SG 084.22
Canada has amended its Surface Coating Materials Regulations and four other pieces of legislation that set requirements for applied coating materials. These will become effective on December 19, 2022.
On June 22, 2022, Canada issued Regulations Amending Certain Regulations Made Under the Canada Consumer Product Safety Act (Surface Coating Materials) (SOR/2022-122, the Regulation) to amend the requirements for surface coating materials across five regulations under the CCPSA for consistency. These five regulations are:
- Cribs, Cradles and Bassinets Regulations (SOR/2016-152)
- Expansion Gates and Expandable Enclosures Regulations (SOR/2016-179)
- Playpens Regulations (SOR/2018-186)
- Surface Coating Materials Regulations (SOR/2016-193)
- Toys Regulations (SOR/2011-17)
The Regulation contains several important provisions. It:
- Broadens the definition of a surface coating material to include surface coating materials that do not ‘dry’ on application, such as powder coatings that are applied electrostatically
- Expands the application for other decorative coating materials that may be applied to products during manufacture to include materials such as stickers or films
- Widens the scope of no more than 90 mg/kg total lead for applied coating materials from furniture for children to all furniture
- Restricts lead, mercury and certain harmful elements in coating materials applied to accessible parts of products
- Replaces the outdated hydrochloric acid test method for the migration of antimony, arsenic, barium, cadmium or selenium with a method that industry commonly uses for the United States, the European Union or other jurisdictions:
- ASTM F963 ‘Standard Consumer Safety Specification for Toy Safety’
- EN 71-3 ‘Migration of Certain Elements’
- ISO 8124-3 ‘Migration of Certain Elements’
- Requires testing to be carried out in accordance with a method that conforms to good laboratory practices
Highlights of several changes to the Surface Coating Materials Regulations and the new requirements for stickers, films and surface coating materials in the Regulation are summarized in Tables 1 and 2.
| Section 1 Definition - Surface coating material | A paint or other similar material, with or without pigment, that forms a solid film after it is applied to a surface and that can be removed. (revêtement) | A paint or other similar material, with or without pigment, that dries to a solid film after it is applied to a surface, but does not include material that becomes a part of the substrate. (revêtement) |
| Section 1 Definition – Accessible part | Any part of a product that may be touched, licked, mouthed or swallowed during reasonably foreseeable use of the product. (partie accessible) | No definition |
| Section 6 Heading for lead content | Products with Applied Stickers, Films or Surface Coating Materials Lead content A sticker, film or other similar material that can be removed, or a surface coating material, that is applied to an accessible part of the following products must not contain more than 90 mg/kg total lead when it is tested in accordance with a method that conforms to good laboratory practices: a) Furniture b) Products for children c) Pencils and d) Artist brushes | Products with An Applied Surface Coating Material Lead content The following products must not have an applied surface coating material that contains more than 90 mg/kg total lead: a) Products for children, including furniture, and b) Pencils and artists’ brushes |
| Effective Date | December 19, 2022 | In force |
Table 1
(Surface Coating Materials) (SOR/2022-122) | ||||
|---|---|---|---|---|
| Stickers, films and surface coating materials | ≤ 90 mg/kg total lead | December 19, 2022 | |
| ≤ 10 mg/kg total mercury | ||||
| ≤ 1,000 mg/kg any compound of antimony, arsenic, barium, cadmium or selenium using, for example, ASTM F963, EN 71-3 or ISO 8124-3 | ||||
Table 2
The Regulation will become effective on December 19, 2022 – 180 days after its publication in the Canada Gazette, Part II.
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