Effective October 3, 2014, Industry Canada revised labelling requirements for devices required to be certified or registered which have an integral (non-removable) display screen. This would include devices such as smartphones, tablets, smartwatches, and other regulated radio equipment and telecommunications devices.
The new rules permit label information previously required to be included directly on the device to be provided to consumers electronically (the e-label). Such information must be readily accessible by consumers within no more than three steps in a device’s menu, and without requiring special access codes or accessories such as SIM cards. Consumers must also be provided with clear and readily accessible instructions on how to access the regulatory information (i.e., a user manual, product packaging, packaging inserts or on a product-related website). The electronic information must be secured and not capable of modification or removal by an unauthorized party (including the user).
Information which was previously required to be contained in a user manual or on packaging may now, in some circumstances, also be included as part of the e-label provided certain conditions are met.
E-labelled devices imported into Canada must contain a physical label on the packaging at the time of importation, marketing and sale. Products that are not packaged individually and imported in bulk can contain a removable adhesive label to meet this requirement provided certain conditions are met. For devices already imported in individual packages ready for sale, the information previously required to be marked directly on the product may alternatively be provided on the package. All manner of marking requirements will continue to apply to information displayed electronically. Additional new rules apply to devices approved as certified transmitter modules.
To view the full scope of the new rules, see Industry Canada’s Notice 2014-DRS1003. For further assistance with these new rules or for other packaging or labelling inquiries, please contact the author of this update.
Part of the October 2014 - Franchise Review