What are the Canadian Requirements for Food-Contact Polymers?
We distribute polymers in North America. One such polymer is Polybutadiene for impact modification of HIPS for packaging. In the past we have only had to verify that the stabilizer in the polymer was FDA approved. Our HIPS customer is now telling us that we need to get "Health Canada" approval for the polymer. Can you provide any guidance on this process?
The process for obtaining approval in Canada depends largely on what your customer requires. More specifically, products that are used in CFIA-regulated facilities require CFIA approval. Such approval is generally obtained by submitting a simultaneous request to two different branches of Health Canada (CFIA and HPFB). However, for all other products (i.e., products that are not used in CFIA-regulated facilities), no premarket clearance is required in Canada. Nonetheless, HPFB does offer a voluntary program that allows companies to obtain "no objection" letters for the use of their food packaging products. Customers sometimes insist on these letters for assurance purposes. (For more information, please see the PackagingLaw.com article, Understanding Food Packaging Regulations in Canada: A Different Approach.)
If your company is not producing the stabilizer, but is instead obtaining it from an outside supplier, is not unusual to ask your supplier about any Canadian approvals for the stabilizer. If your supplier confirms that the stabilizer has not been evaluated by Health Canada, and you determine that an approval is needed, you will likely need the cooperation of your supplier for purposes of submitting any request to Health Canada.