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Child Resistant Container Certifications for Tanks & Pods

Part II of the Vaping Product Labeling and Packaging Regulations (VPLPR) requires that all re-fillable tanks and pods comply with child resistant standards under sections 50 – 55. These requirements are scheduled to go into effect as of January 1st 2021. The global pandemic has resulted in substantial delays to industry compliance efforts, and while VITA continues to work with government on this issue, we urge stakeholders to continue making every effort to become compliant.

In support of compliance efforts, VITA has developed a list of products that have been certified and that are currently (or soon to be) available for retailers to order on the Canadian market.

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Background Information

Health Canada Alert!

On November 19th Health Canada issued the following notice
to the industry regarding their CRC Enforcement Plan

What's Been Happening?

Over the past year, the VITA team has been actively engaged with international device manufacturers, associated companies, and Health Canada regarding the upcoming implementation of child resistant requirements for refillable tanks and pods.

While we were prepared for numerous challenges that needed to be overcome, the impact of the COVID pandemic could not have been anticipated and caused substantial delays. Despite this fact, significant progress has and continues to be made towards certifying refillable tanks and pods.

CRC List Details

The CRC list has been set up so that it can be updated live, meaning that as new products are certified and released, the list will be updated and automatically distributed to subscribers at the end of the week. If no changes are made during the week, no update will be sent. Stakeholders are encouraged to share this within the industry and to notify VITA staff of any certified device currently not on this list.

Each device on this list has:

  • A completed test report based on one of the 3 protocols identified in regulations OR;
  • Has a “Push To Fill” or similar mechanism that should be considered compliant under Exception (2) or section 51 subsection (a).

The VITA team is also tracking a large number of devices that are currently in the process of certification, many of which are new and un-released. The tracking of new/un-released products requires confidentiality, so this list can only include devices that have already been announced or directly authorized by the manufacturer.

Availability

Almost all pre-order shipments of newly certified devices began to arrive in Canada in October. This list does not relate to wholesaler inventory levels, the availability column relates exclusively to when device orders were first received or when they are expected to arrive in Canada.

Kits

The CRC requirements specifically apply to refillable tanks and pods, however, these devices are commonly sold both individually and as part of a starter kit. Under the ‘Kit’ column we have included the kits that the tank/pod is known to be available in, but there may be others and it’s likely that this will expand over time.

CRC Version

Some newly certified devices are new products designed for the Canadian market, others are updated versions of popular devices already on the market. In both cases there are often different versions made for markets with different regulatory requirements. The most common nomenclature being used to identify Canadian compliant tanks/pods by manufacturers is “(CRC Version)” however this does not apply to all brands so extra attention when placing orders is advised.

Certifications

Certification documentation is typically only available upon request, and only the manufacturer or importer is required to have them on hand for enforcement. That said, VITA has confirmed that each applicable device on this list has certification documentation provided by the manufacturer and we are currently working to provide access to certifications via Dropbox link. Further details and access will be provided to those who subscribe as soon as possible.

Feedback

It is in the best interest of all industry stakeholders that CRC tank/pod information is shared as widely as possible. High levels of noncompliance across the industry can be used to justify the case for further restrictions, and this situation must be avoided at all costs. To that end, stakeholders are encouraged to provide feedback and input regarding this list and any related challenges. The more information we can add to this list and share, the higher the compliance rate will be.

Liability

VITA cannot guarantee or be held liable regarding the validity of any certification or device exemption for products on this list.

Please send any feedback, information, or questions to daniel@vitaofcanada.com

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