Health Canada’s Natural and Non-prescription Health Products Directorate (NNHPD) has updated its List of Interchangeable Terms to provide greater flexibility when labelling Natural Health Products (NHPs) and certain non-prescription drugs (NPDs).
The August 2026 update significantly broadens how the List can be used. For NHPs and NPDs covered by List D, the terms in the table are now examples rather than an exhaustive list, meaning other equivalent wording may be used when it conveys the same meaning and meets Health Canada’s requirements. Interchangeable terminology may also now be applied to uses or indications (claims) for these products.
The update is intended to reduce administrative burden while giving companies more flexibility to develop consumer-friendly labels without changing the meaning of their authorized product information. However, flexibility does not eliminate the need for regulatory review. Alternate wording must remain consistent with the product’s terms of market authorization and cannot be false, misleading, deceptive, or create an erroneous impression.
Companies should review existing and planned labels to identify where the expanded flexibility may be beneficial.
Health Canada’s Natural and Non-prescription Health Products Directorate (NNHPD) first published the List of Interchangeable Terms in November 2025 as a resource for companies seeking greater flexibility in the terminology used on Natural Health Product (NHP) and non-prescription drug (NPD) labels.
On August 20, 2026, Health Canada announced an important update to the List in response to stakeholder feedback. According to the NNHPD, the revisions are intended to broaden the List’s applicability, provide greater flexibility in labelling, and reduce administrative burden.
The updated guidance is now Version 1.1, last updated in August 2026. Health Canada identifies three principal changes: greater flexibility in applying interchangeable terms to NHPs and List D NPDs, including their use in claims; clarification that the List is non-exhaustive for those products; and revisions to the table itself, including changes to row 69, relocation of content to a new row 95, and the addition of two new footnotes.
For industry, the significance of the update is not simply the addition or rearrangement of individual terms. The larger change is the way companies are permitted to use equivalent language on their labels.
This provides manufacturers and product licence holders with additional opportunities to use terminology that may be clearer or more appropriate for consumers while maintaining consistency with the product authorization.
The List establishes terminology that may be used interchangeably on the labels of NHPs and NPDs. Health Canada explains that the purpose is to provide flexibility in on-pack labelling even where a particular term appears in the product’s market authorization.
The central principle, however, remains unchanged: changing the terminology cannot change the meaning of the authorized information.
Health Canada specifically states that context must always be considered when determining whether two terms genuinely convey the same meaning. The alternate wording must remain consistent with the terms of market authorization issued under the Natural Health Products Regulations or Food and Drug Regulations, as applicable.
This is particularly important because the flexibility provided by the List does not override section 9 of the Food and Drugs Act. Product labelling and advertising cannot be false, misleading or deceptive, or likely to create an erroneous impression regarding the product’s character, value, quantity, composition, merit or safety.
The List can also have relevance to advertising, although Health Canada notes that applicable advertising policies and guidance must still be followed.
The August update substantially expands the practical usefulness of the List for NHPs and List D NPDs.
Health Canada’s Bulletin No. 12 identifies three primary revisions:
Health Canada states that these revisions were made in response to stakeholder feedback and are intended to increase flexibility while reducing administrative burden.
| Area | Previous Approach | August 2026 Approach |
| NHP claims | Interchangeable terminology was not extended to claims under the original approach. | Interchangeable terms may be used in NHP uses/indications (claims). |
| List D NPDs | More limited application of the interchangeable-term framework. | List D NPDs receive the same expanded approach when they follow applicable Health Canada monographs. |
| Terms outside the table | Flexibility centred on terms expressly identified in the List. | For NHPs and List D NPDs, the table contains examples and other equivalent terms may be acceptable. |
| Other NPDs | Interchangeable terms were restricted to the List. | The List remains exhaustive, and claims must use the exact wording in the terms of market authorization. |
| Underlying requirement | Alternate terminology must preserve the authorized meaning. | This remains unchanged. Context and equivalence of meaning continue to be essential. |
This distinction between NHPs/List D NPDs and other NPDs is one of the most important elements for companies to understand.
For NHPs and List D NPDs, Health Canada now expressly states that the terminology appearing in the table consists of examples. Companies may therefore use terminology that does not appear in the List, provided it meets the requirements established in the guidance.
Interchangeable terms may also be used in the “uses/indications” or claims for these products.
For other NPDs, however, the approach remains considerably more restrictive. Table 1 continues to represent an exhaustive list, and interchangeable terms do not apply to claims. Exact claim wording contained in the terms of market authorization must continue to be used.
The clarification that the List is non-exhaustive for NHPs and List D NPDs is potentially the most consequential part of the update.
Health Canada’s table contains 95 rows of interchangeable terminology, covering relatively straightforward substitutions such as “daily,” “every day,” “per day,” “each day,” and “a day,” as well as terminology that may make technical language easier for consumers to understand. For example, “hypertension” may be expressed as “high blood pressure” or “elevated blood pressure.”
Under the revised approach, an NHP company is not necessarily restricted to those exact examples.
That flexibility must nevertheless be applied carefully.
The test is not simply whether two words appear similar. Companies need to consider whether the alternate terminology conveys the same meaning in the specific context in which it appears and whether the revised wording remains consistent with the authorized product information.
There are also situations where substitutions work in only one direction. Health Canada notes, for example, that the term “avoid” may be replaced by the more stringent “do not,” but “do not” cannot be weakened to “avoid.”
Similarly, individual entries may have limitations based on context. The updated row 69, for example, allows “strengthen,” “fortify,” and “reinforce” to be used interchangeably specifically in an oral/dental health context. Health Canada also specifies that “block,” included alongside “prevent,” “neutralize,” and “protect,” is not appropriate for sunscreen labels where primary and secondary sunscreen monographs apply.
The takeaway is important: the List provides regulatory flexibility, not a blanket authorization to rewrite product information.
The guidance also contains two broader principles that can be useful when preparing labels.
First, Health Canada states that other tenses of a verb may generally be regarded as synonymous even when they are not individually captured in the table, provided changing the tense does not alter the meaning of the sentence. Health Canada provides “ask” and “asking” as an example.
Second, duration-of-use statements from NHP monographs may be represented in days, weeks or months, allowing an equivalent representation to be used in product labelling or advertising.
These provisions may appear relatively minor individually, but together with the August 2026 revisions they demonstrate a broader move toward allowing companies to communicate authorized information more naturally without requiring every permissible wording variation to be expressly listed.
Despite the expanded flexibility, companies should not interpret the update as eliminating Health Canada’s existing labelling requirements.
Alternate terminology must still preserve the meaning of the product’s terms of market authorization. Companies must also continue to comply with the applicable Guidance document: Labelling of Natural Health Products and, where applicable, the Labelling Requirements for Non-prescription Drugs Guidance Document.
There are also restrictions surrounding standardized facts tables. Health Canada states that the titles, headings and subheadings of the Canadian Drug Facts Table for NPDs and Product Facts Table for NHPs cannot generally be changed using the List, beyond specified interchangeable terminology relating to terms such as “ask/consult” and references to health care practitioners or professionals.
The regulatory status of the product therefore remains critical when determining how much flexibility is available.
For most NHPs, Health Canada states that no notification or post-licence change is generally required when interchangeable terminology is used. This is because only the label text is required, including labels generated through the web-based Product Licence Application form.
There is an important exception.
Where mock-up labels and/or leaflets were reviewed and approved before licensing—such as for NPDs and certain NHPs, including nicotine replacement therapy products—Health Canada states that changes should be included in the next filing.
Companies should therefore confirm the regulatory history and authorization requirements for a product before assuming that a terminology change can be implemented without further action.
The revised List creates an opportunity for NHP companies to revisit existing labels, particularly where authorized terminology may be overly technical, inconsistent across a product portfolio, or difficult for consumers to understand.
Companies should consider conducting a structured review of existing and upcoming product labels.
Start by identifying terminology on the label that comes directly from the product licence, applicable monograph, or other terms of market authorization. That language can then be compared with the updated List to identify established interchangeable terms.
For NHPs and applicable List D NPDs, companies can also consider equivalent wording outside the table, but should document why the alternate terminology conveys the same meaning in its specific context.
Claims deserve particular attention. Because the revised framework now permits interchangeable terminology in NHP uses or indications, companies may have new opportunities to improve the readability of authorized claims without changing their underlying meaning.
However, this should not be treated as an opportunity to strengthen or expand a claim beyond what Health Canada has authorized.
Companies should also examine warning statements, directions for use, duration-of-use statements, Product Facts Tables and other mandatory label information to determine whether special restrictions apply.
Finally, organizations managing large portfolios may benefit from establishing an internal terminology standard. A documented process for approving interchangeable language can help maintain consistency across products while reducing the risk that marketing-driven wording changes unintentionally alter an authorized meaning.
Health Canada’s August 2026 update represents a practical improvement for an industry where relatively small differences in wording can create significant regulatory and operational considerations.
The List remains optional. Health Canada is not requiring companies to revise existing labels simply because additional terminology is now available. Instead, the revised framework gives companies more options when developing new labels or updating existing packaging.
For NHP companies in particular, the combination of claim flexibility and a non-exhaustive terminology list may make it easier to develop clear, consumer-friendly labels while remaining aligned with authorized product information.
The opportunity, however, needs to be balanced with appropriate regulatory oversight. Determining whether two terms genuinely communicate the same meaning can be highly contextual, particularly for claims, warnings, risk information and directions for use.
A label review before implementation can help ensure that greater flexibility does not inadvertently create a compliance issue.
The updated List of Interchangeable Terms gives Natural Health Product companies more flexibility, but determining when and how alternate wording can be used still requires careful consideration of the product licence, applicable monographs, claims, warnings and broader NHP labelling requirements.
dicentra’s Natural Health Product regulatory team can support companies throughout the Canadian market authorization and product lifecycle process, including:
For companies with products already on the Canadian market, the August 2026 update is also an opportunity to review existing labels and determine whether the expanded flexibility could improve consumer readability or simplify future packaging updates while maintaining regulatory compliance.
With more than two decades of regulatory experience, dicentra helps companies navigate Health Canada requirements from initial product classification and regulatory strategy through licensing, labelling and ongoing compliance.
Contact dicentra to discuss how the updated List of Interchangeable Terms may apply to your Natural Health Products or to have your existing labels reviewed for compliance.