NHP Product Facts Table and Bulletin No. 13: Your 2028 Labelling Plan

On 13 October 2026 Health Canada published Natural Health Product Licensing Bulletin No. 13, titled Interim Compliance Approach to Labelling-Related Monograph Updates. In plain terms, it tells natural health product (NHP) licence holders that they do not need to rush to update their labels to match the latest changes in Health Canada's Compendium of Monographs. Those monograph-related label updates can wait until the end of a new transition period that Health Canada plans to set through future regulations. The bulletin does not touch the bigger deadline that NHP companies have been planning around, and it does not pause safety-related label changes.

This is a helpful piece of flexibility, but it is easy to misread. Some companies will hear defer and stop all label work. That would be a mistake. The Product Facts table requirement, the single largest change to NHP labelling in twenty years, still carries a compliance date of 21 June 2028, and safety directions from Health Canada are still mandatory on their own timelines. This article explains what Bulletin No. 13 changes, what it does not, and how to turn the news into a sensible relabelling plan.

Executive summary

Health Canada has given NHP licence holders room to avoid making two separate label changes in a short window. Bulletin No. 13 says monograph-related label updates do not need to be implemented until the end of a new transition period that will be set when Health Canada pre-publishes amended labelling regulations, targeted for Canada Gazette, Part I, in spring 2027. The current compliance date for the 2022 labelling amendments, including the Product Facts table, remains 21 June 2028, and Health Canada has signalled it intends to propose a new transition period beyond that date. Safety-related label changes directed by Health Canada remain mandatory within their own timelines. The practical takeaway is to keep planning your Product Facts table conversion, hold routine monograph-driven wording changes until they can be bundled into that conversion, and never defer a safety update.

Monograph-related label updates can wait until the end of the new transition period. This is administrative flexibility, not a change to the regulations.
The Product Facts table and the other 2022 labelling amendments still apply, with a current compliance date of 21 June 2028.
Safety-related label changes communicated through a Health Canada notice remain mandatory and must be made within the stated timelines.
Draft regulations to make labelling more flexible are targeted for Canada Gazette, Part I, in spring 2027, with a new proposed transition period beyond June 2028.

What changed on 13 October 2026

What is it? Bulletin No. 13 is an interim compliance approach, not a new regulation. Why does it matter? Because Health Canada completed its update of the Compendium of Monographs in 2026, which would normally oblige licence holders to update their labels to match. What should companies do? Hold those monograph-driven label changes and fold them into the Product Facts table conversion, so that most products need only one label change rather than two.

Health Canada originally planned to finish updating the monographs by 2025 so that the monograph changes and the new labelling format would arrive together, requiring only one label change. The monograph work took longer than expected and was completed in 2026. That timing mismatch is the problem Bulletin No. 13 solves. By allowing monograph-related label updates to wait until the end of the forthcoming transition period, Health Canada removes the risk that a company updates a label in 2026 or 2027 to match a monograph, then has to change the same label again to adopt the Product Facts table format.

What the Product Facts table requires

What is it? The Product Facts table is a standardized, plain-language information box modelled on the Nutrition Facts table, introduced by the 2022 amendments to the Natural Health Products Regulations. Why does it matter? Because every licensed NHP sold in Canada must carry one by the compliance date, and for many products the whole label must be redesigned to fit it. What should companies do? Treat the conversion as a project, not a quick edit, and start now even though the deadline may move.

The amendments do more than add a table. They set out how information must appear so that consumers can read and understand it. In broad terms, the requirements cover a standardized Product Facts table listing the medicinal and non-medicinal ingredients, uses, warnings and directions; plain language; minimum type size and legibility rules; and contact information so consumers can reach the company. The Product Facts table must appear in both English and French. The exact format and content rules are set out in Health Canada's labelling guidance, and they are the requirements that Health Canada now plans to make more flexible through the regulations targeted for spring 2027.

The table below sets out the dates that matter, drawn from Health Canada's own bulletins.

Date	What happened or will happen
21 June 2022	Regulations Amending the Natural Health Products Regulations registered, introducing the new labelling requirements
21 June 2025	Amendments came into force; newly licensed NHPs expected to meet the new requirements from this date
7 March 2025	Ministerial Exemption Order aligned all NHPs to the same compliance date of 21 June 2028
11 May 2026	Bulletin No. 10 confirmed the 21 June 2028 compliance date and signalled more flexible labelling rules to come
13 October 2026	Bulletin No. 13 deferred monograph-related label updates until the end of a new transition period
Spring 2027 (targeted)	Draft amended labelling regulations to be pre-published in Canada Gazette, Part I, with a new proposed transition period
21 June 2028	Current compliance date for the 2022 labelling amendments, including the Product Facts table

Monograph-related updates versus safety-related updates

What is it? A monograph-related label update is a change you make because Health Canada revised a monograph in the Compendium of Monographs, for example a change to a recommended dose, a use or standard wording. A safety-related update is a change Health Canada directs to protect health, for example a new risk statement after a safety review. Why does it matter? Because Bulletin No. 13 treats them very differently. What should companies do? Sort every pending label change into one of these two buckets before deciding whether it can wait.

The line matters in practice. If Health Canada issues a safety review with a directed label change, as it did in its ashwagandha liver-safety review, that change is not covered by the administrative flexibility in Bulletin No. 13 and must be made within the timeline Health Canada specifies. Only routine monograph-driven wording changes qualify for deferral. The table below makes the split clear.

Can wait (deferred by Bulletin No. 13)	Cannot wait (still mandatory)
Label wording changes that flow only from a revised monograph	Safety-related label changes directed by a Health Canada notice, request or direction
Adopting updated recommended uses or doses from an updated monograph, where not safety-driven	Risk statements, warnings or contraindications added after a safety review
Aligning to monograph format changes that are purely administrative	Any change with a compliance date set by Health Canada in a specific notice

What the 21 June 2028 date still means

What is it? 21 June 2028 is the current compliance date for the 2022 labelling amendments, the date by which currently licensed NHPs must carry the new label format, including the Product Facts table. Why does it matter? Because Bulletin No. 13 did not move it. What should companies do? Keep this date in your plan while watching for the spring 2027 draft regulations, which are expected to propose a new transition period beyond June 2028.

Bulletin No. 10, published in May 2026, confirmed the 21 June 2028 compliance date and signalled that Health Canada intends to make the labelling requirements more flexible through amendments to the regulations. Bulletin No. 13 is consistent with that direction. Health Canada has said the new transition timeline will be determined in consultation with stakeholders and will be outlined as part of the regulatory amendments anticipated for pre-publication in spring 2027. Until those regulations are pre-published and the new transition period is set, the prudent planning assumption is that the format requirement stands and 21 June 2028 is the date to beat, while the monograph wording changes can be scheduled into the same project rather than done twice.

Why the deferral helps: avoiding two label changes

A label change is never only a design cost. It touches artwork, translation, regulatory review, printing, inventory sell-through and sometimes distributor and retailer relisting. Making two changes in two years, first for a monograph and then for the Product Facts table, doubles that cost and the risk of error. Bulletin No. 13 lets most companies make one change. For companies already managing other NHP transitions, such as the move of certain sports electrolyte products out of the NHP framework, consolidating label work into a single, well-planned project is the difference between a smooth transition and a scramble.

The flexibility only helps companies that plan for it. If you keep making monograph-driven changes piecemeal, you lose the benefit. If you inventory your products now, map which monographs affect which labels, and hold those changes for the Product Facts table conversion, you capture it. Health Canada also encourages licence holders to voluntarily adopt applicable monograph updates where feasible, so a product that is being relabelled for another reason is a good candidate to bring fully up to date in one pass.

NHP labelling transition checklist

Use this checklist to turn the bulletin into a plan your regulatory and marketing teams can act on.

Build a complete inventory of your licensed NHPs and the current label artwork for each product licence number (NPN).
For each product, list every pending label change and sort it into safety-related (mandatory now) or monograph-related (can wait).
Implement all safety-related changes within the timelines Health Canada has specified; do not defer these under Bulletin No. 13.
Map which updated monographs apply to which products so you know what wording will change when you convert the label.
Design the Product Facts table for a pilot product to understand the space, translation and legibility impact before scaling.
Schedule one combined label change per product that adopts the Product Facts table and the current monograph wording together.
Watch for the spring 2027 draft regulations and the new proposed transition period, and adjust your timeline when the date is set.
Keep a dated record of your rationale for deferring each monograph change, so your decision is defensible at an inspection.

Common mistakes

Hearing defer and stopping all label work. The Product Facts table deadline and safety updates are not deferred; only routine monograph wording changes are.
Deferring a safety change by mistake. A directed safety label change is mandatory on its own timeline, whatever Bulletin No. 13 says about monographs.
Assuming 21 June 2028 has moved. It has not. A new transition period is proposed, but it will only be set when the amended regulations are pre-published.
Making monograph changes piecemeal. Changing labels one monograph at a time throws away the single-label-change benefit the bulletin was designed to give.
Not documenting the deferral decision. Keep a written rationale for each deferred monograph change so an inspector can see it was deliberate and compliant.

Frequently asked questions

Do I have to update my NHP labels now that Health Canada deferred monograph changes?

Not for routine monograph-driven wording. Bulletin No. 13 lets you defer monograph-related label updates until the end of a new transition period. You must still make any safety-related label change that Health Canada directs, and you must still plan to adopt the Product Facts table format by the compliance date, currently 21 June 2028.

Did Bulletin No. 13 change the 21 June 2028 deadline?

No. The compliance date for the 2022 labelling amendments, including the Product Facts table, remains 21 June 2028. Health Canada plans to propose a new transition period beyond June 2028 when it pre-publishes amended labelling regulations, targeted for spring 2027, but until then the current date stands.

What is the difference between a monograph update and a safety update?

A monograph update is a change you would make because Health Canada revised a monograph, such as standard wording, a use or a dose. A safety update is a change Health Canada directs to protect health, such as a new warning after a safety review. Bulletin No. 13 lets you defer monograph updates but not safety updates, which remain mandatory within the timelines Health Canada sets.

What is the Product Facts table?

The Product Facts table is a standardized information box for NHP labels, modelled on the Nutrition Facts table, introduced by the 2022 amendments to the Natural Health Products Regulations. It presents ingredients, uses, warnings and directions in a clear, consistent, bilingual format with minimum legibility rules. Every licensed NHP must carry one by the compliance date.

When will the new transition period be set?

Health Canada has targeted spring 2027 for pre-publication of amended labelling regulations in Canada Gazette, Part I. The new transition period, which is expected to extend beyond June 2028, will be proposed through those regulations and finalized after consultation. Watch the Canada Gazette and Health Canada bulletins for the confirmed date.

Should I still adopt monograph updates voluntarily?

Where feasible, yes. Health Canada encourages licence holders to voluntarily adopt applicable monograph updates. If a product is being relabelled for another reason, bringing it fully up to date in the same pass is efficient and keeps your labels current. The deferral is a convenience, not a reason to let labels fall behind the science.

How MFLRC can help

MF License and Regulatory Consultants helps NHP companies plan and execute labelling transitions without wasted effort. We run label gap assessments against the Product Facts table requirements, sort your pending changes into safety-related and monograph-related buckets, and build a product-by-product relabelling schedule that captures the single-label-change benefit of Bulletin No. 13. We prepare monograph gap checks, draft and review label artwork for compliance, and support the quality and licensing records that prove your decisions were deliberate. We also help with the wider NHP compliance picture, from site licence scope and foreign building listings to claim verification and finished-product testing.

Not sure which of your label changes can wait and which cannot? That is exactly the question a short gap assessment answers, and getting it right now saves a second relabelling project later.

Book an NHP labelling gap assessment

Conclusion

Bulletin No. 13 is good news for NHP licence holders, but only if it is read correctly. It gives you room to avoid two label changes by deferring routine monograph updates until the Product Facts table conversion. It does not pause the format requirement, and it does not pause safety directions. The companies that benefit are the ones that inventory their products, separate safety changes from monograph changes, and plan one clean label change per product. Start that work now, watch for the spring 2027 regulations, and you will meet the deadline without paying for it twice.