Health Canada has expanded the labelling flexibility available to natural health products (NHPs) and certain non-prescription drugs through an updated List of Interchangeable Terms.
Announced in Natural Health Product Licensing Bulletin No. 12 on August 20, 2026, the update allows companies to use clearer or more consumer-friendly language without necessarily changing the meaning authorized by Health Canada.
The List of Interchangeable Terms identifies words and phrases that may be substituted on product labels when alternative wording conveys the same meaning as the authorized term.
Examples include:
Following stakeholder feedback, Health Canada has broadened the application of this policy in three important ways.
First, interchangeable terms may now be used within NHP uses or indications, commonly referred to as product claims. This provides licence holders with greater flexibility to present authorized claims in language that consumers can more readily understand.
Second, the same flexible approach now applies to certain low-risk non-prescription drugs included on List D, provided the products follow the applicable Health Canada monographs. These product categories include sunscreens, acne treatments, anti-dandruff products, antiperspirants, mouthwashes, and medicated skin care products.
Third, Health Canada has clarified that the table contains examples rather than an exhaustive list for NHPs and List D non-prescription drugs. Other terms may therefore be acceptable when they convey the same meaning and comply with the requirements of the guidance.
The update can help NHP companies create labels that are easier for consumers to read while remaining aligned with the product’s terms of market authorization. In most cases, using an acceptable interchangeable term on an NHP label does not require a notification or post-licence amendment.
However, the policy does not authorize companies to expand, strengthen, or otherwise change an approved claim. Every substitution must preserve the meaning of the authorized wording and must not create a false, misleading, or deceptive impression.
Context remains critical. A term that is acceptable in one statement may alter the meaning or regulatory significance of another. Product Facts Table (PFT) headings and subheadings also remain subject to specific limitations.
For non-prescription drugs outside List D, the table continues to operate as an exhaustive list, and interchangeable terms cannot be applied to authorized claims.
Greater flexibility also requires careful regulatory judgement. Source Nutraceutical, Inc. (SNI) supports NHP and non-prescription drug companies with Canadian label reviews, claim assessments, PFT development, licence amendments and market-entry strategy.
Our team can assess whether proposed consumer-friendly wording remains consistent with the product’s authorization and broader Canadian labelling requirements, helping companies improve label clarity without introducing avoidable compliance risk.
Contact SNI to discuss your Canadian NHP or non-prescription drug labelling project.
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