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ARTICLE · 14 SEPTEMBER 2026

Canada Considers Positive List Approach For Food Contact Substances

Steptoe LLP
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Health Canada has launched a public consultation on a proposed regulatory overhaul that would fundamentally transform how food packaging materials are evaluated and approved for use in Canada. The agency is considering implementing a mandatory notification system and potentially creating a binding positive list of approved substances, marking a significant departure from the current voluntary Letter of No Objection framework.

CanadaConsumer Protection

Health Canada has opened a public consultation on a proposed overhaul of how food packaging materials and articles are regulated in Canada. As discussed more fully in our StepLadder Series article, and under the current regulatory framework, Health Canada requires that a food-contact material or article shall be safe for the intended use when food contained in such material or article is placed on the market for sale in Canada. There is no affirmative requirement, however, that Health Canada conduct a safety evaluation (except in limited circumstances). Instead, Health Canada reviews the safety of a food-contact material for its intended use only when a company voluntarily submits a request for a Letter of No Objection (LONO).

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