Registration for Antimicrobial Treated Articles in Canada and United States
Consumer and commercial products, such as clothing, footwear, paint and plastic articles, may be treated with an antimicrobial pesticide to extend the durability, shelf-life, or claimed public health benefits of the article.
SAFEGUARDS | Softlines NO. 023/19
In the textile industry, antimicrobial technologies usually offer a biologically active surface that helps improve freshness, support hygiene and increase odour control.
In Canada, all products designed to manage, destroy, attract or repel pests that are used, sold or imported into Canada are regulated by Health Canada’s Pest Management Regulatory Agency (PMRA). According to the Regulation, the term “treated article” is generally used to refer to any product that has been intentionally treated with a pesticide. Articles can be treated with pesticides such as antimicrobials (e.g. textile treated with a preservative), insecticides (e.g. insecticide-treated clothing), and herbicides (e.g. herbicide-treated landscape fabric). A pesticide that has been intentionally incorporated into or applied to an article during manufacture for import, sale or use in Canada must be registered under the Pest Control Products Act (PCPA).
The pesticide registration in Canada involves the scientific evaluation of ingredients, extensive testing to determine the potential risks posed to human health and to the environment, and the pesticide’s value which is determined by assessing the product’s efficacy. A registration is typically granted for a term of 5 years, then subject to renewal. Pesticides can be used safely by following the label directions. The text on the label reflects the results of the scientific evaluation that the product has undergone and explains how to further reduce any potential risks to human health or the environment.
Antimicrobial treated articles that are distributed, imported, or manufactured in Canada can only be treated with a pesticide that is registered by PMRA for that use. This requirement applies to treated articles whether label claims are being made or not. Claims made about an article treated with an antimicrobial preservative must be consistent with the approved label for that antimicrobial preservative. It is the label claims in Canada, in addition to the use of, and the mode of action of, the product that ultimately determines whether a product falls under the PCPA and requires registration.
In United States, antimicrobial clothing and household textiles are regulated under The Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA). According to the Regulation, any product that kill or repel bacteria or germs are considered pesticides and must be registered with the Environmental Protection Agency (EPA) prior to distribution or sale. The EPA will not register a pesticide until it has been tested to show that it will not pose an unreasonable risk when used according to the directions. This includes pesticides used on clothing or textiles to provide antimicrobial or other pesticidal characteristics.
FIFRA does not allow companies to make public health pesticidal claims for any product distributed or sold unless the product has been approved and registered by the EPA or is covered by an exemption from registration. The EPA will take action against companies that make such claims. In addition, any pesticide produced in foreign countries must first be registered with the EPA before it can be imported into the United States.
 Canada - Pest Control Product Act
 Canada - Pest Management Regulatory Agency
 US EPA - The Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA)
 US EPA - Consumer Products Treated with Pesticides
SGS Global Softlines has an extensive network of over 40 laboratories worldwide, with a strong team of committed professionals from multi-disciplinary backgrounds. Our internationally accredited state-of-the-art testing laboratories offer a comprehensive range of physical, chemical and functional testing services for components, materials and finished products. We help your company ensure quality, performance and compliance with international, industrial and regulatory standards worldwide. Discover more at www.sgs.com/softlines.
For enquiries, please contact:
US & Canada Softlines Business Head
t: +1 973 461 7919
Stay on top of regulatory changes within your industry: subscribe to SafeGuardS!
Read more articles for the Consumer Goods and Retail industry© SGS Group Management SA - 2019 - All rights reserved - SGS is a registered trademark of SGS Group Management SA. This is a publication of SGS, except for 3rd parties’ contents submitted or licensed for use by SGS. SGS neither endorses nor disapproves said 3rd parties contents. This publication is intended to provide technical information and shall not be considered an exhaustive treatment of any subject treated. It is strictly educational and does not replace any legal requirements or applicable regulations. It is not intended to constitute consulting or professional advice. The information contained herein is provided “as is” and SGS does not warrant that it will be error-free or will meet any particular criteria of performance or quality. Do not quote or refer any information herein without SGS’s prior written consent.