The NHP Product Facts Table: What Changes Before 21 June 2028

For twenty years, natural health product labels in Canada looked largely the way each company designed them. That era is ending. By 21 June 2028, every natural health product sold in Canada must carry a standardized Product Facts table, a bordered box with fixed headings in a fixed order, modelled on the Drug Facts table already familiar from non-prescription drugs. It is the single largest change to NHP labelling in a generation, and most licence holders have not started.

The change comes from SOR/2022-146, the Regulations Amending the Natural Health Products Regulations, and it is not a small artwork tweak. It touches every stock keeping unit in a portfolio, and it interacts with new allergen declaration rules, general legibility standards and bilingual requirements. This article explains what the Product Facts table requires, who must comply and when, and how to run the relabelling project so it does not become a last-minute scramble in 2028.

Executive summary

SOR/2022-146 requires a standardized Product Facts / Info-produit table on natural health product labels. The labelling provisions came into force on 21 June 2025.
Products licensed before 21 June 2025 were given an additional three-year transition. In practice, an exemption order aligned the timelines so that all natural health products must comply by 21 June 2028.
The table has seven fixed headings in a fixed order and strict typography rules set out in sections 93.1 and 93.2 of the Regulations.
Section 93.3 gives a defined path when the label surface is too small, including condensed type minimums and, only as a last resort, a leaflet, insert or website.
This is portfolio-scale work. Treat it as a project with a schedule, not a series of one-off reprints.

What is the NHP Product Facts table?

The Product Facts table is a standardized, bordered information box, required by section 93.1 of the Natural Health Products Regulations, that presents a product's key information under seven fixed headings in a set order. It replaces free-form panel labelling with a consistent format consumers can read the same way on every product.

Section 93.1(1)(f) requires the outer label, or the inner label where there is no outer label, to show one of three options: a single bilingual table titled "Product Facts / Info-produit" (or "Drug Facts / Info-médicament" for the relevant products), or two separate tables, one in English and one in French. The table can be shown vertically or horizontally, and the order of the two languages in a bilingual table may be reversed, but the content and structure are prescribed.

The seven headings must appear in this order: Medicinal ingredients, Uses, Warnings, Directions, Other information, Non-medicinal ingredients and Questions. Each heading has defined content. Medicinal ingredients lists the proper or common name, quantity per dosage unit, authorized potency where applicable, and the source material. Warnings carries the risk information and, where relevant, the bold allergen and aspartame statements. Questions gives a contact telephone number, email or website for the licence holder.

The seven headings, in order

The bilingual headings and their fixed order are set by section 93.1(4). The table below shows the English and French headings that must appear.

Order	English heading	French heading
1	Medicinal ingredients	Ingrédients médicinaux
2	Uses	Usages
3	Warnings	Mises en garde
4	Directions	Mode d'emploi
5	Other information	Autres renseignements
6	Non-medicinal ingredients	Ingrédients non médicinaux
7	Questions?	Questions?

Who must comply, and by when?

Every natural health product sold in Canada must carry a compliant Product Facts table by 21 June 2028. The labelling provisions of SOR/2022-146 came into force on 21 June 2025, and a transition arrangement gives all products until 21 June 2028 to meet them.

The mechanics are worth understanding, because they explain why the deadline is a single date for everyone. SOR/2022-146 was registered in June 2022, but its labelling provisions were given a delayed coming into force of three years, to 21 June 2025. Products licensed before that date received an additional three-year transition period, giving them until 21 June 2028. Products licensed on or after 21 June 2025 would, in principle, have had to comply immediately.

To avoid a two-speed market, Health Canada published an exemption order in the Canada Gazette, Part II on 26 March 2025. It exempts natural health products licensed on or after 21 June 2025 from the new labelling requirements, comes into force on 21 June 2025 and is repealed on 21 June 2028. The net effect is straightforward: whether a product is old or new, the Product Facts table must be in place by 21 June 2028. There is no advantage in waiting, and a great deal of risk in leaving a full portfolio to the final months.

The typography rules that catch people out

Section 93.2 sets strict typography for the table. The title and headings must be bold, the title must be larger than the headings, the headings must be larger than the body text, headings must be separated from the following content by solid black lines, and the whole table must use a single font.

These are not suggestions. A table that uses two fonts, drops the solid black separators, or sets a heading in the same size as the body text is non-compliant even if every word is correct. In practice this is where design teams working from an old template stumble, because a legacy panel design rarely satisfies the relative type-size hierarchy or the separator rule without a full rebuild. Building the table from the regulation, rather than retrofitting an old label, is faster and safer.

SOR/2022-146 also introduced broader legibility requirements for NHP labels, so contrast, minimum type sizes and clarity now matter across the label, not only inside the table. A relabelling project is the right moment to bring the entire label up to the new standard, not just the box.

When the label is too small: section 93.3

Section 93.3 sets a defined order of steps when the available label surface cannot hold the full table. You must first try a bilingual table and condensed type, down to a 5 point minimum for non-medicinal ingredient information and 5.5 points for the rest, before moving any information off the label.

Only if the table still does not fit may the non-medicinal ingredient information be shown in a leaflet attached to the outermost container, in a package insert, or on a website. If space is still insufficient, the source material description for medicinal ingredients may follow to the same leaflet, insert or website. Any table shown in an insert or online must itself comply with sections 93.1 and 93.2. This staged approach matters for small bottles and blister formats, and it is a common reason to redesign the container rather than fight the label surface.

One thing you cannot push to a website is the allergen declaration. It belongs under Warnings, on the physical label, in bold. For the full allergen rules and the cross-contamination carve-out, see our companion article on NHP allergen labelling and the NHPR rules.

How to plan the transition

The organizations that will meet 21 June 2028 comfortably are treating this as a project now. A relabelling programme across a full catalogue takes months, not weeks, once you account for design, translation, regulatory review, print lead times and stock run-out. Leaving it late risks obsolete inventory, rushed reviews and errors of exactly the kind that trigger recalls.

Start with a portfolio inventory: every SKU, its current label, its licence terms and its container format. Prioritize by print schedule and stock levels so you convert labels as they naturally come up for reprint where possible. Build a master Product Facts template that is compliant by construction, then adapt it per product. Route each converted label through the same disciplined artwork approval and reconciliation workflow you would use for any label change, described in our guide to preventing labelling errors, with QAP sign-off before print.

Product Facts table transition checklist

Inventory every SKU with its current label artwork, product licence terms and container format.
Build a master Product Facts / Info-produit template with the seven headings in the correct order and compliant section 93.2 typography.
Confirm medicinal ingredient entries show proper or common name, quantity per dosage unit, authorized potency where applicable, and source material.
Place risk information, allergen and aspartame statements correctly under Warnings, with allergen and aspartame statements in bold.
For small containers, apply the section 93.3 steps in order: bilingual table, condensed type to the 5 pt and 5.5 pt minimums, then leaflet, insert or website only for permitted overflow.
Bring the whole label up to the new general legibility standard, not only the table.
Sequence conversions against print schedules and stock run-out to limit obsolete inventory.
Route every converted label through artwork approval, reconciliation and QAP sign-off before printing.

Common mistakes

Assuming new products have more time. They do not. The exemption order aligns everyone to 21 June 2028.
Retrofitting an old panel design instead of building the table from the regulation, which usually breaks the typography rules.
Reordering or renaming the seven headings. The order and wording are fixed by section 93.1.
Moving allergen information off the label to a website to save space. Allergen declarations must stay on the physical label under Warnings.
Leaving the whole catalogue to 2028 and creating a print and review bottleneck that invites errors.

Frequently asked questions

What is the Product Facts table on Canadian supplements?

It is a standardized, bordered information box required by section 93.1 of the Natural Health Products Regulations. It presents medicinal ingredients, uses, warnings, directions, other information, non-medicinal ingredients and a contact question under seven fixed headings, in English and French.

When does the NHP Product Facts table become mandatory?

All natural health products sold in Canada must carry a compliant Product Facts table by 21 June 2028. The labelling provisions came into force on 21 June 2025, with a transition to 21 June 2028 for existing products, and an exemption order aligned newer products to the same date.

Which regulation created the Product Facts table?

SOR/2022-146, the Regulations Amending the Natural Health Products Regulations, which added sections 93.1 to 93.3 to SOR/2003-196 and introduced new allergen and legibility requirements.

What are the seven headings on the Product Facts table?

In order: Medicinal ingredients, Uses, Warnings, Directions, Other information, Non-medicinal ingredients and Questions. The order and wording are fixed by section 93.1 and cannot be changed.

What if my product label is too small for the table?

Section 93.3 requires you to try a bilingual table and condensed type first, down to 5 point and 5.5 point minimums. Only then may non-medicinal ingredient information move to a leaflet, package insert or website, and any such table must still comply with sections 93.1 and 93.2.

Can I keep my current labels until they run out?

Only until 21 June 2028. After that date, product on the market must carry the compliant Product Facts table. Sequencing conversions against reprint cycles and stock levels before the deadline is the way to limit waste while staying compliant.

How MFLRC can help

MF License & Regulatory Consultants helps natural health product licence holders convert entire portfolios to the Product Facts table on time and without errors. Our natural health product services and quality assurance support include Product Facts table gap assessments, master template design, per-SKU label review against the product licence, small-surface strategy under section 93.3, SOP development for artwork control, QAP sign-off and project management across the full transition.

The 2028 deadline is closer than a full relabelling project makes it feel. If you have not started scoping your portfolio, now is the time. We can build the plan, the templates and the review process with you.

Book a consultation

Conclusion

The Product Facts table is a rare thing in regulatory affairs: a large, unavoidable change with a clear deadline and a defined format. That makes it manageable, but only if you begin in time. The licence holders who start scoping now will convert on their own schedule. Those who wait will convert on the printer's. For the wider compliance picture, see our overview of NHP licensing, GMP and labelling obligations.