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Notice Regarding Canada's Legislated Safety Requirements Related to Heavy Metal Content in Surface Coating Materials Applied to Children's Toys
October 2009
To: Manufacturers, Importers, Distributors and Retailers of Children's Toys, as well as Product Testing Laboratories
The purpose of this notice is to provide you with information concerning the legally allowable limits of particular heavy metals that may be found in the surface coatings applied to children's toys and to provide information on the Canadian test methods that are used to verify compliance with Canadian law.
In Canada, the legislated safety requirements for children's toys are specified within the Hazardous Products Act (HPA) and the Hazardous Products (Toys) Regulations. It is the responsibility of manufacturers, importers, distributors and retailers to ensure that any toy advertised, imported or sold in Canada, including second-hand toys, meets all applicable safety requirements as set out in the HPA and the associated regulations.
Item 9 of Part I of Schedule I to the HPA prohibits 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 material applied to them that contains any of the following heavy metals:
- total lead in excess of 600 mg/kg;
- migratable heavy metals (antimony, arsenic, cadmium, selenium or barium) in excess of 0.1% (1000 mg/kg); or
- any compound of mercury introduced as such.
Surface coating materials on toys can include, but are not limited to, paints, varnishes and stickers/decals applied during product manufacturing.
During 2008, there were several recalls of children's toys due to excessive lead and/or barium content in their applied surface coatings. Health Canada is reminding companies of Canada's legislated safety requirements related to the heavy metal content in such coatings.
Health Canada advises that children's toys be tested for compliance with all Canadian legislated requirements before they are offered for sale on the Canadian market; in many cases, but in particular for heavy metals, these requirements and associated test methods, are different in Canada than they are in the United States and in Europe. Furthermore, manufacturers are encouraged to establish effective control systems for on-going monitoring of safety compliance throughout the design and manufacturing phases. Establishing effective controls for regular compliance monitoring of the supply chain is also critical for manufacturers, importers, distributors and retailers.
Health Canada's Product Safety Laboratory has developed test methods to assess heavy metal content in applied coatings on toys and the below noted test methods are available from the Product Safety Laboratory by contacting:
- Quality System Manager
Product Safety Laboratory
Health Canada
Postal Locator: 6402A1
1800 Walkley Road
Ottawa, Ontario
CANADA
K1A 0K9 - phone: 613-952-3645
fax: 613-954-8515
email: PSL-LSP@hc-sc.gc.ca
- C02.2 - Determination of total lead in surface coating materials in consumer products
- C03 - Determination of Leachable Arsenic (As), Selenium (Se), Cadmium (Cd), Antimony (Sb), and Barium (Ba) in Applied Coatings
- C07 - Determination of Total Mercury in Surface Coating Materials and Applied Coatings
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