This product classification is country specific – a cosmetic in one country may be considered a drug or a natural health product in another. In turn, the product classification dictates regulatory requirements, so a product requiring pre-market registration in one country may be brought immediately to market in another.
Determining what category or categories a product may be classified into is essential to ensure the proper licenses are obtained. In Canada, for example, the difference between a cosmetic and a cosmeceutical (natural health or drug) product must be carefully examined. A Canadian cosmetic product label may include only claims to only superficial, short-lasting effects and cosmetics don’t require pre-market notification. A cosmeceutical product falling into the drug or natural health product categories requires pre-market approval and a complete assessment of medicinal properties and benefits by Health Canada. Changes in regulatory definitions and product classifications are ongoing, which can complicate classification.
As the first step working with our clients, our team of experts will conduct a full product assessment and identify the appropriate product classification to ensure success in various marketplaces. As part of the product review and classification, our firm will identify any potential areas of concern (including verifying ingredients are compliant); associated costs (if applicable) for registrations; advantages and disadvantages of a particular product category and make recommendations on how to bring the product into compliance.
NHP Consulting can provide you with classification guidance and suggest label or formulation changes to shift classifications.