Thank you for the question.
Under CUSMA, there's a cosmetics annex in the sectoral annexes that the Parliament of Canada endorsed. There were a number of principles with respect to how cosmetics are to be regulated. We're the only sector that has this provision in CUSMA.
They include not having duplicate regulations. You shouldn't have two sets of labelling requirements. Whatever you want to do in labelling should be under one set, for efficiency.
You should apply a risk-based system.
The parties use INCI, which are international nomenclatures that are known by consumers, importers and manufacturers. Using necessarily chemical codes and what have you to determine a substance isn't an easy way to recognize it for most consumer industries. This recognizes that as the important labelling provision for nomenclature.
It recognizes that cosmetics have a lot in common with drugs and natural health products. Toothpaste can be a drug, a cosmetic or a natural health product, and they should be regulated together.
These are the four guiding principles.
What we've asked is, if there is a provision inserted in this bill with respect to additional labelling requirements, it should exempt those products that already have mandatory ingredient labelling. If you have two sets of requirements, you're going to have different rules for size, font size and where they're located. How does anyone comply?
Again, that's the principle of the “best-placed act”. If you intend to add any of that to the bill, we think that you would want to exempt anybody now who is covered by another consumer product legislation that has labels—