REGULATORY NEWS | CANADA FOOD CONTACT MATERIALS
Health Canada is seeking input on a proposed framework that could supplement and significantly reshape today's largely voluntary pre-market review model by introducing broader notification and data-readiness expectations for the food packaging supply chain.
Regulatory status: Public consultation; the first-round comment deadline is October 9, 2026. The notification framework has not been adopted.
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Key Takeaways
Health Canada proposes online notification for food contact materials used with food sold in Canada.
The proposal could cover direct-contact components, components from which chemicals may migrate into food, and food service ware sold with prepared food.
The responsible notifier, notification timing, data format, treatment of confidential information, and final legal form remain under consultation.
A public knowledgebase, risk-based review process, and an approximately five-year phase-in period are also being considered.
Canada's Current Food Packaging Compliance Framework
Section B.23.001 of the Food and Drug Regulations (FDR) prohibits the sale of food in packaging that may transfer a harmful substance to the food. Section 4 of the Food and Drugs Act also prohibits the sale of food containing poisonous or harmful substances.
For most general food packaging materials, a Health Canada pre-market assessment is currently voluntary. Manufacturers, suppliers, formulators, and converters may submit a material, finished article, or individual constituent for a chemical safety assessment. When Health Canada reaches a favourable opinion for the proposed use, it may issue a Letter of No Objection (LONO). A LONO is an advisory opinion rather than a legal approval, and it does not transfer the seller's compliance responsibility to the authority.
What Health Canada Is Proposing
1. Mandatory Notification Through an Online Portal
Health Canada proposes that information on the food contact materials used for food sold in Canada be submitted through an online portal. The proposed scope would include:
parts of finished food packaging that directly contact food;
parts that do not directly contact food but may contain chemicals that can migrate into food; and
food service ware sold with prepared food, such as containers, straws, and utensils.
Packaging components separated from food by an effective impermeable barrier would not be subject to notification under the proposal. Notifications are expected to include the chemical composition of all substances in the food contact material and information on its expected distribution in Canada. However, the final data format, technical requirements, and confidentiality arrangements have not yet been established.
2. Responsibility May Fall on Different Supply-Chain Parties
Health Canada has not determined who should submit the notification. Options under discussion include the finished food packaging manufacturer or its delegate, the Canadian food manufacturer, the brand owner, the Canadian importer, or the food retailer. The timing is also open: Health Canada is considering whether notification should occur before distribution in Canada or within a defined period after the product enters the market.
3. A Public, Continuously Updated Knowledgebase
Health Canada intends to create a public knowledgebase recording the outcomes of food packaging safety evaluations. The initial content could draw on previously completed LONO evaluations, decisions from other jurisdictions when relevant to the Canadian context, and chemical safety assessments conducted under Canada's Chemicals Management Plan.
Submitted information would be cross-checked against the knowledgebase. Where the material, chemical composition, and conditions of use match an existing entry, the notifier could expect a notification number and an abbreviated LONO. Where no matching entry exists, or the intended conditions of use fall outside an existing entry, Health Canada would initiate an evaluation. Following a favourable assessment, the knowledgebase could be amended and the notifier could receive a notification number and LONO.
4. Risk-Based Review and a Possible Positive List
Health Canada is considering a tiered, risk-based process for evaluations and amendments to the knowledgebase. The detailed assessment framework is expected to be addressed in a later consultation.
The legal form is also unresolved. One option is an administrative, guidance-based model. The other is to embed the system in regulation as a positive list with which food contact materials must comply. If Canada ultimately adopts the positive-list approach, substances would need to be listed and used within the applicable material categories, conditions of use, migration limits, or other restrictions. This would represent a substantial change from the current framework, which relies primarily on the seller's safety responsibility and voluntary LONO submissions.
Proposed Timeline
The dates below describe the consultation and policy-development plan in the consultation paper. They are not implementation or enforcement dates for a final rule.
| Date / Period | Planned Step |
|---|---|
| October 9, 2026 | Deadline for comments in the first public consultation. |
| November 2026-January 2027 | Expected second public consultation. |
| By spring 2027 | Expected internal consideration of recommendations for a mandatory food packaging framework, subject to consultation outcomes. |
| After internal consideration | Regulatory development may begin, depending on the option or options selected. Further consultation and program refinement would follow as applicable. |
| Approximately five years | Proposed phase-in period to populate the knowledgebase, stabilize processes, and allow stakeholders to adapt. The period would begin only after the framework is established. |
Potential Impact on the Food and Packaging Supply Chain
If implemented, the proposal could move Canadian food packaging oversight toward a model combining market notification, knowledgebase matching, and regulatory evaluation where necessary.
However, regardless of the final form of the new framework, companies' existing safety responsibilities will remain unchanged. Food retailers and downstream manufacturers will continue to be responsible for ensuring that food products and their packaging comply with applicable safety requirements and for preventing the migration of harmful substances from packaging into food.
For industry stakeholders, the key challenges associated with the proposed framework may include, but are not limited to, the following:
Greater composition transparency. Complex structures may require information on monomers, additives, coatings, inks, adhesives, tie layers, and other components to move across the supply chain. Companies should expect to address confidentiality while still enabling regulatory assessment.
Possible effects on launch planning. If a food contact material or its intended use does not match the knowledgebase, a Health Canada evaluation could be triggered. Data availability and assessment timing may need to be considered earlier in product development and commercialization.
More structured safety evidence. Depending on the material and use, companies may need composition data, migration or extraction evidence, exposure information, and toxicological support. The exact requirements for the proposed framework remain to be defined, so testing should be planned only after an applicability and data-gap review.
What Companies Can Do Now
Industry stakeholders can begin preparing by establishing comprehensive inventories of material compositions and supplier information, while referring to food contact positive lists and regulatory requirements in major jurisdictions, such as the EU and the U.S., to strengthen safety management of food contact materials. These proactive measures will help companies better prepare for and timely address the potential impacts of the proposed framework on product compliance and supply chain management.
How REACH24H Can Help
REACH24H's food contact materials team supports regulatory compliance across multiple markets, including Canada. We will continue to closely monitor Health Canada's consultations and subsequent framework development activities, providing ongoing updates on regulatory developments and the evolving landscape of food packaging compliance requirements in Canada.
