first on Focal Point.

DTSC’s decision is driven by environmental and health safety evaluations regarding this class of chemicals. The department has determined that PPD derivatives are expected to exhibit specific hazard traits, primarily dermatotoxicity and wildlife survival impairment.

​Regulators are concerned that these derivatives may cause or contribute to adverse dermatological impacts (such as skin sensitization) as well as severe adverse aquatic impacts (such as death).

​What This Means for Your Business:

​It is important for manufacturers and formulators to understand the immediate impact of this update. Adding a chemical to the Candidate Chemicals List does not create any new regulatory obligations. However, this listing serves as a strong indicator that PPD derivatives are under scrutiny and may be targeted for future evaluation or product prioritization by the DTSC.

​If you have any questions regarding this update or would like to get your formulas reviewed, our team is here to help. Contact us today.

The post California DTSC Updates Candidate Chemicals List to Include PPD Derivatives appeared first on Focal Point.

The R-ICL is an administrative list of substances found in products regulated under the Food and Drugs Act that were in Canadian commerce between January 1, 1987, and September 13, 2001. Under CEPA, substances on the R-ICL may be added to the DSL once specific eligibility criteria have been met.

With their addition to the DSL, these 656 substances have been removed from the R-ICL and are no longer subject to the New Substances Notification Regulations. This change may reduce regulatory requirements for companies using these substances in products regulated in Canada. For more such updates, contact us.

The post 656 substances added to Canada’s Domestic Substances List appeared first on Focal Point.

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.

The post Health Canada’s Update on Interchangeable Terms for NHPs and NPDs appeared first on Focal Point.

​While the published regulations formally introduced two new substance categories, i.e., Dechlorane Plus (DP) and decabromodiphenyl ethane (DBDPE), an update to ECCC’s Substances Search Tool reveals an increase in the listed substances, jumping from 209 CAS RNs under the 2012 Regulations to 3,218 CAS RN entries with the 2025 Regulations.

The addition of over 3,000 CAS RNs does not reflect new regulatory amendments, but rather individual chemicals that fall under broad structural definitions already regulated, particularly per- and polyfluoroalkyl substances (PFAS) such as PFOA, PFOS, and LC-PFCA precursors.

​The List is Non-Exhaustive: ECCC emphasizes that its database is a compliance guide, not an all-inclusive list. If a substance meets the structural definition outlined in the regulations, it is prohibited or restricted regardless of whether its CAS RN is explicitly cataloged.

​A screening by industry regulatory teams identified 13 cosmetic-relevant CAS RNs linked to International Nomenclature of Cosmetic Ingredients (INCI) names: including ingredients like Perfluorononyl Dimethicone, Perfluorooctylethyl Triethoxysilane, and certain fluorinated phosphates.

​Recommended Next Steps for Manufacturers and Brand Owners:

• Review all cosmetic ingredients and formulations against relevant substance groups and definitions.
• Request comprehensive ingredient disclosures and Certificates of Analysis (CoA) from the suppliers.
• Review relevant packaging, components and other materials associated with cosmetic products, as these may also be implicated.

Ensuring proactive compliance with evolving Canadian environmental standards is essential to preventing supply chain interruptions, product recalls, or import holds.

​If you have any questions regarding how this update may affect your business, do reach out to us today.

The post Canada Expands Substances Under Toxic Substances Regulations (2025) appeared first on Focal Point.

This latest order officially adds 174 substances to the NDSL. For companies manufacturing or importing chemical substances into Canada, this update provides a more streamlined regulatory environment.

Substances listed on the NDSL benefit from:

• Higher Volume Thresholds: Allowing for larger quantities to be handled before specific notification requirements are triggered.
• Streamlined Notifications: Providing a more direct and efficient path to compliance compared to substances not appearing on the list.

It is critical for stakeholders to remain aware of NDSL additions, as these changes can directly impact your notification strategy and timelines. Utilizing substances on this list often results in reduced administrative burden and faster processing for your chemical notifications.

If you need any assistance with these associated regulatory updates, our team is here to assist you.

The post 174 Substances Added to the Non-Domestic Substances List (NDSL) appeared first on Focal Point.

​Previously, navigating requirements could be complex due to the overlap with prescription drug content. The new landing page serves as a distinct resource, ensuring that NPD requirements are easily accessible and separated from other drug categories.

​Key Highlights of the New Portal

• ​The page provides comprehensive guidance covering the full product lifecycle, ranging from initial authorization to essential post-market activities.
• ​Both the Labelling Standards and Category IV Monograph pages have been refreshed with updated links and current information to ensure accuracy in submissions.
• The NNHPD has committed to updating this landing page regularly as new regulatory content and guidance documents become available.

​How We Can Help

​Navigating departmental updates and ensuring compliance can be a rigorous process. If you need any assistance with your NPD registrations, comprehensive labeling reviews, or interpreting how these new guidelines impact your specific product portfolio, we are ready to provide the necessary support.

The post NNHPD Launches Dedicated Landing Page for Non-prescription Drugs appeared first on Focal Point.

What is Changing?

The update focuses on Significant New Activity (SNAc) provisions. These are risk management tools used when a substance, already on the DSL, is used in a new quantity, concentration, or circumstance that could change its impact on human health or the environment.

• SNAc requirements have been applied to 54 existing substances and modified for 161 others.
• Part 2 of the DSL (Chemicals and Polymers) is now split into Division 1 (individual substances) and Division 2 (group of substances).
• A new Schedule 1 has been added to standardize information required for SNAc Notifications (SNAN).

Why This Matters to Your Business?

The most critical takeaway is the potential for instant non-compliance. Many of these changes specifically target consumer products and cosmetics, and the triggers for reporting are much lower than previous standards.

• Low concentration triggers: Some substances now have concentration triggers as low as 0.1% or 1%.
• Low volume triggers: Compliance requirements may now kick in at just 10 kg per year. This is significantly lower than standard New Substances Notification (NSN) triggers.
• Pre-emptive reporting: Companies are required to submit a Significant New Activity Notice (SNAN) at least 90 days before the day on which the significant new activity begins. If your current operations exceed these new thresholds, you may need to act immediately.

Recommended Next Steps:

• Review your current raw materials and finished product formulations against the updated DSL list.
• Check if any of your ingredients fall under the 223 impacted substances.
• Determine if your annual use exceeds the new concentration or volume thresholds. 
• File a SNAN for any significant new activity.

If you need assistance reviewing your formulations or determining your compliance status under these new requirements, please contact us. We are here to help you navigate these changes and ensure your products remain compliant.

The post New Compliance Requirements for the Canadian Domestic Substance List (DSL) appeared first on Focal Point.