This document provides information about the safety requirements that apply under the Canada Consumer Product Safety Act (CCPSA) and under the Children's Jewellery Regulations to children's jewellery that is manufactured, imported, advertised or sold in Canada.
Additionally, this document will explain how this legislation applies to the lead content of children's jewellery; define children's jewellery and help identify which products fall within the scope of the legislation; and specify the analytical test methods used for children's jewellery.
This document is an unofficial summary of the safety requirements for children's jewellery under the Children's Jewellery Regulations. It is not intended to substitute for, supersede or limit the requirements under the applicable legislation. In case of any discrepancy between this summary and the legislation, the legislation will prevail. For further information, contact a Health Canada Consumer Product Safety Office via email (email@example.com) or telephone at 1-866-662-0666 (toll-free within Canada and the United States).
To obtain information on the legislative requirements for children's jewellery not covered in this document, refer to the Canada Consumer Product Safety Act and its Regulations listed under Appendix B - Information Resources.
This document may be updated from time to time. For the most recent version, consult Health Canada's website.
Children's jewellery manufactured, imported, advertised or sold in Canada are subject to the CCPSA and Children's Jewellery Regulations.
In addition to the product-specific requirements noted in this document, it is prohibited to manufacture, import, advertise or sell any consumer product that is a "danger to human health or safety" as defined in the CCPSA (see paragraphs 7(a) and 8(a)).
The onus is on industry to comply with the legislation.
The Consumer Product Safety Program administers and enforces the CCPSA and the regulations made under it. Enforcement actions taken by Product Safety Officers on noncompliant products depend on the degree of hazard associated with noncompliance, and include commitment to product correction by industry, negotiation with industry for the voluntary removal of these products from the market, seizure and/or prosecution under the CCPSA. Any person that manufactures, imports, advertises, or sells noncompliant products that result in property damage, injury or death may also be subject to legal liability.
Under the Canada Consumer Product Safety Act (CCPSA), the Children's Jewellery Regulations and Surface Coating Materials Regulations regulate the importation, advertisement or sale in Canada of children's jewellery items which contain lead. The regulations set limits on lead content in order to protect children from toxicity associated with lead exposure.
The Children's Jewellery Regulations define children's jewellery as:
Jewellery that is manufactured, sized, decorated, packaged, advertised or sold in a manner that appeals primarily to children under 15 years of age but does not include merit badges, medals for achievement or other similar objects normally worn only occasionally.
See page 9 for examples of children's jewellery.
Children's jewellery, when tested using good laboratory practices, must not contain more than 600 mg/kg of total lead and no more than 90 mg/kg of migratable leadFootnote 1.
Both the total lead limit and the migratable lead limit must be met.
"Good laboratory practices" means practices that are in accordance with the principles set out in the Organisation for Economic Co-operation and Development's (OECD) document entitled OECD Principles of Good Laboratory Practice,Number 1 of the OECD Series on Principles of Good Laboratory Practice and Compliance Monitoring, ENV/MC/CHEM(98)17, the English version of which is dated January 21, 1998 and the French version of which is dated March 6, 1998. (For a link see "Information resources", on page 12 of this guide.)
The Children's Jewellery Regulations permit the importation, advertising or sale in Canada of children's jewellery that does not contain more than 600 mg/kg of total lead and more than 90 mg/kg of migratable lead in any component. The lead content limits apply to all accessible components of children's jewellery items, whether metallic or non-metallic, including glass and crystal components.
A component is considered accessible if it is exposed to direct contact with the hands or mouth or if there is potential for the component to become exposed under reasonably foreseeable handling by a child. Jewellery components such as beads, chains and clasps, which are sold separately, either individually or in kits, rather than as a finished jewellery item, must also meet the requirements of the Children's Jewellery Regulations.
An item is considered compliant only if all accessible components meet both lead limit requirements.
Many jewellery items are covered with a decorative or protective coating. The material under the coating is considered accessible for the purposes of the Children's Jewellery Regulations, since such coatings are easily removed if the item is sucked, chewed or swallowed, or through normal wear and tear.
The Children's Jewellery Regulations do not restrict the lead content of jewellery intended for adults or children aged 15 years or older. However, industry is encouraged to avoid the use of lead in all jewellery items.
Section 7.2 of the Surface Coating Materials Regulations limits the lead content of applied paints and other surface coatings on children's articles to 90 mg/kg of total lead. Children's jewellery items are considered children's articles. Therefore, any paints or other surface coatings materials on children's jewellery would be subject to the limit of 90 mg/kg of total lead under section 7.2.
Health Canada has proposed a guideline for cadmium content in children's jewellery which would limit total cadmium to 130 mg/kg.
In October 2010, Health Canada appealed to members of industry to voluntarily stop the manufacture, importation and sale of children's jewellery made with cadmium or cadmium-containing materials.
In July 2011, Health Canada posted a draft risk assessment report for stakeholder consultation proposing a guideline limit for total cadmium concentration in children's jewellery of 130 mg/kg. Based on our risk assessment, jewellery containing cadmium below this level is not considered to pose a risk of acute toxicity following ingestion or of chronic toxicity from daily mouthing of jewellery by small children.
Lead and cadmium are potentially toxic heavy metals often found in children's jewellery. Although there are no known risks to health from simply wearing jewellery containing lead or cadmium, there are serious, potentially fatal risks, from ingesting large amounts of lead or cadmium. Young children, under four years of age, are at a greater risk of injury due to their natural habit of putting non-food items into their mouths.
Lead is often used in making children's jewellery because it is inexpensive and easily molded. It has a sweet taste that may encourage children to chew or suck on lead-containing jewellery.
If ingested, lead can affect the nervous system and is especially harmful to children. Recent studies suggest even small amounts of lead in the body can cause learning and behavioural problems in children. At high levels of exposure, lead can cause seizures, coma and death. Since lead builds up in the body, ongoing exposure to even very small amounts of lead can result in large amounts of lead being present in the body.
It has been demonstrated, with tragic consequences, that swallowed jewellery may become lodged in the stomach, leading to the release of large amounts of lead in certain cases.
Several cases of lead poisoning in children have been linked to children's jewellery containing lead. In 2006, a child from the United States died of lead poisoning after swallowing a children's charm with a high lead content.
The health concerns surrounding lead in children's jewellery have raised similar concerns of cadmium exposure from children's jewellery. Ingested cadmium has been associated with renal, hepatic, cardiovascular, hemotological, neurological, reproductive/developmental and immunological effects.
Since the regulation of lead limits in children's jewellery, Health Canada has found high levels of cadmium in various items of children's jewellery in the Canadian marketplace, suggesting that cadmium may be increasingly substituted for lead in certain low-cost children's jewellery. Cadmium in children's jewellery has been detected at levels up to 93%.
If ingested, there may be serious health effects. Although no reported incidents of cadmium poisoning were found following ingestion of jewellery, it is considered this may pose a threat analogous to lead.
For purposes of the Children's Jewellery Regulations, an item of jewellery is considered to be any decorative item intended for regular wear on the body or on clothing or clothing accessories. This includes some items which might not ordinarily be described as jewellery, such as zipper pulls and shoelace charms.
Functional items like watches and hair clips, and functional components of clothing and accessories such as buttons and belt buckles, are not considered as jewellery, unless they are designed or marketed in a way which clearly indicates that their primary purpose is decorative. However, components of clothing fasteners and hair ornaments which are purely ornamental, such as charms and beads, are subject to the lead content limits of the Children's Jewellery Regulations.
Children's jewellery is defined in section 1 of the Children's Jewellery Regulations as "jewellery that is manufactured, sized, decorated, packaged, advertised or sold in a manner that appeals primarily to children under 15 years of age."
For the purposes of the Children's Jewellery Regulations, jewellery items shall be considered as appealing primarily to children under 15 years of age if, for example:
This list is not intended to be all-inclusive. Jewellery items will be classified on a case-by-case basis taking into account all relevant factors.
For assistance on classifying specific jewellery items, please contact the nearest Health Canada Consumer Product Safety Office (see list on page 14 of this document).
The following are examples of children's jewellery and the rationale for their classification.
Rationale for Classification
|(Note: only the ornamental components of the hairclips, for example, bunny face and ladybug, are subject to the Children's Jewellery Regulations.)|
(This item would not be classified as children's jewellery based on the design alone.)
|Bracelet with apple and heart charms
|'Canada' pendant necklace
|Headband with feathers and tiara
|Metallic charms on plastic wristbands
|Mood stone bracelet
|Pendant on cord
|Set of toe rings
|Teddy bear ring with mood stone
|Turtle pendant sold for use in jewellery-making classes
Industry is responsible for making sure their products comply with the Children's Jewellery Regulations. Health Canada does not specify or recommend any particular analytical methods to test jewellery for lead content. However, any methods used to test the lead content of jewellery for the purpose of assessing compliance with the Children's Jewellery Regulations must comply with Organisation for Economic Co-operation and Development's (OECD) Principles of Good Laboratory Practice, Number 1 of the OECD Series on Principles of Good Laboratory Practice and Compliance Monitoring, ENV/MC/CHEM(98)17 (see "Information resources" on page 12 of this document).
Any digestion methods, as well as any analytical instruments, that allow the determination of total and migratable content in jewellery items are acceptable provided that control-certified materials and standards are used to monitor the quality of the results.
In conducting enforcement of the Regulations, Health Canada uses the following test methods to determine total and migratable lead, and total cadmium, in jewellery:
C02.2 Determination of Total Lead in Surface Coating Materials in Consumer Products
C02.3 Determination of Total Lead in Polyvinyl Chloride Products by Closed Vessel Microwave Digestion
CO2.4 Determination of Total Lead and Cadmium in Metallic Consumer Products
CO8 Determination of Migratable Lead in consumer products
To obtain a copy of test methods, email Health Canada at firstname.lastname@example.org.
NOTICE: For further information visit the resources below or contact a Health Canada Consumer Product Safety Office via email (email@example.com) or telephone at 1-866-662-0666 (toll-free within Canada and the United States).
Canada Consumer Product Safety Act
Children's Jewellery Regulations
Draft Proposal for Cadmium Guidelines in Children's Jewellery
Surface Coating Materials Regulations
Organisation for Economic Co-operation and Development (OECD) Principles of Good Laboratory Practice
Canada Consumer Product Safety Act Quick Reference Guide
To subscribe for email updates about the Canada Consumer Product Safety Act
Guidance on Mandatory Incident Reporting under the Canada Consumer Product Safety Act - Section 14 Duties in the Event of an Incident
Migratable lead is the amount of lead which is released from a product when it is brought into contact with a liquid solvent.
For the purposes of enforcing the Children's Jewellery Regulations, 'premises' are considered to include vehicles, kiosks, street stands and any other place where or from which jewellery items are displayed, advertised, distributed or sold.