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Canada Proposed Amendment to Surface Coating Material Requirements

Health Canada has proposed to amend the regulatory requirements for surface coating materials under the Canada Consumer Product Safety Act (CCPSA).

Summary on the proposal
The proposed amendments to provisions regarding surface coating materials include:

  • Expanding the meaning of “surface coating material” to include surface coating that do not dry on applications, such as electrostatically applied powder coatings, and decorative surface coating like stickers or films.
  • Extending the application of 90 mg/kg total lead limit to surface coatings on furniture.
  • Removing the heavy metal restrictions for surface coatings applied to inaccessible parts of products.
  • Removing an outdated test method.

Changes to regulations
The amendments will be incorporated in the respective regulations as follows:
SOR/2016-193 Surface Coating Materials Regulations

  1. The regulation will define the two terms “surface coating material” and “accessible part”:
    • Surface coating material” means 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.
    • Accessible part” means any part of a product that may be touched, licked, mouthed or swallowed during the reasonably foreseeable use of the product
  2. The 90 mg/kg total lead limit in accessible surface coating materials will apply to the following products:
    • Furniture (scope expanded from children’s furniture to all furniture)
    • Products for children
    • Pencils
    • Artist brushes

SOR/2011-17 Toys Regulations
SOR/2016-152 Cribs, Cradles and Bassinets Regulations
SOR/2016-179 Expansion Gates and Expandable Enclosures Regulations
SOR/2018-186 Playpens Regulations

  1. For products which are within the scope of the above regulations, any surface coating material that is applied to an accessible part shall not exceed the following limits:
    • Total lead ≤ 90 mg/kg
    • Migration of any compound of antimony, arsenic, cadmium, selenium or barium ≤ 1000 mg/kg
    • Total mercury ≤ 10 mg/kg
  2. The test method (using 5 % hydrochloric acid for 10 minutes at 20 ℃) stated in the respective regulations will be removed. Any test method can be used to verify the compliance, if it conforms to good laboratory practices.


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