Toys and Hardlines | Monthly bulletin | October 2026

Published Date :
Wednesday, Oct 21, 2026
Tags :
Regulatory Updates
Softlines & Hardlines

Europe

Updated harmonised toy safety standards for chemistry sets, formamide and flame retardants

The European Commission has adopted Commission Implementing Decision (EU) 2026/2032, amending the list of harmonised standards supporting the Toy Safety Directive 2009/48/EC. The Decision was adopted on the 11 September 2026 and published in the Official Journal of the European Union on the 14 September 2026.

The Decision introduces new and revised standards developed by the European Committee for Standardisation (CEN) that address chemical risks associated with toy materials and experimental chemistry sets.

The harmonised standards added are:

  • EN 71-4:2020+A1:2025 – Safety of toys – Part 4: Experimental sets for chemistry and related activities.
  • EN 71-15:2025 – Safety of toys – Part 15: Formamide in foam toy materials (content).
  • EN 71-16:2025 – Safety of toys – Part 16: Certain chlorinated phosphorus flame retardants (TCEP, TCPP, TDCP) in toy materials.

The publication of EN 71-15 and EN 71-16 introduces, for the first time, harmonised European standards specifically addressing:

  • Formamide content in foam toy materials.
  • Certain chlorinated phosphorus flame retardants, namely TCEP, TCPP, and TDCP, in toy materials.

The revised standard EN 71-4:2020+A1:2025 replaces the previous EN 71-4:2020 standard. To provide sufficient time for manufacturers to adapt, the Commission has postponed the withdrawal of the reference to EN 71-4:2020. The withdrawal will apply from the 14 March 2028.

For toy manufacturers, importers, retailers, and testing laboratories, these standards provide updated technical specifications for demonstrating compliance with EU toy safety requirements.

This Decision entered into force on the 15 September 2026.

Childcare articles and consumer products standard updates

The table below summarises the most recent standard updates and upcoming dates of withdrawal (non-exhaustive):

(*) Date of withdrawal: latest date by which national standards conflicting with a European Norm (EN) (and Harmonisation Document (HD) for the European Committee for Electrotechnical Standardisation (CENELEC)) must be withdrawn.

The European Committee for Standardisation (CEN)/CENELEC
Reference Title Date of withdrawal
(*)
Supersedes
EN 16781:2026 Textile child care articles - Safety requirements and test methods for children's sleep bags for use in a cot 31 March 2028 EN 16781:2018
EN 18122:2026 High chairs and learning towers - Learning towers - Requirements and test methods 9 September 2027  
EN 18239:2026 Digital product passport - Access rights management, information system security, and business confidentiality 31 March 2027  
EN 18246:2026 Digital product passport - Data authentication, reliability and integrity 31 March 2027  
EN 15493:2026 Candles - Specification for fire safety 31 March 2027 EN 15493:2019

EU Commission updates guidance on single-use plastic products

On the 8 September 2026, the European Commission published an updated Notice revising its guidance on the interpretation and implementation of the Single-Use Plastics (SUP) Directive (EU) 2019/904, which aims to reduce the environmental impact of certain plastic products. 

The update is limited to one specific section of the existing guidance and focuses on caps, lids and covers used on single-use plastic beverage containers and cups. In particular, the Commission has added a new illustrative example involving a plastic cap used together with an aluminium foil lid, such as those commonly found on high-density polyethylene (HDPE) bottles containing ultra-high-temperature (UHT) processed milk. The guidance clarifies that the plastic cap remains subject to the SUP Directive's tethered cap requirements, whereas the aluminium foil lid is not considered a plastic closure and is therefore excluded from those requirements.

The update provides additional clarity for manufacturers, importers, retailers, and compliance professionals assessing product classification and design requirements under the SUP Directive, particularly in relation to beverage packaging closures and tethered cap obligations.

EU amends EUDR product scope

On the 17 September 2026, the European Commission adopted Commission Delegated Regulation (EU) 2026/2102, amending Annex I of the EU Deforestation Regulation (EUDR) (Regulation (EU) 2023/1115). The changes introduce targeted updates to the list of relevant commodities and products.

Key changes in the scope are:

  • Instant/soluble coffee (HS 2101 11 00) has been added. The new requirement will apply from the 30 December 2027.
  • Raw hides and skins of cattle (HS 4101), tanned hides and skins (HS 4104), and prepared leather of cattle (HS 4107) have been removed from Annex I.
  • Frozen cattle tongues (HS ex 0206 21 00) are now included. Application starts on the 30 December 2027.
  • Numerous additional palm-oil-derived oleochemicals and chemical intermediates. These new entries will become applicable from the 30 December 2027.
  • Conveyor belts (HS 4010) and other vulcanised rubber articles (HS 4016) have been removed.
  • Retreaded tyres are narrowed to cover only tyre treads (HS ex 4012 90 30).
  • Soybeans for sowing are effectively excluded through replacement of the broader HS 1201 entry with HS 1201 90 00 00 ("other" soybeans).

The Commission also introduced several important clarifications:

  • EUDR applies only to specific species of cattle, oil palm, and natural rubber. Products made from other species are excluded.
  • Wood products made from bamboo, rattan and other non-covered woody materials are excluded.
  • Samples used for testing, examination and analysis are outside the scope under certain conditions.
  • Packaging and containers used solely to support, protect or carry another product are generally excluded from EUDR obligations.
  • Marketing materials, labels accompanying products, and items of correspondence are clarified as being outside the scope.
  • Numerous clarifications exclude waste, used products and second-hand products from relevant product categories.

The amendment provides greater clarity on product coverage while simultaneously extending EUDR obligations to new downstream products. Meanwhile, leather manufacturers will welcome the removal of cattle hides and leather from Annex I.

EU moves to negotiate a successor to the international tropical timber agreement

The European Commission adopted a recommendation for a Council Decision authorising the European Union to participate in negotiations for a new international agreement that would replace the International Tropical Timber Agreement (ITTA) 2006, which is due to expire on the 6 December 2029.

According to the Commission, discussions on a successor agreement have been ongoing since 2024 and are expected to intensify during meetings scheduled in November 2026 in Yokohama, Japan. The EU intends to actively participate in these negotiations to ensure that any new framework remains aligned with European policy objectives on sustainable forest management, environmental protection, and responsible trade.

The agreement also supports market transparency, data collection, sustainable supply chains, and capacity building in tropical forestry.

A successor agreement could play an important role in supporting legal sourcing, forest conservation, and supply chain transparency worldwide.

EU Launches consultation on harmonised packaging labels under the PPWR

The European Commission is preparing a draft act for a public consultation on new implementing rules that will establish harmonised labels for packaging, containers for waste collection, and waste receptacles under the Packaging and Packaging Waste Regulation (PPWR). The initiative aims to create a common labelling system across the EU to improve waste sorting and facilitate recycling.

Key elements expected to be addressed in the implementing rules include:

  • Harmonised labels for packaging placed on the EU market.
  • Matching labels for separate waste collection containers and receptacles.
  • Visual elements and specifications to ensure labels are easily recognisable throughout the EU.
  • Measures to improve consumer understanding of recycling and sorting requirements.

For manufacturers, importers, retailers and packaging producers, the forthcoming rules will be particularly relevant as they will determine how packaging must be labelled to comply with the PPWR requirements once the Regulation becomes fully operational. Companies may need to review packaging artwork, labelling strategies and product information to ensure future compliance.

France

France introduces eco-modulation penalties targeting ultra-fast fashion in the Textile EPR Scheme

On the 28 August 2026, France adopted a new measure to strengthen the environmental performance requirements of the textile sector by amending the rules governing the Extended Producer Responsibility (EPR) scheme for textiles, footwear and household linen (TLC). 

The amendment modifies the specifications applicable to approved producer responsibility organisations (PROs) and individual compliance schemes. Its main objective is to adjust producers’ financial contributions according to environmental performance criteria linked to industrial and commercial practices associated with ultra-fast fashion.
From the 1 September 2026, producers will be subject to additional financial penalties where products achieve a low durability score ("D score").

Penalty amounts will increase progressively between 2026 and 2030 depending on the product category. 

These new eco-modulation rules may result in increased EPR costs for products failing to meet the specified durability criteria.

For more information, consult the official publication in Legifrance website here.

France establishes reimbursement framework for reusable menstrual products

France has adopted an Order of 6 August 2026 establishing the conditions under which reusable menstrual products can be reimbursed under the French social security system. The measure adds menstrual cups and menstrual underwear to the list of products eligible for reimbursement under Article L. 162-59 of the Social Security Code. The new provisions will take effect from the 1 October 2026.

To qualify for reimbursement, products must meet detailed technical, safety, durability and manufacturing requirements set out in the Order. The Order establishes extensive requirements covering materials, absorbency, durability, product safety and size availability.

The Order also requires manufacturers to demonstrate compliance with social and environmental standards through recognised certifications such as GOTS, EU Ecolabel, Fair Wear Foundation, Fairtrade, B-Corp, ISO 14001, or equivalent schemes. Companies must also provide traceability information covering each stage of the production process.

For manufacturers and suppliers, compliance with the technical and certification requirements will be essential to access the French reimbursement system and pharmacy distribution channel.

Reusable menstrual products Requirements
Menstrual underwear •    Testing must be carried out by an independent European laboratory accredited to ISO/IEC 17025.
•    Products must include at least three functional layers: a draining layer, an absorbent layer and a leakproof layer.
•    The skin-contact layer must be made from organic cotton or lyocell.
•    The entire product must be certified according to OEKO-TEX® Standard 100 Class I or II.
•    Manufacturers must demonstrate product tolerance through real-use testing under dermatological and gynaecological supervision.
Menstrual cups •    Platinum-cured medical-grade silicone or medical-grade TPE, while silver ions, colorants and other additives are prohibited.
•    Certification under the EU Ecolabel; or
•    Testing based on several ISO 10993 standards covering irritation, sensitisation, cytotoxicity, chemical characterisation and extractables.
•    The manufacturer must also be certified to ISO 13485.

Ireland

Ireland revokes domestic furniture fire safety order following introduction of GPSR

On the 22 July 2026, the Irish Government revoked The Industrial Research and Standards (Fire Safety) (Domestic Furniture) Order 1995, marking a significant regulatory change for businesses placing furniture products on the Irish market. The repeal follows the application of the EU's General Product Safety Regulation (GPSR), which now provides the overarching framework for consumer product safety across the European Union.

The revoked legislation, commonly known as the Irish Domestic Furniture Fire Safety Order, had established specific national fire safety requirements for certain furniture products sold in Ireland. With the implementation of the GPSR, Ireland has moved to align its approach more closely with the harmonised EU product safety framework.

US 

California enacts new restrictions on bisphenols in paper receipts

On 30 September 2026, California Governor Gavin Newsom signed Assembly Bill 1604 (Chapter 882, Statutes of 2026), establishing new restrictions on bisphenol A (BPA) and other bisphenols in paper receipts. The legislation adds Chapter 12.3 (commencing with Section 108943) to the California Health and Safety Code and introduces a phased prohibition on intentionally added bisphenols in paper proofs of purchase. 

The law aims to reduce exposure to bisphenols commonly used in thermal receipt paper, including BPA and bisphenol S (BPS), which may present potential health concerns for consumers and workers who frequently handle receipts.

Scope and key requirements

The legislation applies to paper receipts issued at the point of sale for purchases of food, alcoholic beverages, other tangible personal property, or services.

Under the new law, businesses must comply with the following restrictions:

Effective date Requirement
1 January 2028 Prohibits the manufacture, distribution, sale, or offer for sale of paper receipts containing intentionally added BPA.
1 January 2029 Extends the prohibition to all intentionally added bisphenols in paper receipts, including BPS and other bisphenol alternatives.

The law defines bisphenols as chemicals containing two phenol rings connected by a single linker atom, including compounds with additional substituents on the phenol rings or linker atom.

Requirements for chemical substitutions

In addition to restricting bisphenols, AB 1604 establishes requirements for manufacturers replacing these substances in receipt paper.

Manufacturers must use the least toxic alternative and are prohibited from substituting bisphenols with chemicals identified by the U.S. Environmental Protection Agency or California as causing, or having specified evidence of, cancer, reproductive toxicity, or developmental harm.

Enforcement and penalties

The California Department of Toxic Substances Control (DTSC) is authorised to adopt implementing regulations and enforce the requirements.

Violations may result in administrative penalties of up to $5,000 for a first violation and $10,000 for each subsequent violation. DTSC must also publish substantiated violations and final enforcement actions on its website. 

The new restrictions will affect manufacturers and suppliers of receipt paper, as well as retailers and other businesses involved in distributing or using paper receipts in California. Businesses should review their receipt paper formulations and supplier documentation to prepare for the upcoming compliance deadlines.

California introduces mandatory ingredient disclosure requirements for children's diapers

On September 28th, 2026, California Governor Gavin Newsom signed Assembly Bill 1901 (Chapter 719, Statutes of 2026), establishing new ingredient disclosure requirements for children's diapers. The legislation adds Section 108948 to the California Health and Safety Code and requires manufacturers to provide information on intentionally added ingredients through product packaging and publicly accessible websites. 

Scope and product coverage

The law applies to children's diapers, including disposable diapers, protective underwear, liners, boosters, inserts, and underpads intended to absorb or contain urine and faecal waste.

The definition also encompasses diaper components, such as absorbent materials, outer shells, adhesive tabs, wetness indicators, dyes, and fragrances.

For purposes of the legislation, intentionally added ingredients include chemicals deliberately incorporated into children's diapers to achieve a functional or technical effect. This also covers components or intentional breakdown products of added chemicals that serve a functional or technical purpose.

Website ingredient disclosure requirements

Beginning January 1st, 2029, manufacturers of children's diapers sold, distributed, or manufactured in California must provide ingredient information for each specific diaper product on a dedicated page of the manufacturer's website.

The disclosure must include:
•    The chemical or raw material name of each intentionally added ingredient.
•    The Chemical Abstracts Service (CAS) number.
•    The specific function or purpose of each ingredient in the product.

The information must be clearly organised, with ingredients listed in order of predominance by weight. The ingredient name, CAS number, and corresponding function must appear together to facilitate identification.

Online product listings may also display the ingredient information directly or provide a link to the manufacturer's dedicated disclosure page.

Packaging labelling Requirements

In addition to website disclosures, the law establishes mandatory labelling requirements for children's diaper packaging.

Compliance Date Requirement
1 January 2029 Children's diapers manufactured or distributed in California must display a list of intentionally added ingredients and the manufacturer's dedicated ingredient disclosure website address on the outermost packaging.
1 July 2029 All children's diapers sold in California must comply with the packaging disclosure requirements.

The required information must be presented in an easily identifiable manner. 

Compliance implications

The legislation establishes ingredient transparency requirements rather than new chemical concentration limits or prohibitions. Manufacturers will need to obtain ingredient information from their suppliers, identify the functions of intentionally added chemicals, and update their product packaging and websites before the applicable deadlines.

Connecticut expands approved PFAS labelling options for consumer products

The Connecticut Department of Energy and Environmental Protection (DEEP) has expanded its list of approved labelling statements and symbols for consumer products containing intentionally added per- and polyfluoroalkyl substances (PFAS). The update provides manufacturers with additional options to comply with the state's PFAS labelling requirements under Connecticut General Statutes § 22a-903c, established through Public Act 24-59.

Since July 1st, 2026, Connecticut has required specified consumer products containing intentionally added PFAS to carry labels informing purchasers of their presence. The requirements apply to 12 product categories, including apparel, carpets and rugs, cleaning products, cookware, cosmetics, dental floss, fabric treatments, juvenile products, menstruation products, textile furnishings, ski wax, and upholstered furniture. 

Expanded labelling options

DEEP has approved additional labelling statements, including:

  • "This product contains PFAS"
  • "Contains PFAS in internal components"
  • "Contains PFAS in packaging components"
  • A chemical disclosure statement beginning with "This product contains:", followed by a list of chemicals that includes "PFAS" or "PFAS chemicals"

In addition, manufacturers may use two approved symbols featuring an Erlenmeyer flask containing the letters "PFAS," either with or without an exclamation mark.

These alternatives supplement previously approved statements, including "Contains PFAS," "Made with PFAS," "Made with PFAS chemicals," "Made with intentionally added PFAS," and "This product contains PFAS chemicals."

DEEP may also approve alternative labelling language or symbols upon petition by a manufacturer or producer.

Labelling requirements

Regardless of the wording or symbol selected, labels must be clearly visible before sale and inform consumers that PFAS are present. Labels affixed to products must be sufficiently durable to remain legible throughout the product's useful life.

The expanded labelling options do not change the existing notification requirements or upcoming restrictions on intentionally added PFAS.

Upcoming restrictions

Beginning 1 January 2028, Connecticut will prohibit the manufacture, sale, offer for sale, and distribution of specified products containing intentionally added PFAS, subject to applicable statutory exemptions. The prohibition covers the 12 product categories identified above, as well as outdoor apparel for severe wet conditions and firefighting turnout gear.

Manufacturers and other businesses supplying products to Connecticut should review their existing PFAS disclosures and ensure compliance with applicable labelling, notification, and future prohibition requirements.

CPSC proposes expanded substantial product hazard designations for corded window coverings

On 24 September 2026, the U.S. Consumer Product Safety Commission (CPSC) published a Notice of Proposed Rulemaking (NPRM) to expand the types of hazardous cord configurations on window coverings that would be classified as substantial product hazards (SPHs) under the Consumer Product Safety Act (CPSA).

The proposal would amend 16 CFR Part 1120 by incorporating additional requirements from ANSI/WCMA A100.1-2022, American National Standard for Safety of Corded Window Covering Products. It builds on the existing 2022 rule and aims to further reduce strangulation risks associated with accessible cords, particularly for children aged eight years and younger. 

Proposed requirements

The proposed amendments would expand the list of hazardous characteristics for both stock (ready-made) and custom window coverings.

The following conditions would be designated as substantial product hazards:

  • Accessible operating cords: Free-hanging operating cords on custom window coverings exceeding 8 inches in length in any use position.
  • Continuous loop systems: Exposed continuous loops on custom horizontal blinds, regardless of whether a tension device is installed. For other custom window coverings, exposed continuous loops without the required tension device or other permitted protective system.
  • Retractable cords: Single retractable cord lift systems on custom window coverings with a stroke length exceeding 36 inches.
  • Roll-up shades: Cord loop lift systems on stock or custom roll-up style shades.
  • Warning labels: Missing required warning labels or tags on custom window coverings equipped with certain continuous loop operating systems or single retractable cord lift systems.

The proposal would also update the referenced voluntary standard from ANSI/WCMA A100.1-2018 to ANSI/WCMA A100.1-2022 for the applicable provisions governing operating cords, inner cords, manufacturer labels, and other safety features.

Regulatory implications

Under Section 15(j) of the CPSA, CPSC may designate consumer products with specified hazardous characteristics as substantial product hazards when the statutory criteria are satisfied.

Products falling within these designations may be subject to mandatory reporting obligations under Section 15(b) of the CPSA, corrective actions, recalls, and restrictions on importation into the United States.

If finalised, the proposed amendments would expand the circumstances under which noncompliant window coverings are automatically regarded as presenting substantial product hazards. Manufacturers, importers, distributors, and retailers should therefore review applicable cord configurations, product designs, and labelling against the updated ANSI/WCMA standard.

Public comment period

The proposed rule was published on 24 September 2026, and public comments will be accepted until 23 November 2026. The amendments have not yet been finalized, and the existing requirements under 16 CFR Part 1120 remain applicable.

New Jersey bans intentionally added PFAS in apparel and diaper products

On 27 August 2026, the state of New Jersey signed S1281 into law as P.L.2026, c.76, amending New Jersey's 2025 "Protecting Against Forever Chemicals Act" (P.L.2025, c.202) to add apparel and diaper products as newly covered categories. The base 2025 Act already regulates intentionally added PFAS in carpets, cosmetics, fabric treatments, plant-fiber derived food packaging, and cookware.

Scope

The law creates two separate covered-product categories:

  • Apparel — clothing items intended for regular wear or formal occasions, defined broadly to include undergarments, shirts, pants, skirts, dresses, overalls, bodysuits, vests, dancewear, suits, tops, leggings, school uniforms, athletic wear, sports uniforms, everyday swimwear, formal wear, onesies, footwear, and everyday work-wear, plus outdoor apparel (including apparel designed for severe wet conditions).
  • Diaper products — absorbent products, disposable or reusable, manufactured to be worn to contain human waste. Menstrual products are excluded from this definition (diapers were carved out of the "apparel" definition and given their own category during the Assembly committee substitute process.)

Key obligations

  • Prohibition: No person may sell, offer for sale, manufacture, or distribute for sale or use in New Jersey any apparel or diaper product containing intentionally added PFAS.
  • "Intentionally added PFAS" is defined as PFAS added to a product, or intentionally used during development of a product or a product component, to provide a specific characteristic, appearance, or quality, or to perform a specific function — including known degradation byproducts. The definition excludes technically unavoidable trace PFAS stemming from impurities in natural or synthetic ingredients or from the manufacturing process.
  • Manufacturer certification: Manufacturers must certify, in a form and manner to be prescribed by the New Jersey Division of Consumer Affairs (NJDCA), that each apparel or diaper product they manufacture does not contain intentionally added PFAS. Certifications are valid for five years and must be updated if manufacturing processes or materials change. Manufacturers must provide certification copies to purchasers.
  • "Manufacturer" is defined to include the entity whose brand name is affixed to the product. For imported products, the importer or first domestic distributor is deemed the manufacturer if the actual manufacturer/brand owner has no U.S. presence.

Effective dates

  • The act took effect immediately upon signing (27 August 2026).
  • The sales/manufacture/distribution prohibition and the certification requirement take effect two years later, on 27 August 2028.
  • The Division of Consumer Affairs is authorised to adopt implementing regulations and will prescribe the form and manner of the required certification. Companies should monitor future NJDCA guidance or rulemaking concerning implementation of the certification requirement.

Exemptions / Carve-Outs

  • Product exclusions: Personal protective equipment; clothing exclusively for U.S. military use; and equipment/protective apparel designed for safe motorcycle or off-highway-vehicle operation.
  • Media liability: The law does not impose liability on news media that accept or publish advertisements for otherwise regulated products.

Enforcement

A violation of this section constitutes a violation of the underlying Protecting Against Forever Chemicals Act (P.L.2025, c.202), triggering that act's existing remedies and penalties. Under that framework, NJDCA may impose civil administrative penalties in the range of $1,000–$20,000 per violation per day; penalties pursued through the courts can reach up to $25,000 per day.

New Mexico issues guidance on mandatory PFAS labelling for consumer products

The New Mexico Environment Department (NMED) has published guidance to assist manufacturers and other businesses in complying with the state's labelling requirements for consumer products containing intentionally added per- and polyfluoroalkyl substances (PFAS).

The guidance, issued in July 2026, supports implementation of New Mexico's PFAS Protection Act (House Bill 212, enacted in 2025) and its implementing regulations under 20.13.2 NMAC. The regulations establish phased restrictions, reporting obligations, and labelling requirements for consumer products containing intentionally added PFAS.

PFAS labelling requirements

Beginning 1 January 2027, consumer products manufactured on or after this date and containing intentionally added PFAS must carry a label identifying the presence of these substances, unless a specific exemption or approved waiver applies. The requirement also covers finished products containing components with intentionally added PFAS.

The mandatory label must feature an Erlenmeyer flask symbol with the letters "PFAS" displayed inside the flask. The label must be clearly visible and legible to consumers before purchase.

NMED's guidance provides clarification on several aspects of labelling compliance, including:

  • Product and packaging labels: Labels must be displayed on products and, where packaging prevents the product label from being visible before purchase, on the packaging. Special provisions apply to products too small to accommodate a legible label.
  • Label size and appearance: The PFAS lettering must be no smaller than the largest font used for other consumer information on the product or packaging. No specific label colour is mandated.
  • Online and catalog sales: PFAS disclosures must be included in online product listings and other sales materials when consumers cannot view the product or packaging label before purchase.
  • Complex durable goods: The guidance provides examples of labelling through product specifications, manuals, and other consumer-facing documentation.
  • Alternative labelling: Manufacturers may seek NMED approval to use PFAS labels adopted in other states, subject to applicable conditions.

Exemptions and labelling waivers

Certain product categories are exempt from the labelling requirements, including specified federally regulated products such as medical devices and drugs and certain pesticide products.

Manufacturers may also request a labelling waiver for eligible products where intentionally added PFAS are confined to internal components that do not come into contact with consumers during intended use, provided the applicable regulatory conditions are satisfied.

Importantly, products containing fluoropolymers may be exempt from PFAS reporting requirements and sales prohibitions but remain subject to labelling obligations.

Upcoming compliance deadlines

Date Requirement
1 January 2027 PFAS labelling and initial reporting requirements begin; restrictions take effect for specified products, including cookware, food packaging, dental floss, and juvenile products
1 January 2028 Additional PFAS prohibitions apply to categories including textiles, carpets and rugs, cleaning products, fabric treatments, and upholstered furniture
1 January 2032 Broader prohibition applies to other products containing intentionally added PFAS, subject to exemptions and currently unavoidable use designations

Manufacturers, importers, and retailers supplying products to New Mexico should review the composition of their products, identify any intentionally added PFAS, and evaluate applicable labelling, reporting, and prohibition requirements before the relevant compliance deadlines.

Canada

Health Canada requires products and packaging with button/coin batteries to meet safety criteria

On 18 September 2026, Health Canada added products containing button/coin batteries, and the packaging of button/coin batteries, to Table 3 of its approach to the General Prohibitions under the Canada Consumer Product Safety Act (CCPSA). Table 3 is Health Canada’s list of product classes it has formally determined to be a danger to human health or safety. The identified hazard is severe internal injury resulting from battery ingestion. Products and packaging that don’t meet the listed criteria, or an equivalent, can no longer be manufactured, imported, advertised, or sold in Canada.

What makes this update different

A single listing impacts three aspects of compliance: battery accessibility within the product, the packaging of loose batteries, and hazard labelling. Because each area has distinct requirements, the design, packaging, and labelling teams must work together to ensure compliance.

There is no transition period. Paragraphs 7(a) and 8(a) of the CCPSA are already in force, so the listing applies from the day it was posted. Health Canada says it will prioritise compliance promotion after an update, but it can enforce immediately. 

On the product side, Canadian requirements are closely aligned with those in the US. Both use ANSI/UL 4200A-2023 for non-toy products and require toys to meet the requirements of toy safety standard ASTM F963, so a US-compliant product is a good starting point. The Canadian packaging and labelling criteria cite different standards. Unlike the US, Canada does not currently require special packaging for zinc-air batteries. Health Canada also cites the mandatory standards from Australia’s ACCC and the UK’s PAS 7055:2021 as comparable measures.

Warnings must be bilingual. Appendix C of the assessment gives each warning in English and French and accepts equivalent statements in both languages, so a US label written only in English needs a French translation.

Scope

The assessment defines button/coin batteries as small single-cell batteries whose diameter is greater than their height. They can be lithium, alkaline, silver oxide, or zinc-air, and run from 5 to 30 mm across. Table 3 covers three groups:

  • Consumer products that are not toys: products that incorporate or use button/coin batteries, assessed against ANSI/UL 4200A-2023.
  • Toys: products intended for use by a child under 14 years of age in learning or play, assessed against ASTM F963-23.
  • Battery packaging: packaging for lithium, alkaline, and silver oxide button/coin batteries, with separate criteria for reclosable and non-reclosable packages. The Notice specifies that child-resistant packaging requirements apply to batteries sold separately.

Scope exclusions: Consumer products that use zinc-air button/coin batteries, and packaging for zinc-air batteries. 

Key obligations

  • Prohibition: No one may manufacture, import, advertise, or sell a covered product or battery package that doesn’t meet the criteria listed in Table 3, or equivalent.
  • Product criteria: Non-toy products must meet ANSI/UL 4200A-2023, and toys must meet ASTM F963-23. The assessment sorts the requirements into battery security, accessibility, captive screws, secureness, performance (use-and-abuse testing), and safety warnings, and points to sections 5.2 to 5.7, 6.1 to 6.4, and 7 of UL 4200A-2023 and 4.25.4, 5.14, and 8.5 to 8.10 of ASTM F963-23. UL 4200A-2023 generally requires a tool or coin, or two independent and simultaneous movements, to open a battery compartment by hand. These requirements are intended to reduce the risk of child access to button/coin batteries.
  • Packaging criteria: Reclosable packages: CAN/CSA Z76.1-99 (R2003) or ISO 8317:2015. Non-reclosable packages: ISO 28862:2018, or Annex E of CSA C22.2 No. 60086-4:19 (R2024) for lithium batteries or Annex E of IEC 60086-5:2021 for batteries with aqueous electrolyte.
  • Labelling criteria: Labelling, marking, and instruction requirements can be met under any of ANSI/UL 4200A-2023; CSA C22.2 No. 62368-1:25; ASTM F963-23; CSA C22.2 No. 60086-4:19 (R2024); IEC 60086-5:2021; ANSI C18.3M Part 2-2024; CSA C22.2 No. 62133-1:20; or CSA C22.2 No. 62133-2:20. The Notice and the assessment cite the 2024 edition of ANSI C18.3M Part 2, while the Table 3 summary lists 2023.
  • Label placement: Product warnings go on the product packaging (UL 4200A-2023 and ASTM F963-23). Battery warnings go on the battery packaging, and batteries larger than 20 mm in diameter also need a label on the battery itself.
  • Label content: Product-level warnings say that the product contains a button/coin battery, that swallowing can cause severe internal chemical burns in as little as 2 hours and can be fatal, that new and used batteries must be kept away from children, and that a battery that may have been swallowed or inserted into the body needs immediate medical attention. Warnings for batteries and battery packaging vary by chemistry and standard. Appendix C of the assessment has the exact wording and example labels.
  • Language: Required warnings must be in both English and French, using the Appendix C wording or an equivalent statement in both languages.
  • Compliance beyond the criteria: Meeting the listed criteria doesn’t make a product fully compliant with the CCPSA. Health Canada notes there may be other health or safety concerns with these or similar products and expects industry to review products for all potential hazards.

Effective dates

  • Requirements became effective on 18 September 2026, when the Table 3 entry was posted.
  • There is no legislated transition period. The general prohibitions were already in force.

Enforcement

Health Canada can act immediately once it has reasonable grounds to believe a product is a danger to human health or safety. The Notice lists seizure, orders to take corrective measures, orders to recall products, administrative monetary penalties, and criminal prosecution. Under Health Canada’s enforcement approach, actions are proportional to the risk a product presents, and a product doesn’t have to be on any table for Health Canada to act. This underscores the importance of immediate compliance assessment for affected products.