Health Canada issued SOR/2022-122 approval to amend the regulatory requirements for surface coating materials in the Canadian Consumer Product Safety Act (CCPSA). The previously proposed requirements have been adopted in full and all requirements will come into effect on December 19, 2022.

Summary of revisions

Revisions on surface coating materials include:

Expands the definition of "surface coating material" to include surface coatings that do not dry out in application, such as electrostatically sprayed powder coatings, and decorative surface coatings such as stickers or films.

Extend the application of the total lead limit of 90mg/kg to the surface coating of furniture.

Removed the heavy metal restriction that the product should not touch the surface coating of parts.

Removed obsolete test methods.

Regulation specific updates

The amendments will be incorporated into the corresponding regulations as follows:

SOR/2016-193 Surface Coating Materials Regulations

1. The regulations define the terms "surface coating material" and "accessible parts":

"Surface coating material" means a paint or other similar material, with or without pigments, that, when applied to a surface, forms a solid film and can be removed.

"Accessible Parts" means any part of the Product that may be touched, licked, chewed or swallowed during reasonably foreseeable use of the Product.

2. The total lead limit of 90 mg/kg will apply to removable stickers, films or other similar materials, or surface coating materials on accessible parts of the following products:

Furniture (ranging from children's furniture to all furniture)

Children's Products

pencil

artist brush

SOR/2011-17 Toy Regulations

SOR/2016-152 Cribs and Cradles Regulations

SOR/2016-179 Expanding Doors and Guardrails Regulations

SOR/2018-186 Playpen Regulations

1. For products within the scope of the above regulations, removable stickers, films or other similar materials on accessible parts, or surface coating materials shall not exceed the following limits:

Total lead ≤ 90 mg/kg;

Migration of compounds of antimony, arsenic, cadmium, selenium or barium ≤ 1000 mg/kg;

Total mercury ≤ 10 mg/kg.

2. The test method specified in the corresponding regulations (using 5% hydrochloric acid for 10 minutes at 20°C) will be deleted. Any test method can be used to verify compliance if it is in accordance with Good Laboratory Practice.