13 May 2003 Excise Interpretation 45459 - Labelling Requirements Under the Excise Act, 2001

Dear XXXXX,

Thank you for your letter XXXXX expressing your concerns regarding the new labelling requirements under the Excise Act, 2001.

As you are aware the scheduled implementation of the Excise Act, 2001 is July 1, 2003, and the Regulations Respecting the Information to be Displayed on Alcohol Containers and their Packaging will require the name and address or the licence number of the alcohol licensee who packaged the alcohol to be displayed on the container. You indicated in your letter that this labelling requirement could result in a substantial expense for XXXXX[.] During the course of discussions with industry this issue was raised and consideration sought for a transitional period during which existing supplies of labels could be depleted. To address this issue, we will be implementing an administrative policy that will allow licensees to continue applying existing labels until July 1, 2004, an extension from the December 31, 2003 date originally considered and as stated in your letter. This extension follows the concerns expressed in your letter, and while we recognize that a one-year period is less than you requested our findings show that this transitional policy should allow alcohol licensees adequate time to comply with the new labelling requirements within a reasonable timeframe.

Additionally, you indicated in your letter that any new labels introduced after July 1, 2003 will be fully compliant with the regulations as well as those that require changes after this date. This practice would agree with the CCRA transitional policy regarding labels. However, as the new licence numbers will be available from CCRA at any time after April 1, 2003, we will also accept the use of labels compliant with the Excise Act, 2001 prior to July 1, 2003. Therefore any labels currently requiring printing can be updated immediately, which should effectively provide an additional three months to the transition period.

Should you require any further information, please contact me at the above address or by telephone at (613) 954-5894.

Sincerely,

Mark Hartigan
Manager
Excise Act Implementation
Excise Duties and Taxes Div.

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