cosmetic notification form

New format to CNF (Cosmetic Notification Form) coming Summer 2016

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Health Canada’s Cosmetics Unit is (finally) changing their CNF format from the pdf forms we all know and love-to-avoid, to an hopefully much more user-friendly HTML (website) form. Below is the original newsletter email. Because this information is not found on their website anywhere, before we posted this, we did some fact checking and asked our Cosmetics division contact to confirm the change, and that email is below that! 

What do you think of this change? 

From: Cosmaliste <cosmaliste@HC-SC.GC.CA>
Date: April 22, 2016 at 2:50:23 PM EDT
To: COSMETICS_LIST@LIST.HC-SC.GC.CA
Subject: NEW from Health Canada’s Consumer Product Safety Program /NOUVEAUTÉ du Programme de la Sécurité des  produits de consommation de Santé Canada
Reply-To: cosmaliste@HC-SC.GC.CA

Subject: New format for online forms

Based on Government of Canada Guidelines for Web Content Accessibility, Health Canada has committed to the replacement of PDF forms with HTML forms, which are expected to be launched in Summer 2016.  Once the HTML forms are available, you will no longer be able to use or submit the PDF forms online.

This update will impact the following forms:

        • Cosmetic Notification Form
        • Incident Report Forms (for Consumers and Industry to report an incident or event involving a consumer product or cosmetic)
        • Form for submitting additional documents to Health Canada

What this means for you:  

For cosmetic industry members: If you have notified Health Canada about a cosmetic product using the PDF form and need to make an amendment/discontinuation, OR if you intend to submit additional information on an incident, you are encouraged to send the changes using the current PDF forms as soon as possible.  Note that once the HTML form is available, and you need to inform Health Canada of an amendment/discontinuation to a cosmetic notification, you will have to manually re-enter all the information related to your cosmetic product. This is due to the fact that the information from a saved PDF form cannot be imported into the new HTML form.

The current PDF Cosmetic Notification Form can be found here:
http://www.hc-sc.gc.ca/cps-spc/cosmet-person/notification-declaration/index-eng.php

The current PDF Incident Report Forms & Form for submitting additional documents to Health Canada can be found here:
http://www.hc-sc.gc.ca/cps-spc/advisories-avis/incident/index-eng.php

For all other industry members or consumers:  If you intend to submit additional information on an incident, you are encouraged to send the changes using the current PDF forms as soon as possible.
———————————————————–
Sujet: Nouveau format des formulaires en ligne
Selon les lignes directrices sur l’accessibilité du contenu des sites Web du Gouvernement du Canada, Santé Canada s’est engagé à remplacer les formulaires PDF pour des formulaires HTML, qui devraient être disponibles à l’été 2016.  Une fois les formulaires HTML disponibles, vous ne pourrez plus utiliser ni soumettre les formulaires PDF en ligne.

Cette mise à jour aura un impact sur les formulaires suivants:

        • Formulaire de Déclaration des cosmétiques
        • Formulaires de Rapport d’incident (pour le signalement d’incidents ou d’événements par les consommateurs et l’industrie concernant un produit de consommation ou un produit cosmétique)
        • Formulaire pour soumettre des documents additionnels à Santé Canada

Ce que cela signifie pour vous:

Pour les membre de l’industrie des cosmétiques: Si vous avez déclaré un produit cosmétique en utilisant le formulaire PDF et souhaitez informer Santé Canada que le produit a été modifié ou n’est plus sur le marché (arrêt de vente), OU si vous avez l’intention de soumettre de l’information additionnelle au sujet d’un incident, vous êtes encouragés à soumettre vos changements à l’aide des formulaires PDF actuels aussi rapidement que possible. Veuillez noter qu’une fois que le formulaire HTML de Déclaration des cosmétiques sera disponible et que vous devez informer Santé Canada que votre produit a été modifié ou qu’il n’est plus sur le marché, vous devrez entrer à nouveau, manuellement, toute l’information reliée à votre produit cosmétique. Cela est dû au fait que l’information provenant du formulaire PDF ne peut pas être importée dans le nouveau formulaire HTML.

Le Formulaire de déclaration des cosmétiques actuel, en format PDF, est disponible ici:
http://www.hc-sc.gc.ca/cps-spc/cosmet-person/notification-declaration/index-fra.phpLe Formulaire pour soumettre des documents additionnels à Santé Canada et les formulaires de Rapport d’incident concernant un produit de consommation ou un produit cosmétique actuels, en format PDF, sont disponibles ici:
http://www.hc-sc.gc.ca/cps-spc/advisories-avis/incident/index-fra.php

Pour tous les autres membres de l’industrie et les consommateurs: si vous avez l’intention de soumettre de l’information additionnelle au sujet d’un incident, vous êtes encouragés à soumettre vos changements à l’aide des formulaires PDF actuels aussi rapidement que possible.

 

‎Hello Ms. Garrett,
 
Please consider this email a confirmation that the information received through the Cosmetics listserv is accurate.
 
‎There is no information currently available about this on our website at this time, which is why this “heads up” email was sent.
 
‎If your members have any questions or concerns, they can contact their nearest regional Product Safety Office:
  
Regards,
 
E.C.
Head, Cosmetics Unit
Consumer Product Safety Directorate 
Health Canada
cosmetic notification form

Cosmetic Notification Forms (CNF) – Part Two

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Wow, this month is flying by! I apologize for the delay in getting Part Two of this series on CNF published, especially since I know it is on the mind of so many of you these days.

In the first part of this series we talked about what a CNF is, and when you would need to file one. If you missed it, you can find it here. Today I’m going to talk a little bit about completing the actual filing process. A blog is not a good forum to actually walk through completing a form step by step, so I’m going to answer Frequently Answered Questions in this post.

The first thing to know is that there is no fee for filing a CNF with Health Canada.

Secondly, when you sit down to file your first one, it’s going to look really confusing; don’t panic, it’s really not that bad.

To file a CNF you will need to go to this link for English, http://www.hc-sc.gc.ca/cps-spc/cosmet-person/notification-declaration/index-eng.php, or this link for French, http://www.hc-sc.gc.ca/cps-spc/cosmet-person/notification-declaration/index-fra.php. Before you start actually filling out the form, I would suggest that you either print or download into another window the Guide to Filing Cosmetic Notification Forms, which is found here in English, http://www.hc-sc.gc.ca/cps-spc/cosmet-person/notification-declaration/guide-eng.php, and here in French, http://www.hc-sc.gc.ca/cps-spc/cosmet-person/notification-declaration/guide-fra.php.  This Guide will walk you through the steps to completing a CNF, and should make the process relatively painless, but if there continues to be confusion surrounding the process, let us know and we can put together a step by step tutorial. 

Questions:

1) Am I the Notifier, the Manufacturer or the Distributor?

The answer to this is sometimes you’re all 3! It depends on how you sell your product. If you are making product and selling it directly to the public, you are the Notifier (the company that is filing the form), the Manufacturer (the company that is making the product) and the Distributor (the company that is selling the product).

If you are selling product to stores at wholesale prices and they are selling to the public, you are the Notifier and the Manufacturer, and the store(s) would be listed as the Distributor. This also applies if you are making products for Private Label customers. You would have to file 1 CNF for your direct sales to the public, then file a separate CNF for each retailer or Private Label customer that sells your product.

2) What is a Notifier’s Reference and do I have to have one?

This is a description you use to identify a product for your own use. If you make Lavender Soap, you might use that description on your website, but for selling you may have an SKU identifier, such as SPLAV or maybe a number that identifies it on your system. You don’t have to enter this on the CNF form unless you want to.

3) Do I have to file a separate CNF for each different fragrance of a product?

If the manufacturer, distributor, function, and form of the cosmetic are the same for all the variations of the product, and the base ingredients remain the same, you can file one CNF and add all of the variations in colour, fragrance, or flavour by using the “May Contain” option. If you sell wholesale and/or Private Label as well, you would have to file 1 CNF for your direct sales to the public, and a separate CNF for each store or Private Label customer that sells your product.

4)  Do I list the exact percentage of that I use of each ingredient?

No. The reason for listing the ingredients is so that Health Canada can confirm you are not using ingredients that are prohibited from use in cosmetics, or if they are permitted but restricted, you are using a safe percentage. They do not need to know what your exact recipe is. If you use 20% shea butter in your lotion, you can use any range that contains your 20%. For instance, LL (Lower Limit, or the minimum that you would use) of 10% and UL (Upper Limit, or the maximum that you would use) of 40%. As long as your recipe stays within the ranges you list for each ingredient, you won’t have to file an amendment if you adjust your recipe slightly because you were short on shea butter and added a little more cocoa butter instead. NOTE: that only applies if all of the ingredients remain the same, and the amount you use falls within the range you have listed on your CNF. You cannot substitute ingredients without filing a new CNF.

5)  I only use fragrance oils in my products; how do I fill out the CNF for that?

If you make a product where the base is always the same, but you use multiple different fragrance oils, you file one CNF and you list your fragrance oils as “Parfum”. If you make some with fragrance oils and some with essential oils, you can still file one CNF, but use the “May Contain” option to list all of the options, including one for ‘Parfum”, and one for each different essential oil.

6)  When I’m listing my ingredients for soap, do I list what goes into the pot, or what comes out of the pot?

The definition of ingredients for the purpose of filing a CNF “excludes ingredients consumed during the manufacturing process”. Since lye is used up during the soapmaking process, the proper way to list the ingredients is by using the INCI for the soap that is produced. For instance, saponified olive oil is sodium olivate, saponified coconut oil is sodium cocoate, etc. You can find an INCI listing in the Files of our Facebook group Soapz and Stuffs.

NOTE: Although glycerine is created during the soapmaking process, you do not add it to your ingredients. The definition of ingredients for the CNF is “any substance or component that is deliberately added to the formulation.” Glycerine is created during the process, not added. Please note that you DO need to add it to your label. 

7) Ok, I’ve got my number now what?

Once you’ve filed your CNF, you may receive an email or telephone call asking you to change or clarify some information. If you don’t receive any questions, at some point you will receive an email or letter containing your Cosmetic Number. File it away in a safe place. If you change your recipe, or discontinue selling the product, you will need that number to file an amendment to your CNF. You will also need to have it to show to Health Canada inspectors who may show up at a market where you’re selling, or may find you online.

8) I’ve changed my recipe, now what?

Anytime you make a change to your recipe that increases or decreases an ingredient so that it no longer falls within the range listed on the approved CNF, you will need to file an amendment. You will also need to file an amendment if you make an existing product but use a new essential oil. You don’t need to file an amendment to add a new fragrance oil or flavouring, because the generic “parfum” and “flavour” used on your original CNF will still apply.

Okay, those are the FAQs that we see most often. If any of these answers are unclear, or you have other questions, please feel free to leave a comment below, and I will answer as quickly as possible. You can also post a question in our Facebook group, as we have many people there who are experienced in filing CNFs and would be happy to help.

cosmetic notification form

Cosmetic Notification Form (CNF) : Part One.

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imageIf you are new to the handcrafted bath and body industry in Canada, you may be wondering what all the fuss is about the Cosmetic Notification Form (CNF). I started to write a short post about CNFs, which quickly turned into an encyclopedia, so I have turned it into a two or three part series. Up first, what is a CNF and why do I need one?

Health Canada requires that anyone who sells a cosmetic product in Canada must file a CNF with them within 10 days of first making the product available for sale. Anyone means everyone, from the big name sellers such as L’Oreal or Lush, all the way to your neighbour who sells a few bars to family and friends just to help cover the cost of her raw materials: no exceptions. Aside from reviewing the ingredients in your product to confirm that all of your ingredients are approved for use in cosmetics, the CNF also provides Health Canada with your contact information, which will be used in the event that your product causes an allergic reaction or other issue that is reported to them. They will contact you and ask you to recall the product.

To get you started, here are some commonly asked questions about filing a CNF:

  1. Is my product a cosmetic? Health Canada defines a cosmetic as “”Any substance or mixture of substances manufactured, sold or represented for use in cleansing, improving or altering the complexion, skin, hair or teeth, and includes deodorants and perfumes.” This includes bath bombs, bath salts etc.
  2. What is not considered a cosmetic? If you make any claims that your product has any therapeutic or healing effect, it is no longer a cosmetic. For example, claims that your dandelion balm treats eczema, or that your tea tree oil mask clears up acne will result in your product being regarded as a drug or Natural Health Product, which requires testing and approval. Some products, such as bug spray or sunscreen are automatically excluded from the cosmetics category even if you make no claims about them. Sunscreen is considered a drug, and bug spray is a pesticide, and they must conform to much stricter regulations. Sale of handmade sunscreen is prohibited in Canada, and sale of handmade bug spray is currently under review.
  3. If I file a CNF, can I say that my recipe is approved by Health Canada? No. The only things that are screened by Health Canada when you file a CNF is that the ingredients you are using have been approved for use in cosmetics, and that you are not exceeding the maximum usage rate of any ones that are restricted. 
  4. What happens if I sell product and don’t file a CNF? That depends on how and where you sell your product. If you are that person who is just selling to family and friends, your chances of getting “caught” are pretty slim. However, there is always the chance that your product may cause an allergic reaction in someone, and it may get reported to Health Canada. Fines for non-compliance range from $1,000 to $25,000 per offence. Now you may think, “my friends would never do that to me”, but imagine if your product caused a reaction in their young child? Or, what happens if your friend buys soap from you and gives it as a gift to someone you don’t know? Still feel confident? It is always better to be in full compliance with all regulations. There is no fee to file a CNF. If you sell your products online, in stores, or at a market, your chances of being found non-compliant are increasing every week. Health Canada has staff reviewing websites and attending markets, and you could find yourself under scrutiny at any time.
  5. Okay, I’ve filed my CNF…now what? Once you’ve filed your CNF, one of two things will happen. You may receive an email or phone call from Health Canada indicating a problem with your submission. Respond to their inquiry, and work out the problem. If you aren’t contacted, then at some point you will receive a notice that your CNF has been approved and they will provide you with a number. Keep that number in a safe place. If you ever change the product you will need that number to file an amended CNF. More importantly, this is your proof of compliance which you can show to a Health Canada inspector if one shows up at your market, or contacts you by email requesting to see your CNF.

In Part 2 of this series, we will take a closer look at the actual filing process.  In the meantime, if you have any questions about the CNF, come join our Facebook group, Soapz and Stuffs and post a question. The group is open to everyone, not just HBBG members, and someone is always around to help.