The Natural Health Products Directorate (NHPD) has changed its name to the Natural and Non-prescription Health Products Directorate (NNHPD) subsequent to its recently expanded mandate to include the oversight of non-prescription and disinfectant drugs in addition to natural health products (NHPs). Please note that we are currently modifying documents to reflect this change.
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Health Canada is pleased to announce the release of the revised Sunburn Protectants Monograph for stakeholder consultation. The document is now titled "Guidance Document Sunscreen Monograph", to reflect the common Canadian term for this category of drugs.
This draft Monograph is intended to replace the existing Sunburn Protectants Monograph of October 12, 2006. The proposed Monograph applies to drugs subject to the Food and Drug Regulations administered by the Therapeutic Products Directorate (TPD) and natural health products subject to the Natural Health Product Regulations administered by the Natural Health Products Directorate (NHPD). It identifies the permitted ingredients, doses, directions and indications for use for these products, which will be required to appear on the product labels as well as the recommended supporting test methods.
The development of this Monograph is the result of a thorough survey of existing regulations, guidance documents, policies and current practices within Health Canada and other leading regulatory agencies.
Guidance documents are meant to provide assistance to industry and health care professionals on how to comply with governing statutes and regulations. Guidance documents also provide assistance to staff on how Health Canada mandates and objectives should be implemented in a manner that is fair, consistent and effective.
Guidance documents are administrative instruments not having force of law and, as such, allow for flexibility in approach. Alternate approaches to the principles and practices described in this document may be acceptable provided they are supported by adequate justification. Alternate approaches should be discussed in advance with the relevant program area to avoid the possible finding that applicable statutory or regulatory requirements have not been met.
As a corollary to the above, it is equally important to note that Health Canada reserves the right to request information or material, or define conditions not specifically described in this document, in order to allow the Department to adequately assess the safety, efficacy or quality of a therapeutic product. Health Canada is committed to ensuring that such requests are justifiable and that decisions are clearly documented.
This document should be read in conjunction with the accompanying notice and the relevant sections of other applicable guidance documents.
This monograph describes the requirements necessary to receive marketing authorization, that is (i.e.) a Drug Identification Number (DIN) or a Natural Product Number (NPN), for topical sunscreen products generally regarded as safe and effective, without additional supporting scientific data. Sunscreens may include products for use only as sunscreens and products which provide sun protection in addition to a cosmetic attribute. Products which do not meet the criteria outlined in this document should apply outside of the monograph stream.
Sunscreens are classified as natural health products (NHPs) if they contain ingredients from Table 1. Applicants applying for a natural product number (NPN) can access the appropriate forms and guidance [Accessed 2012-09-10].
The requirements set forth in this guidance align with the United States Food and Drug Administration Sunscreen Drug Products for Over-the-Counter Human Use: Final Rule (2011). As such, sunscreens meeting the requirements established by the US FDA Final Rule are also meeting the requirements outlined in this monograph.
Products that are intended to provide protection against sunburn and Ultraviolet (UV) rays. Sunscreen products are classified as drugs and must meet the requirements set out in Canada's Food and Drugs Act before they may be imported, advertised, or sold in Canada.
Sunscreens include products intended to be applied to the face or skin as makeup or some skincare products which also carry sunscreen claims. These may be foundations (in any form), facial moisturizers, lipsticks, lip gloss, makeup powder, and skin moisturizers (as long as it is clear that there is a primary moisturizing purpose).These do not include eye shadows (due to safety concerns regarding application to the area around the eye), or any product without an explicit primary cosmetic function included on the inner and outer panels of labelling. Acceptable cosmetic claims can be found in Health Canada's Guidelines for Cosmetic Advertising and Labelling Claims.
A critical wavelength of at least 370 nanometers (nm).
UV sun radiation in the spectrum of 320-400 nm; also referred to as "longer" rays. The UVA waveband has been further subdivided into UVA II (320-340 nm) and UVA I (340-400 nm)Footnote 1. UVA rays are the principle cause of long term skin damage due to sun but may also contribute to sunburn.
UV sun radiation in the spectrum of 290-320 nm; also referred to as "shorter" rays. UVB rays are the principle cause of sunburn due to sun exposure.
Sun Protection FactorFootnote 2
In order to provide adequate protection from UV rays, all broad spectrum sunscreen products are required toFootnote 3:
Sunscreen products may provide a UVA: UVB ratio labelling claim of not less than 1:3Footnote 5.
protection Footnote 8
|Source material Table 1 footnote 1||Quantity|
Table 1 footnotes
|Titanium dioxide (TiO2)||
CAS No. 13463-67-7
|Zinc oxide (ZnO)||
CAS No. 1314-13-2
CAS No. 150-13-0
|Medicinal ingredient preferred name||Synonyms and other recognized names||UV
|Terephthalylidene dicamphor sulfonic acid||
Certain ingredients that are formulated as nanosize, such as titanium dioxide and/or zinc oxide are acceptable ingredients. Refer to Section 10.2.1.
Balm, cream, emulsion, gel, lotion, mousse, oil, ointment, powders, paste, spray [including non-pressurized sprays, continuous (bag-on-valve) sprays, and aerosol [non-chlorofluorocarbons (CFC) based sprays]Footnote 9, stick, and suspension.
The following forms require review outside of the monograph (including but not limited to):
The use of the generic form "Liquid" is also not acceptable. As sunscreens are mixtures of substances not in pure form, a more accurate dosage form should be employed to communicate the finished product delivered at time of use.Footnote 12
The principal display panel should clearly communicate the following information:
All sunscreens providing broad spectrum protection with a SPF value ≥ 15, may use the following statement verbatim and bolded:
"The sun may cause sunburn, premature aging of the skin and skin cancer. Avoiding the sun, wearing protective clothing and regular use of sunscreens over the years reduces the chance of these harmful effects." [Adapted from the Canadian Cancer Society (2010) and the Canadian Dermatology Association (2011)].
The sun alert statement may not be broken down, displayed on separate locations on the labelling material and no substitution of words or phrases are permitted. This statement may not include a reference to the name of the product.
Sunscreens without broad spectrum protection or sunscreens with SPF value of < 15 must use the following statement verbatim:
"Skin Cancer/ Skin Aging Alert: Spending time in the sun increases your risk of skin cancer and early skin aging. This product has been shown only to help prevent sunburn, not skin cancer or early skin aging."
Statement(s) to the effect ofFootnote 12:
The following claims may be used on the product label provided that there is scientific product-specific data on file to support the claim:
The following additional information may also be included on labelling:
Titanium dioxide (TiO2) reflects short UVA range (320-340 nm), which is referred to as UVA-2 (or UVA-II), and UVB.Footnote 18 As this range of protection does not meet the critical wavelength requirement of at least 370 nm if used as a single medicinal ingredient, it must always be used in combination with other acceptable sunscreen medicinal ingredients to meet the broad spectrum requirement of this monograph. See examples of combinations of Natural Health Products (NHPs) in Table 3.
Zinc oxide (ZnO) reflects both short (320-340 nm, UVA-II) and long (340-400 nm, UVA-I) UVA radiation as well as UVB; however, ZnO at 25% provides a maximum of SPF 7 as a single ingredient.Footnote 19 As this ingredient would not meet the minimum Sun Protection Factor (SPF) value of SPF 15 if used as a single medicinal ingredient, it must always be used in combination with other medicinal ingredients. See examples of combinations of Natural Health Products (NHPs) in Table 3.
|Concentration||Sun protection factor (SPF)|
|Titanium dioxide||Zinc oxide||Total|
|10%||13Table 3 footnote 1||3Table 3 footnote 1||16|
|25%||38Table 3 footnote 2||7Table 3 footnote 2||45|
Any combination of the ingredients listed in Table 1 and 2 is permitted in which case the product will be considered a drug. Combinations with active ingredients not included in this monograph will not be considered monograph applications.
The upper limit for use as a single ingredient also applies when the ingredient is used in combinations.
Statement(s) to the effect of (Alternative statements can be used such as those included in the Sunscreen Drug Products for Over-the-Counter Human Use: Final Rule (2011)):
Adults and children > 6 months old:
Reapply every 2 hours or after swimming, towel drying, perspiring heavily, washing, or in the case of products applied to the lips, after eating or drinking.
Reapply at least every 2 hours or [insert 40/80 minutes as appropriate] after swimming or perspiring heavily or immediately after towel drying or washing,
Reapply after eating or drinking.
No additional statement is required.
For all products containing the non-medicinal ingredient(s) alpha-hydroxy acids (AHA), such as glycolic acid and lactic acidFootnote 22, at concentrations ranging from 3-10 % and/or retinol (or its acceptable derivatives, such as retinal acetate and retinal palmitate) at concentrations ranging from 0.1-1.0 %:
"This product contains [insert as appropriate: an alpha-hydroxy acid (AHA) and/or retinol] that may increase your skin's sensitivity to the sun and particularly the possibility of sunburn. Please limit sun exposure while using this product and for a week afterwards."
All drug products are subject to labelling requirements outlined in the Food and Drugs ActFootnote 23 and the Food and Drug RegulationsFootnote 24 (including but not limited to C.01.004, C.01.005, etc.). See Appendix 3 for some detailed examples.
Legibility of labels:
Although no specific type size is mentioned in the Regulations, Section A.01.016 specifies that all information required to appear on a label must be:
A person with normal vision, or those with corrective glasses that restore normal vision, should be able to read the information without straining. The colour, contrast, the position, and the spacing of the information are all to be taken into consideration in complying with these requirements. A type size of 10 point for text and 9 point minimum for tables are recommended for any sunscreen product package inserts, in keeping with section 2.2 of Health Canada's Guidance to Industry: Product Monograph. It is recommended that sunscreen product labels have a minimum of font size 9.
All Natural Health Products (NHPs) are subject to labelling requirements outlined in the Natural Health Product Regulations (including but not limited to sections 86(1) to 97).
This monograph describes those requirements that are specific to this class of drugs and to NHPs. Note that requirements described in the Food and Drug Regulations or the Natural Health Products Regulations (as applicable) must be met.
For products containing Table 1 medicinal ingredients only:
The finished product must comply with the minimum specifications outlined in the current Natural Health Products Directorate (NHPD) Compendium of Monographs.
The medicinal ingredients from Table 1 may comply with the specifications outlined in the appropriate monograph from the following Food and Drugs Act, Schedule B list of standards:
For products containing Table 2 medicinal ingredients:
All ingredient (medicinal and non-medicinal) and finished product specifications should, as a minimum, meet the standards described in the publications referred to in Schedule B of the Food and Drugs Act, or equivalent standards. Where no Schedule B monograph exists for the dosage form, specifications should be similar to those of a comparable compendial dosage form. In the absence of a Schedule B standard for any dosage form, testing must be adequate to demonstrate the product's identity, potency, purity and quality.
Manufacturers are reminded that sunscreens, like all drugs, are subject to Division 1A and 2 of the Food and Drug Regulations, so must ensure that their products are safe, effective, and of high quality. Further, all products must have established stability and are required to display the lot number and expiry date on packaging (C.01.004).
Any change to the manufacturing process, requires supporting data concerning the manufacturing information, specification and the identity that will be submitted outside the monograph. This applies to both active and non-medicinal ingredients, in terms of the final finished formulation.
Nanomaterials vary widely in composition, morphology, and other characteristics and cannot be considered a uniform group of substances. These substances may have physical, chemical, or biological properties that are different from those of their larger counterparts.
Nanomaterials and nano-enabled products continue to enter the Canadian marketplace in a variety of health products and food. Examples of current nanotechnology applications include food packaging, diagnostics and therapeutic products. While recognizing the potential health benefits of nanomaterials, it is important to ensure they are used safely and that their potential risks to the environment and human health are well understood and managed.
Therefore, licence holders are expected to continue monitoring and collecting new safety data as it emerges.
Applicants are required to keep information for record-keeping purposes when nano zinc oxide and/or nano titanium dioxide are used in sunscreen products. This information is required to be made available upon request. See Appendix 4 for a listing of the supplementary information related to nano ZnO and nano TiO2.
The recommended testing outlined in this section is expected to be performed on the finished formulation for each product.
The degree of Sun Protection Factor (SPF) protection should be measured using standardised, reproducible testing methods. Health Canada will accept SPF testing performed using any of the following in vitro or in vivo test methods:
To ensure that at least 95% confidence that a sunscreen has a true SPF equal to or greater than that claimed on the label and that any potential retesting of the formulation will not yield a mean SPF lower than that claimed on the label, it is recommended that the claimed SPF should be calculated as recommended in the United States FDA method, regardless of the employed testing protocol.
Values obtained from SPF testing may be rounded down if so desired by a manufacturer. However the converse does not hold true and SPF values may not be rounded up, as this misrepresents the level of protection offered by a sunscreen.
The degree of UVA protection should be measured using standardised, reproducible testing methods. Health Canada will accept the critical wavelength testing performed using any of the following test methods:
In order to establish that the product has met the 370 nm critical wavelength to establish the breadth of protection offered by a given product, the following test methods may be used:
In order to establish the magnitude of UVA protection offered by a given product, the following test methods may be used:
To establish that the product meets the optional claim for the ratio of Ultraviolet A: UVB protection of 1:3, the following test method may be used:
Colipa.The European Cosmetics Association.In vitro method for the determination for the Ultraviolet A protection factor and "critical wavelength" values of sunscreen products.Guideline, Prepared by the COLIPA In vitro UV Protection Method Task Force, June 2009.
The terms "water resistant (40 minutes/ 80 minutes)", are acceptable provided data is available to show that the product meets the testing requirements for these terms outlined in the following documents:
Similarly, products may carry a "sweat resistant" or "very sweat resistant" claim if the parameters for "water resistance" or "very water resistant" testing (respectively) have been met.
Non-medicinal ingredients: Nomenclature using recognized proper, common, or international names from a valid scientific reference may be used on drug packaging.
Non-medicinal ingredients must be restricted to those substances necessary for the formulation of the dosage form. Their concentration must not exceed the minimum required to provide their intended effect. They must be harmless in the amounts used, their presence must not affect the bioavailability, therapeutic efficacy or safety of the medicinal ingredients and they must not interfere with assays and tests for the medicinal ingredients and, if present, antimicrobial preservatives. Manufacturers are reminded that the presence of an ingredient in a published scientific reference [e.g. International Nomenclature of Cosmetic Ingredients (INCI) Dictionary] does not convey acceptability in a drug formulation, and should be relied on for nomenclature purposes only.
Ingredients of botanical origin added as non-medicinal ingredients must comply with the Drugs Directorate Policy, Herbs Used as Non-medicinal Ingredients in Non-prescription Drugs for Human UseFootnote 29.
All non-medicinal ingredients must also respect the limitations set out in the Food and Drug RegulationsFootnote 30, the Cosmetics HotlistFootnote 31 and the New Drug ListFootnote 32. Colourants are restricted to those outlined in Section C.01.040.2 of the Food and Drug RegulationsFootnote 33.
For products containing Table 1 medicinal ingredients only:
Ingredients must be chosen from the current Natural Health Product Ingredients Database (NHPID)Footnote 34 and must meet the limitations outlined in that database.
Sunscreen products should be sufficiently effective against UVB and UVA radiation to ensure a high protection of public health. To this end, a sunscreen product should provide a minimum UVB and UVA protection.
An increased sun protection factor (i.e. mainly UVB protection) should include an increase in the UVA protection as well. Therefore, the protection against UVA and UVB radiation should be related. Scientific findings show that certain biological damage to the skin can be prevented and reduced if the ratio of the protection factor measured in the persistent pigment darkening test (i.e. addressing mainly UVA radiation) is at least 1/3 of the factor measured by the sun protection factor testing method (i.e. addressing mainly UVB radiation).
Moreover, in order to ensure abroad protection, dermatologists recommend a critical wavelength of at least 370 nm. As such, in order to ensure that sunscreens offer sufficient protection for the user, all sunscreens must adhere to the following:
|Labelled category||Sun protection factor range
[UVB protection measurement]
|Recommended minimum UVA protection factor||Required minimum critical wavelength|
|Medium protection||15-29.9||Not less than 1/3 of sun protection factor||370 nm|
|Very high protection||SPF 50+ (plus)|
The following information must accompany the cover letter and other standard documentation provided with a Sunscreen Monograph Drug Submission Application for a Drug Identification Number(DIN):
Note that the evidence provided as requested may be audited during the course of the monograph review. In the course of an audit of the file or product, Health Canada may request additional specific test data (adhering to the test recommendations specific in this monograph) in support of the application.
For a Natural Health Product Licence Application for a Natural Product Number (NPN), by submitting a compendial application according to this monograph, the attestation covers the above noted points for drug applications in Appendix 2, Section A. Additional evidence or documentation does not need to be submitted, but must be made available to Health Canada upon request.
All drug products are subject to labelling requirements outlined in the Food and Drugs Act and the Food and Drug Regulations (Justice Canada 2008 and 2011) (including but not limited to C.01.004, C.01.005, etc,).
Manufacturers are reminded that drug labelling must include the following information in addition to the information outlined in this monograph:
Manufacturers of sunscreen products are reminded that small packaging labelling exemptions do not usually apply to products presented in > 5 millilitre volumes (as a rough guide).
The following information must be made available upon request:
Beasley et al. 2010; Wang et al. 2010; Nash et al. 2006
Sun Protection Factor (SPF) only communicates the level of UVB protection
See Appendix 2 for further details.
Nash et al. 2006
Colipa, June 2009; United States Food and Drug Administration (US FDA) 2011
If the proposed sunscreen contains an ingredient (whether listed in the application as an active or as non-medicinal ingredient) which provides protection from UV ray exposure and/or treats skin damage resulting from UV ray exposure, then the product will be considered to fall outside the scope of this Monograph.
Merck 2012; United States Pharmacopeia (USP) 35; CTFA 2008; Ph.Eur. 2012
Wang et al. 2010; El-Boury et al. 2007
Spray dosage forms must be accompanied by a further qualifier of the delivered dosage form, e.g. lotion, cream, powder, etc.
Refer to Appendix 1 for the product's UVA and UVB protection characteristics
These statements must appear together and prominently on the principle display panel of all labelling.
All iterations of the acceptable indications are referenced to Shaath 2005; APhA 2002.
This information applies to the premarket assessment of drug products only, as the Natural Health Products Directorate requires that manufacturers are solely responsible for non-sunscreen claims.
Only logos from the Canadian Dermatology Association are acceptable. Any other logo would need to be considered for its acceptability in context outside of the Monograph stream.
Sunless tanners containing skin dyes (for example. dehydroxyacetone) are permitted
As the frequency of use and required dosage are contradictory for the safe use of such combinations, insect repellents and sunscreens may not be combined either as Monograph applications or outside of the Monograph.
This list is not considered to be exhaustive as other innovative claims may be subject to review outside of the monograph.
Beasley and Meyer 2010; El Boury et al. 2007
El Boury et al. 2007
Diffey 2001; United States Food and Drug Administration (US FDA) 1999, 2006 and 2007.
Water resistance testing indicates that the product will retain its efficacy for longer than a regular sunscreen under these conditions, but still for less than 2 hours. Note that washing is still included as the physical friction of washing and the use of cleansing agents may remove the product. Water resistance testing is insufficient to demonstrate otherwise.
Justice Canada 2008
Justice Canada 2011
Until the ISO document is final, testing according to the International Sun Protection Factor Test Method (2006) will be acceptable.
Alternatively, the Japanese Cosmetic Industry Association (JCIA) PPD method as modified by the French health agency Agencefranšaise de sÚcuritÚ sanitaire des produits de santÚ - Afssaps.
Alternatively, the most recent United States Food and Drug Administration (US FDA) Monograph may be used.
When this methodology is used the labelled Canadian Sun Protection Factor (SPF) value would be the SPF value of the final product formulation determined following immersion to ensure accuracy in labelling and consistency with other international test results.
Health Canada 1995
Justice Canada 2011
Health Canada 2011
Health Canada 1999
Justice Canada 2011
Health Canada 2007