Answer first
For vaping products intended for retail sale in Canada, the Vaping Products Labelling and Packaging Regulations set detailed requirements for labelling, health warnings, nicotine statements, ingredient information and, in defined situations, child-resistant containers. A B2B team should control the exact product configuration, packaging layer, market artwork, warning source and technical record before a product is manufactured, imported, listed or released.12
What is covered by the federal framework?
Health Canada describes the Vaping Products Labelling and Packaging Regulations as having two parts: labelling requirements under the Tobacco and Vaping Products Act, and labelling, child-resistant-container and nicotine-related requirements under the Canada Consumer Product Safety Act.1 The regulatory text states that Part 1 applies to vaping products intended for retail sale in Canada and their packaging, subject to stated exclusions.2
The framework is more than a graphic-artwork task. It can affect the product itself, the exterior package, an interior package, a leaflet, a tag and the immediate container. The applicable presentation route depends on the product configuration, display surface, nicotine status, kit format and other defined conditions.23
The documentation checklist in one view
| Review area | What official sources describe | B2B control to establish |
|---|---|---|
| Nicotine statement | A vaping product containing nicotine must display a nicotine concentration statement. It uses prescribed wording and mg/mL format; placement depends on product and packaging configuration.2 | Controlled nicotine specification, packaging-layer map and approved artwork version |
| Health warning | A nicotine-containing vaping product must display the health warning set out in the Government of Canada’s incorporated List of Health Warnings for Vaping Products, as amended from time to time.24 | Current official warning source, bilingual proof and placement approval |
| Languages and legibility | Required health warnings and permitted nicotine-free expressions are displayed in both official languages. The Regulations also set presentation, durability and visibility rules.3 | Bilingual copy master, packaging proof and print-production sign-off |
| Ingredient list | Every vaping substance requires an ingredient list with prescribed titles and common names, subject to stated flavour-denotation and placement rules.5 | Formula record, supplier evidence and controlled ingredient-copy file |
| Child-resistant container | Specified immediate containers must meet child-resistant-container requirements unless a stated exception applies. The responsible person must evaluate certain factors and retain defined records.5 | Container standard or test evidence, compatibility assessment and document-retention owner |
The table is a record-management aid, not a substitute for the current statutory text. Requirements must be assessed against the actual product and commercial activity.
Nicotine concentration statements: treat content and placement as one decision
The Regulations require every vaping product that contains nicotine to display a nicotine concentration statement.2 The statement must show nicotine concentration in the vaping substance in milligrams per millilitre, preceded by “Nicotine — ” and followed by “mg/mL.” Different placement rules apply to un-packaged devices or parts, packaged devices or parts, refill products and kits.
The federal nicotine-concentration rules are a separate control layer: Health Canada states that the Nicotine Concentration in Vaping Products Regulations establish a maximum of 20 mg/mL for products manufactured or imported for sale in Canada and prohibit packaging and sale where the displayed concentration exceeds that amount.1
For a B2B release file, the formula value, product specification, packaging artwork, product data record and market version should be checked together. A label can be visually consistent yet unsuitable if it reflects the wrong concentration, package layer or product configuration.
Health warnings: use the current official source and validate presentation
The Regulations require nicotine-containing vaping products to display the health warning listed for the product in the Government of Canada’s List of Health Warnings for Vaping Products, as amended from time to time.2 The current published list states: “WARNING: Nicotine is highly addictive.”4
The regulatory text also contains detailed presentation rules. It requires the first word of a health warning to be upper-case and bold, requires the English and French warnings to be immediately beside or below one another without being combined, and sets rules for visibility, size and use on display panels, leaflets and tags.3 The official text includes a 180-day transition period after publication of an amended list for a person who was displaying the previous warning in accordance with Part 1.2
A compliance file should record the official warning-list version, source URL, date checked, language proof, product and packaging placement, and any approved leaflet or tag treatment. A product render is not evidence that a final printed item meets the applicable requirements.
Bilingual, durable and readable information is part of product control
Required health warnings and any permitted nicotine-free expression must be displayed in both official languages in the same manner.3 The Regulations also require required information to be clear and legible, use specified presentation conventions and remain legible through normal transportation, storage, sale and use conditions.
This matters operationally. Changes in print supplier, package size, closure, label stock, ink, panel layout or package format may affect whether required information remains visible or legible. Packaging governance should have a pre-production review, production proof, approved artwork identifier and change-control record. A commercial reprint should not be assumed to preserve the original compliance result.
Ingredients and child-resistant-container records: separate evidence files
For every vaping substance, the Regulations require an ingredient list that begins with prescribed English and French titles and identifies each ingredient by its common name, without abbreviation. The text provides a defined route for ingredients or combinations added solely to produce a flavour: they may be denoted as “flavour” and “arôme” rather than by their common names.5
Part 2 also includes child-resistant-container requirements for specified immediate containers. The Regulations state that every immediate container that is a vaping device or vaping part, and every other immediate container containing a vaping substance at a nicotine concentration of 0.1 mg/mL or more, must meet the child-resistant-container requirements unless the stated exception applies.5 The text describes applicable standards or an equivalent standard, evaluation using good scientific practices, documentation and retention duties.
The responsible person should maintain distinct but linked records: controlled formula and ingredient-list source, package specification, container and closure specification, testing or standards evidence, compatibility assessment, and proof of the actual market version. The Regulations require certain child-resistant-container documents to be kept for at least three years after manufacture or import, and relevant documents requested by an inspector to be provided within 15 days of request.5
A six-step B2B packaging review workflow
- Define the exact Canadian product version. Record the device, part, substance, kit, immediate container, exterior package and intended retail market. Do not use a trade name as the only identifier.
- Confirm nicotine status. Connect the formula, concentration value, nicotine statement, health warning and product configuration in one controlled record.
- Map every required information location. Identify the main display panel, interior package, exterior package, product surface, leaflet and tag. A requirement can move with a package configuration.
- Check bilingual content and presentation. Review language pairing, wording, contrast, font treatment, dimensions, visibility and durable printing against applicable provisions.
- Build ingredients and container evidence files. Link ingredient source data, formula status, child-resistant-container specification, test evidence and compatibility records to the market version.
- Lock release through change control. Require regulatory, quality and document-control approval before a changed formula, concentration, warning, label, package, closure or supplier enters production, import or sale.
Questions to resolve before production or import
| Decision area | Question | Suggested evidence |
|---|---|---|
| Product identity | Which exact Canadian configuration is being reviewed? | Controlled product specification and SKU or version record |
| Nicotine data | Does the formula value match every required product and package statement? | Formula approval, artwork proof and concentration check |
| Warning source | Which official warning-list version has been applied? | Source URL, retrieval date and approved bilingual copy |
| Packaging layers | Where must information appear for this product and package configuration? | Panel map, package dieline and regulatory review log |
| Ingredients | Does the final ingredient list trace back to a current formulation record? | Formula, supplier documentation and copy master |
| Container | Is child-resistant-container evidence required for this immediate container? | Standard or test evidence, compatibility review and retention file |
| Change control | Who approves a change before product release? | Named owner, release checklist and revision history |
Frequently asked questions
Is a 20 mg/mL nicotine limit the only packaging requirement?
No. The federal 20 mg/mL nicotine limit is one requirement. Labelling, health-warning, ingredient, child-resistant-container and provincial requirements can also apply depending on product and activity.12
What wording is used for a nicotine concentration statement?
The Regulations state that the statement shows nicotine concentration in milligrams per millilitre, preceded by “Nicotine — ” and followed by “mg/mL.” The required placement depends on the product and package configuration.2
What health warning is currently listed for vaping products containing nicotine?
The Government of Canada’s list currently states: “WARNING: Nicotine is highly addictive.” The list is incorporated by reference and may be amended, so the current source should be checked before release.24
Must required warnings be in English and French?
The Regulations require required health warnings, and any permitted nicotine-free expression, to be displayed in both official languages in the same manner. They also contain detailed presentation requirements.3
When should a trade team review child-resistant-container documentation?
Review before release whenever the actual immediate container and vaping substance fall within relevant requirements. The regulation contains specific child-resistant-container, evaluation and record-retention provisions.5
Official sources
- Health Canada — Vaping products regulations, reviewed 28 September 2026.
- Justice Laws Website — Vaping Products Labelling and Packaging Regulations, SOR/2019-353, page 1, current to 3 September 2026; page modified 22 September 2026; reviewed 28 September 2026.
- Justice Laws Website — Vaping Products Labelling and Packaging Regulations, SOR/2019-353, page 2, current to 3 September 2026; page modified 22 September 2026; reviewed 28 September 2026.
- Health Canada — List of Health Warnings for Vaping Products, reviewed 28 September 2026.
- Justice Laws Website — Vaping Products Labelling and Packaging Regulations, SOR/2019-353, page 3, current to 3 September 2026; page modified 22 September 2026; reviewed 28 September 2026.