Health Canada has announced a guideline to assist stakeholders with safety requirements under the Consumer Products Containing Lead Regulations. The guidance contains examples of products for each of the five categories of consumer goods.

SAFEGUARDS | Consumer ProductsNO. 021/22

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In May 2018, Canada published its Consumer Products Containing Lead Regulations (CPCLR, SOR/2018-83) to repeal the Consumer Products Containing Lead (Contact with Mouth) Regulations (CPCLCMR, SOR/2010-273). The CPCLR restricts lead content to no more than 90 mg/kg in each accessible part of five categories of consumer goods.

An accessible part, however, may contain more than 90 mg/kg lead content provided all of the following three conditions are met:

  • The use of lead is necessary for an essential characteristic
  • There are no alternatives available, and
  • ≤ 90 mg/kg migratable lead using EN 71-3 or when tested in accordance with good laboratory practices

The CPCLR became effective in November 2018 (SafeGuardS 67/18 and references therein).

In January 2022, Health Canada issued ‘Information for Regulated Parties Regarding the Consumer Products Containing Lead Regulations’ (the Guideline) to assist stakeholders with the safety requirements in the CPCLR, a piece of legislation that falls under the Canada Consumer Product Safety Act (CCPSA). The Guideline contains several important points:

  • Several examples of consumer goods that are within the scope of each of the five product categories
  • Clarifies that an accessible part in CPCLR means ‘any part of a product that may be touched, licked, mouthed, or swallowed during the reasonably foreseeable use of the product.’ Reasonably foreseeable use includes normal wear and tear
  • Emphasizes that lead content in consumer products is also restricted in several regulations under the CCPSA, including:

Highlights of the Guideline with product examples for each of the five categories are summarized in Table 1.

Health Canada
Information for Regulated Parties Regarding the Consumer Products Containing Lead Regulations, January 26, 2022

Entry

Scope

Product Example

1

Products that are brought into contact with the user’s mouth during normal use1

  • Drinking aids, including straws and parts of bottles, sippy cups, and other drinking vessels that are in contact with the user’s mouth during normal use

  • Mouth pieces of vaping devices, and mouthpieces of cannabis

  • Pacifiers and teethers

  • Sports mouthpieces and mouth guards

2

Clothing or clothing accessories for children under 14 years of age

  • Belts and suspenders

  • Boots and shoes

  • Buttons and other attachments

  • Daywear and sleepwear

  • Gloves and muffs

  • Hats and bonnets

  • Jackets

  • Lanyards, socks and stockings 

  • Neck ties

  • Shawls and scarves

3

Products for use in learning or play by children under 14 years of age

  • Building blocks

  • Children’s role-playing products (such as doctor/nurse kits, doll strollers and cooking equipment)

  • Products intended to learning purposes, such as pencils, erasers and rulers

  • Rattles, squeeze toys and toy figurines

4

Books or similar printed products for children under 14 years of age2

  • Books made of materials such as vinyl, textile, plastic or metal materials

5

Products that are designed and intended to facilitate the relaxation, sleep, hygiene, carrying or transportation of a child under 4 years of age

  • Bassinets, baby swings

  • Car seats, changing tables

  • Childcare articles such as bath accessories, bibs, pacifiers and teethers

  • Cradles, cribs

  • Highchairs and strollers

1Exemption: kitchen utensils, and products subject to Glazed Ceramics and Glass Regulations
2Exemption: printed on paper or cardboard, and printed and bound in a conventional manner using conventional materials (both conditions must be met)

Table 1

SGS is committed to providing information about development in regulations for consumer products as complimentary services. Through a global network of laboratories, SGS provides a wide range of services including physical/mechanical testing, analytical testing and consultancy work for technical and non-technical parameters applicable to a comprehensive range of consumer products. In the end, it’s only trusted because it’s tested. Contact us for more information or visit our website.

For inquiries, please contact:

Dr. Hingwo Tsang
Global Information and Innovation Manager
t: (+852) 2774 7420

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