Health Canada is conducting a mandatory cost-benefit analysis (CBA) to assess the positive and negative impacts of the proposed Ministerial Class Exemption Order on industry, consumers, and the Government of Canada. Industry feedback will help inform the analysis and may support refinements to the proposal that reduce regulatory costs while maintaining its policy objectives. While quantitative data is preferred, qualitative feedback is also valuable. Survey responses will be aggregated with other data sources for inclusion in the Regulatory Impact Analysis Statement (RIAS), and individual responses will remain confidential.
Cosmetics Alliance will be providing additional commentary on the CBA, focusing details on the benefit not being one of cost savings but rather cost avoidance.
Sponsors are not likely to pursue the existing pathway (Division 8 requirements). The proposed exemption is expected to remove a significant barrier to the market entry rather than generate conventional cost savings.
We encourage all members to complete the industry survey as thoroughly and accurately as possible. Your responses will provide Health Canada with the evidence needed to quantify the operational, financial, and administrative impacts of the proposed changes and ensure that the unique perspectives of our sector are reflected in the Cost-Benefit Analysis.
