At the December 2003 Society of Cosmetic Chemists annual meeting, I presented a one-day session on international cosmetic regulations, and concluded by saying that 2004 would be the year of Canada. So far in 2004, three major changes have occurred.
Canadian Environmental Protection Act
The Canadian Environmental Protection Act known as CEPA was reviewed in detail in my February 2003 column. As this act covers all ingredients that enter Canada, either as raw materials or in finished cosmetic products (this also includes all ingredients in fragrances), it is worthwhile to review the major points, expand on the details, and consider how to comply.
All chemicals entering the environment of Canada must be on Canada’s Domestic Substances List (DSL) or be notified (reported to the Canadian Environmental Protection Agency). There is an exception for ingredients that were in commerce in foods, drugs and cosmetics between 1987 and 2001. These are on a list called the Transition List and currently ingredients on this list can be used for these applications without further notification. If the same chemical is used in non-FDA regulated uses, that chemical must be notified.