- with Senior Company Executives, HR and Finance and Tax Executives
- with readers working within the Aerospace & Defence industries
Effective June 15, 2026, Health Canada is changing the compliance test for playpens with removable floor pads and removable foldable components. Health Canada has developed an interim policy that modifies compliance testing under the Playpen Regulations, SOR/2018-186 (the “Regulation”), replacing the existing test method1 for vertical displacement with an approach that aligns with ASTM F406-24 Standard Consumer Safety Specification for Non-Full-Size Baby Cribs/Play Yards (“ASTM F406-24”). Manufacturers and distributors of playpens with flexible or soft bases sold in Canada should ensure their testing is up to date and compliant with the new requirements.
Background
The Regulation sets specific limits on how far a playpen’s floor can move upward, a requirement designed to prevent gaps where a child’s head could become entrapped. Section 29 of the Regulation currently requires that a removable floor pad composed of a rigid panel or series of rigid panels not be displaced upward more than 133 mm when tested in accordance with Schedule 14.2 It similarly limits vertical displacement of a removable and foldable component on which the floor pad rests. Health Canada’s Consumer Product Safety Program (CPSP) administers these regulations under the Canada Consumer Product Safety Act (CCPSA) as part of Canada’s post-market consumer product safety regime.
When Canada adopted the 133 mm limit in 2018, it mirrored the US Consumer Product Safety Commission (CPSC) standard. Since then, the relevant industry standard, ASTM F406-24, has been amended to include a secondary test for vertical displacement. This secondary test more appropriately evaluates products that sit directly on the floor without a tubular floor support structure, or that have flexible or soft bases. Schedule 14 of the Playpens Regulations does not contain a comparable secondary test.
Health Canada’s New Interim Policy
The interim policy is being introduced to address limitations with the current methodology. Schedule 14 measures how far a floor pad is displaced upward, but for playpens with soft or flexible bases, the entire base lifts off the ground during testing. That movement gets captured in the displacement measurement, causing products to exceed the 133 mm limit even where no genuine safety risk exists.
To address this, Health Canada is implementing an interim policy to align its test method with Section 8.28 of the ASTM F406-24 standard, conducting both the primary and secondary tests in place of the Schedule 14 test method. Under the interim policy, only products that fail both the primary and secondary tests will be considered non-compliant.
Health Canada will update its Product Safety Laboratory test method M08 Playpens, Section 4.31 (which covers the vertical displacement test) to reflect the new procedure. The updated test method takes effect on June 15, 2026, and Health Canada will apply the interim policy and updated test method to all compliance and enforcement activities on playpens conducted after that date.
Key Takeaways
This change is particularly significant for manufacturers and distributors of playpens with flexible or soft bases. Under the old single-test approach, some products were testing as non-compliant even where no genuine entrapment hazard existed. The interim policy corrects this by requiring failure of both tests before enforcement action is triggered. More broadly, the move toward alignment with the ASTM F406-24 standard is a welcome development for manufacturers who routinely face the challenge of producing products that comply with divergent regulatory requirements across multiple jurisdictions.
Industry participants should note the following:
Industry participants bear full responsibility for ensuring that consumer products manufactured, imported, advertised, or sold in Canada meet all applicable requirements. Health Canada oversees a post-market regulatory regime and does not review or approve products before they enter the market.
Manufacturers and distributors should promptly assess their product lines against both the primary and secondary tests under Section 8.28 of ASTM F406-24 to confirm compliance before the interim policy takes effect on June 15, 2026.
The Playpens Regulations remain unamended. Health Canada has adopted this change as an interim enforcement policy, and manufacturers should monitor for any subsequent regulatory amendments that may formally align Schedule 14 with the updated ASTM standard.
Only playpens with flexible or soft bases that sit directly on the floor are affected. Products with traditional rigid floor support structures need not adjust their testing.
Footnotes
1. Playpen Regulations, (SOR/2018-186) Schedule 14: Tests for Vertical Displacement of Removable Floor Pad and Removable and Foldable Component.
2. Playpen Regulations, (SOR/2018-186) section 29.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
[View Source]
