About to sell toys or other children’s products in Canada? In this guide, we explain what importers and manufacturers must know about Canadian toy safety standards, chemical restrictions, labeling, lab testing, and documentation.
- Plush toys
- Electronic toys
- Children’s jewelry
- Children’s clothing
- Children’s furniture
- Feeding bottles
Canada Consumer Product Safety Act (CCPSA)
The Canada Consumer Product Safety Act (CCPSA) requires that consumer products manufactured or imported to Canada, including children’s products and toys, must be safe and do not harm human health.
As we will see in the next section of this article, the CCPSA not only specifies general safety requirements; it also enforces specific regulations for a large array of children products, including testing standards, labeling requirements, and more.
The CCPSA establishes safety requirements concerning the electrical, mechanical, flammability, chemical, and auditory hazards of toys that are intended to be used by children under the age of 14. These regulations apply to fabric plush toys, plastic toys, electrical toys, wooden toys, and many other types of toys.
Under SOR / 2011-17, electrical toys must comply with the Canadian Standards Association Standard C22.2 No. 149-1972 – Electrically Operated Toys (with the exception of battery-operated toys).
Electrically heated toys must comply with C22.2 No. 122-M1989 – Hand-Held Electrically Heated Tools.
Other Potential Hazards
The Regulations also list other potential hazards of the toy products and the corresponding requirements in the aspects of design, construction, installation, flammability, metal migration, and stability.
For example, a wireframe or structure that is embedded in a toy must be properly designed, constructed, or finished so that the metal end will not cause harm to children.
Or, as another example, a toy that is intended to bear the weight of a child must stay stable and balanced when being used.
The regulations also specify packaging requirements, including film bag specification and warning label content and language standard for toy products.
Packaging bag for toys must conform to either one of the following requirements:
1. Opening in the bag circumference should at least be less than 356 mm (14 inches)
2. The thickness of the film bag should be least 0.019 mm (0.75 mils)
Meanwhile, packaging bags must contain warning statements, in both English and French, in bold style, to alarm parents and adults about the potential danger of the packaging bag to infants and children.
Visit the official website of the Government of Canada to learn more about the requirements of the toy regulations
The regulation sets the permissible limit for lead and cadmium contained in children’s jewelry when tested according to EN Standard 71-3 or other alternative test methods:
- Lead: maximum 90 mg/kg
- Cadmium: maximum 130 mg/kg
SOR / 2016-169 establishes specifications, testing methods, and labeling requirements for loose-fitting and tight-fitting children’s sleepwear.
Loose-fitting sleepwear includes children’s nightshirts, gowns, housecoats, robes, and pajamas in sizes up to and including 14X.
Tight-fitting sleepwear includes products that are intended for infants weighing under 7 kg and polo pajamas.
The regulation lists several testing standards, including:
- CAN/CGSB-4.2 No. 27.5, Textile Test Methods: Flame Resistance
- OECD Test No. 401 – Acute Oral Toxicity
- OECD Test No. 402 – Acute Dermal Toxicity
- OECD Test No. 404 – Acute Dermal Irritation/Corrosion
- OECD Test No. 406 – Skin Sensitisation
- OECD Test No. 471 – Genetic Toxicology
The regulation also specifies labeling requirements for loose-fitting sleepwear treated with a flame retardant process. Such a product should contain the following information in the label:
a. Include a description like “flame retardant” in English and “ignifugeant” in French
b. Caring instructions in English and French
Carriages and Strollers
SOR/2016-167 includes a list of restricted substances, and testing methods for stability, braking device, child restraint system, latching system, structural integrity. It also specifies labeling requirements.
In particular, the regulations require that carriages and strollers must not contain several substances, including: :
- Carbon tetrachloride
- Methyl alcohol
- Petroleum distillates
- Boric acid or salts of boric acid
- Ethyl ether
- Heavy metals (i.e. lead, cadmium)
Labeling requirements set out rules concerning general information (i.e. manufacturer and supplier’s business information, model number, date of production), warning statements (safety and potential hazards when using the equipment), installation, usage instructions, maintenance guide (including literal descriptions and illustrations).
SOR/2016-152 set up rules for children’s cribs, cradle, and bassinets concerning issues like surface coating materials, heavy metal concentration limit contained in the components, assembly methods, testing standards, advertising, and labeling information.
Restricted chemical substances used in these products include:
SOR/2016-152 also includes testing standards, including testing for the following:
- Test for Strength and Integrity of Slats
- Test for Openings
- Test for Strength of Mesh and Integrity of Attachment
- Test for Determination of Size of Openings in Mesh
- Test for Entanglement
- Test for Loops
- Test for Structural Integrity
- Test of Mattress Support
SOR/2016-152 requires that the following information must be shown in the main product, component and stand of every crib, cradle, and bassinet, whether in the form of text, illustration, or a combination of these two:
- Product model name or model number
- Components list
- Product dimension
- Date of the manufacturer
- Assembling instructions
- Usage guide
Warning statements or phrases conveying equivalent meaning are also required to be displayed in every crib, cradle and bassinet product, in both English and French.
a. Do not use this crib if you cannot entirely follow every requirement listed in the instruction guide.
b. Do not use this crib for a child who is able to climb out of it or taller than 90 cm.
c. Do not put any cord, strap, or similar article near the crib if case it suffocates the child.
Restraint Systems and Booster Seats for Motor Vehicles
SOR / 2016-191 establishes requirements concerning product dimensions, structural elements, movement, labeling, testing methods of booster seats, and restraint systems intended to be used by children.
SOR/2018-186 establishes requirements concerning structural elements, surface coating toxicity, pen stitching, strength and integrity, flammability, and material finishing requirements of the playpen products.
Particularly, components and parts of playpen products must comply with section 25 of the Toys Regulations for toxic chemical substances restriction.
If the playpen product is made of or contains a certain part of textiles, then it should comply with the Standard CAN/CGSB-4.2 No. 27.5 – Flame Resistance.
Feeding Bottles and Pacifiers
SOR / 2016-180 sets a limit of volatile N-nitrosamines contained in infant feeding bottle nipples or similar products, such as teethers, pacifiers, and straws.
The limit for volatile N-nitrosamines in these products must not exceed 10 µg/kg.
SOR / 2016-184 specifies the material composition, toxicity requirements, protective devices design, labeling requirements, and testing methods for pacifiers.
In particular, pacifiers shall not present hazards including strangulation, ingestion, obstruction of the throat under normal circumstances.
Chemicals & Heavy Metals
Surface Coating Materials
SOR / 2016-193 requires that the lead content contained in the surface coating applied in children’s toys must not be more than 90 mg/kg total lead.
SOR/2016-188 requires that children’s products must not contain more than 1 000 mg/kg of di(2-Ethylhexyl) phthalate (DEHP), dibutyl phthalate (DBP) or benzyl butyl phthalate (BBP), diisononyl phthalate (DINP), dodecyl phthalate (DIDP) or di-n-octyl phthalate (DNOP), and other substances.
Consumer Products Containing Lead Regulations
SOR/2018-83 requires that children’s products must not contain more than 90 mg/kg of lead.
The CCPSA requires importers and manufacturers to prepare and maintain a copy of documentation which includes business information (i.e. manufacturers, importers, sellers, and distributors information), product information, batch coding, product test reports, product distribution location and other information required by the government.
This documentation might be required by the Minister of Health when necessary.
You can learn more about CCPSA documentation requirements on the official CCPSA page.
Toys Regulations under the CCPSA established labeling requirements for toys. As already mentioned in this article, some regulations like SOR/2016-152, SOR/2016-167, SOR / 2016-169 provide their own labeling specifications. Thus, manufacturers and importers can refer to individual regulations when assessing their product labeling content.
Meanwhile, CCPSA strongly recommends adding age appropriateness and choking hazards labels printed upon the product and packaging, in both English and French, to inform the consumer that potential hazards could be caused by the toys.
Importers must ensure that their toys and children’s products are safe to use and comply with all the requirements of the Toys Regulations as well as other applicable CCPSA regulations, even when no mandatory testing is required.
As such, importers should contact a reputable lab testing such as UL, SGS, CSA, and Intertek, to carry on the necessary tests.
Note that, for electric toys, some provincial and territorial legislation may require a compliance certification mark from a certification body accredited by the Standards Council of Canada to prove their compliance.
Prohibited Children’s Products
The CCPSA prohibits some types of baby walkers, pacifiers, and other children’s products.
Additionally, it prohibits products that contain excessive amounts of lead and toys emit a sound over 100 decibels.
You can find a full list of prohibited items in Appendix B of the regulation.
Mandatory Incident Reporting
Health Canada has published a guidance document on the mandatory incident reporting requirements under the Canada Consumer Product Safety Act (CCPSA).
In short, manufacturers, importers, and distributors of consumer products must file incident reports with Health Canada so that they can monitor the response to the danger.
Children’s Apparel: Textile Labelling Act
Textile products manufactured or imported in Canada are subject to the Textile Labelling Act. The act also covers textile products intended to be used by children, including children’s clothing, pajamas, and toys that are made of textiles.
Labeling information on textile products should also conform to the requirements set by the act, such as correct product information and fiber content, maintenance instructions, and more.
If you want to learn more about the specific regulations for textiles products, you can read this article.
Toys and other children’s products manufactured outside Canada may contain excessive amounts of regulated substances, or fail to comply with mandatory safety standards. Here are a few examples:
- Feeding bottles containing excessive amounts of banned chemicals
- Toys non-compliant with mechanical/general safety standards
- Incorrectly labeled children’s products
This can be partially explained by the fact that Canadian children’s product standards are not well known among manufacturers in China and other major toy exporting countries. When communicating with factories overseas, it’s therefore critical to inform them of the specific standards to which the product must be compliant. That said, you may need to refer to corresponding ASTM, EN or ISO standards rather than Canadian standards – as the former are more well known internationally.
That being said, some toy manufacturers don’t have the capability to manufacture children’s products in compliance with Canadian standards. As such, it’s important to review the suppliers existing compliance track record – including pre-existing lab test reports.