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Canada Approved Amendments to Surface Coating Material Requirements !
Publisher:Admin  Source:  Date:2022/6/30

On June 22, 2022, Health Canada has published SOR/2022-122 in the Canada Gazette approving to amend the regulatory requirements for surface coating materials under the Canada Consumer Product Safety Act (CCPSA). These Regulations will come into force on the 180th day after the day on which they are published in the Canada Gazette.


Summary on the Amendments

The amendments to provisions regarding surface coating materials include:

a. 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.

b. Extending the application of 90 mg/kg total lead limit to surface coatings on furniture.

c.  Removing the heavy metal restrictions for surface coatings applied to inaccessible parts of products.

d. Removing an outdated test method.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”:

a.  “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.

b.  “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 applies to 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: 

a. Furniture (scope expanded from children’s furniture to all furniture)

b. Products for children

c. Pencils

d. Artist brushes


Relevant regulatory consistency

• 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, a sticker, film or other similar material that can be removed, or a surface coating material that is applied to an accessible part shall not exceed the following limits:

a. Total lead ≤ 90 mg/kg

b. Migration of any compound of antimony, arsenic, cadmium, selenium or barium ≤ 1000 mg/kg

c. 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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Bay Area Compliance Labs Corp.( BACL for short), with its headquarter in Silicon Valley, it is a professional and international third-party testing and certification body. Currently we have physical and chemical testing labs in the United States, Shenzhen, Dongguan, Xiamen and other places, and we have accredited the certifications by UKAS (Lab No.: 7827), CNAS (Registration No.: L2408, L6290, L9963, IB0343), CPSC(Lab ID:1112, 1415, 1647), CMA (No.: 2016192126Z, 2015192413Z) and other authorities. We offer a full range of testing service which cover footwear, toys, textile, clothing, leather, jewelry, groceries, food contact materials, cosmetics and electrical and electronic products, etc. We can help enterprises to complete the precise control of whole industry chain from raw materials to the finished products.



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