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Content provided by : SGS Hong Kong Limited
29 Oct 2009
Canada Publishes Legislated Heavy Metal Requirements for Toys Containing Surface Coating Materials

Health Canada recently published a notice concerning the legal limits of certain heavy metals in surface coatings on children's toys and the test methods that are to be used to verify compliance with the Canadian law. The notice also reveals that stickers and decals applied during product manufacturing are considered as surface coating materials.


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For children's toys entering the Canadian market, the legislated safety requirements are specified within the Hazardous Products Act (HPA) and the Hazardous Products (Toys) Regulations. Manufacturers, importers, distributors and retailers are responsible to ensure that any toy advertised, imported or sold in Canada, including second-hand toys, meet all applicable safety requirementsas set out in the HPA.

In October 2009, Health Canada published a notice on the legal limits for certain heavy metals and their associated test methods1. This notice advised that children's toys be tested for compliance with all Canadian legislated requirements before they are offered for sale on the Canadian market. It also advised that in many cases, the requirements and associated methods, in particular for heavy metals, are different to those under the US and European regulations. Under item 9 of Part 1 of Schedule I to the HPA, the advertising, importation and sale of toys, equipment and other products for use by a child in learning or play that have had a surface coating applied to them that contains total lead, certain migratable heavy metals and any compound of mercury are prohibited. Highlights of the scope and requirements for surface coating materials on toys for the Canadian and the US markets are summarised in Table 1.

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1. Notice Regarding Canada's Legislated Safety Requirements Related to Heavy Metal Content in Surface Coating Materials Applied to Children's Toys, Consumer Product Safety, Health Canada, October 2009

2. Consumer Product Safety Improvement Act of 2008, Public Law 110-314, August 2008; Part 1303 - Ban of Lead-Containing Paint and Certain Consumer Products Bearing Lead-Containing Paint, Title 16: Commercial Practices, Electronic Code of Federal Regulations (e-CFR), e-CFR data is current as of October, 2009