This is just a summary or what I learned and the conclusions I came to while I did my own personal research into making items that would be compliant with Canadian regulations. (I read the sources for my information quite carefully and read through them several times, so I feel like I have a good grip on what I'm talking about but please don't hurt me if I have something wrong. If you want to be 100% sure that you are compliant, please do your own research too after you finish reading. THANKS!)
I am not going to cover what is required to set up your business in this article. I am only going to take you through the steps required to make compliant items.
There are really only two steps to this:
Labeling your items correctly
Making sure your materials are compliant
Diapers:
Labeling your diapers:
- Diapers are eligible for a non permanent tag. This means you may use a sticker, hand tag, wrapper etc and it doesn't need to be a sewn in or able to withstand washing like a permanent tag.
- There are 2 important pieces of information that must be on your tags: Your dealer identity and your fiber content.
- Your dealer identity can be listed in 2 ways: you may give your name and full postal address or your CA number (if you have one)
- Fiber content must be expressed in percentages by mass.
- You must list the fiber content of the different fabrics that you used separately, and say where you used them (The outer shell, lining, etc.)
- You do not need to list the fiber content of any findings (defined as textile fiber products that are added for a functional purpose). This includes elastic, thread, gussets and fasteners (snaps/applix)
- On the subject of bilingual tags: You need to have your fiber content section include both English and French unless you live in an area where only one official language is used in consumer transactions (My best advice is to look up the official language of your area or just go ahead and include both the English and French- after all, Canada as a whole is bilingual and it’s really only a few lines of text) . Your dealer identity only needs to be in one language. (Note: If you live in the province of Quebec, you have different requirements altogether)
- You are not required to give care information. But if you decide to list it anyway, the information should be in English and French also and should give an appropriate wash routine. (I recommend this wash routing for diapers)
- If you sell hybrid fitted diapers offline in Ontario, Quebec or Manitoba, your poly fleece layer is considered stuffing. This means you will need to register, and you also will have more labelling guidelines. I cannot comment anymore because this is not something I have any experience with.
Making diapers with compliant materials:
Some of your materials will need to pass testing in order to be proven to be safe enough to use in 'for sale' items. This can be a little bit confusing so I will explain as best I can. The official stance of Health Canada is that certain textile products need certain testing done. However, according to an individual in the Canadian compliance facebook group (Join! It's great!), the way that an official that they phoned about the issue explained it to them was that if you could be 'reasonably' sure that the testing is unnecessary then you don't need to have it done (Quite a Canadian way of doing business, eh?). So what people have been doing is following the USA standards since it's more clear cut in the way that it describes which fabrics are exempt and which are not, and the general consensus is that their standards are more rigid than ours. so anything that would pass in our neighborland to the south will certainly be okay here.
What am I saying? That I've been operating under the assumption that if a fabric is exempt from needing testing in the USA then I can be 'reasonably' sure that it doesn't need it here either.
What fabrics are exempt then? Here is a list of commonly used fabrics and materials for diaper making and what testing you will probably need to have done to them.
For the sake of keeping this article brief, I am only going to comment on fabrics that I believe are commonly used or that I use myself.
- BPA/Phalates testing: For diapers, you don't need to worry about this as it is only required for items that are used to facilitate eating (like bibs) or sleeping (like pajamas)
- Lead testing:
- Any part that is not touching the skin is exempt from lead testing.
- Anything made entirely from any of the following or a combination of the following is exempt: cotton, kapok, flax, linen, jute, ramie, hemp, kenaf, bamboo, coir, sisal, silk, wool (sheep), alpaca, llama, goat (mohair, cashmere), rabbit (angora), camel, horse, yak, vicuna, qiviut, guanaco, rayon, azlon, lyocell, acetate, triacetate, rubber, polyester, olefin, nylon, acrylic, modacrylic, aramid, or spandex
- As far as common diaper making materials go, what does that leave that still requires testing? Resin snaps (if they touch the skin) should be lead tested.
- Flammability testing:
- Any part that is not exposed to the air when worn is exempt from flammability testing.
- Any fabric that is plain (as in, it doesn't have a raised surface like velour or terrycloth) and it weighs 2.6oz/sq yard or more, is exempt.
- Anything that is made entirely of one or more of the following is exempt: acrylic, modaacrylic, nylon, olefin, polyester, or wool
- Anything with a laminate layer (PUL) is exempt as long as the laminate side isn't exposed. (The laminate side should never be exposed to air unless you have a very new and strange design unlike anything I've ever seen)
- As far as common diaper making materials go, what does that leave that still requires testing? If you are using bamboo/cotton velour as your inner fabric, you will need flammability testing for it. A fitted made entirely from something like bamboo/cotton/hemp terry may need flammability testing.
Wet bags:
Labeling your wet bags:
- Wet bags are not specifically described in the Textile Labelling Act as being exempt from needing labels; however, handbags and carry cases are all listed as being exempt for needing any labels at all.
For this reason, I believe there reason to believe that wet bags do not need any kind of tags or labels. - With that said, I make non-permanent labels for my wet bags in the same way as I described in the section about non-permanent tags for diapers because I am proud of the way I make my items and I like to share the extra information about them with my customers. (NOTE: If you decide to make labels, In the same way that findings for diapers do not need to have their fiber content listed, zippers and thread used in your wet bags do not need to be listed. A non-laminated lining is also considered a finding, but PUL lining must be listed.)
Making wet bags from compliant materials:
- BPA/Phalates testing: For wet bags, you don't need to worry about this as it is only required for items that are used to facilitate eating (like bibs) or sleeping (like pajamas)
- Lead testing: Wet bags are entirely exempt from needing lead testing because they are not intended for children.
- Flammability testing: Wet bags are also exempt from flammability testing because they are not clothing.
Yes, I am basically telling you that wet bags are easy peasy because you don't really need to do anything other than whip them up and find a buyer!
(Please scroll up and read the little blurb that I wrote in the beginning of the 'making compliant diapers section for an explanation as to why I am using the USA flowcharts for determining which fabrics are exempt)
Menstrual Pads (aka mama cloth/sanitary napkins)
Labeling menstrual pads (and some extra info):
The Textile Labeling Act does not specifically list menstrual pads as an item that does is eligible for a non-permanent label, but diapers are on the list of eligible items. Because menstrual pads are so similar to diapers in their construction and function, I feel like it is safe to assume they are also eligible for a non-permanent tag. (Instructions for making compliant non permanent labels are under the diapers section- scroll up)
(NOTE: a 'sanitary belt' is exempt from needing any kind of labeling, so there may be a case for menstural pads not needing any label at all. I feel
(NOTE: a 'sanitary belt' is exempt from needing any kind of labeling, so there may be a case for menstural pads not needing any label at all. I feel
I personally called Health Canada regarding menstrual pads because in the USA menstrual pads are considered medical devices and therefore it is very expensive for sellers to become compliant. This is not the case in Canada. They are not considered a medical device here.
Making menstrual pads from compliant materials:
- BPA/Phalates testing: Menstrual pads are not used to facilitate eating or sleeping and are therefore exempt.
- Lead testing: Menstrual pads are entirely exempt from needing lead testing because they are not for children
- Flammability testing: menstrual pads are not clothing and therefore are exempt from needing flammability testing.
Nursing pads
Labeling nursing pads:
The Textile Labeling act does not specifically list nursing pads as an item that is exempt from having a permanent label; however, as they are so similar in construction and function to diapers (which ARE listed as items eligible for a non-permanent label) I feel like they should also be eligible for a non-permanent label.
Making nursing pads from compliant materials:
- BPA/Phalates testing: Now, nursing pads are used to facilitate eating in their own way; however, you still only need BPA/phalates testing if you use fabric that is made from “plasticized” material (laminates). So if you use PUL, and the laminated side is exposed, you will need BPA/Phalates testing.
- Lead testing: Nursing pads are entirely exempt from needing lead testing because they are not for children.
- Flammability testing: Nursing pads are also exempt from flammability testing because they are not clothing.
(Please scroll up and read the little blurb that I wrote in the beginning of the 'making compliant diapers section for an explanation as to why I am using the USA flowcharts for determining which fabrics are exempt)
A few more tips before I go....
- If you have just finished reading this and have found that you need any kind of testing on some of your materials, this doesn't necessarily mean you need to pay a lab to preform the testing. Ask the supplier who you buy your materials from if they have the certificates for their products already. Many popular sources for diaper making supplies tend to already have the required testing done.
- Registering for a CA number will save you from having to put your name and full postal address on your labels.
- If you plan to use stickers as your non-permanent labels, it is best to test them on a piece of scrap fabric before putting them on 'for sale' items. They may leave residue.
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