Health Canada Finalizes Button Battery Rules: Apparel and other products covered

Apparel and other consumer products containing button or coin batteries are now subject to newly reinforced compliance requirements in Canada. Companies that sell apparel containing button batteries need to take note of these changes.

Health Canada has formally added these products — and their packaging — to Table 3 of the General Prohibitions process under the Canada Consumer Product Safety Act (CCPSA), effective September 18, 2026, meaning products that fail the specified safety criteria are now prohibited from manufacture, import, advertisement, or sale in Canada. 

These changes were made after a consultation process.  The changes take effect immediately with no transition period.  

CAF members with light-up, flashing, or musical apparel should confirm compliance now rather than wait for a compliance deadline that doesn't exist.

Health Canada has stated this is not a ban, and anticipates that most products currently on the Canadian market already meet the criteria and will remain available. The prohibition applies only to products that fail the specified safety criteria.

Button and coin batteries are commonly used in light-up, flashing, and musical apparel:

• Holiday and novelty clothing — light-up sweaters, flashing headbands, illuminated costume pieces

• Children's footwear and accessories — light-up shoes, flashing caps, glowing hair accessories and jewelry

• Dress-up and costume wear — sound or light modules in children's theatrical and play garments

What "Table 3" means

Table 3 is the final stage of Health Canada's three-step hazard process (Identification → Comment Period → Determination). Because paragraphs 7(a) and 8(a) of the CCPSA are already in force, there is no legislated coming-into-force or transition period when a product class moves to Table 3. Health Canada says it will prioritize compliance promotion following the update, but may take immediate enforcement action — seizure, recall, or prosecution — at any time it has reason to believe a product is non-compliant.

The compliance standard

Battery security and performance:

• Non-toy products: ANSI/UL 4200A-2023

• Toys (under age 14): ASTM F963-23

Labelling (bilingual, on product or packaging) — any one of: ANSI/UL 4200A-2023, ASTM F963-23, CSA C22.2 No. 60086-4:19, IEC/CEI 60086-5:2021, ANSI C18.3M Part 2-2023, CSA C22.2 No. 62133-1:20 or -2:20, CSA C22.2 No. 62368-1:25, or their equivalents

Health Canada notes that equivalent performance criteria not listed on Table 3 may also be acceptable — firms aren't locked into these exact standards if they can demonstrate equivalent hazard mitigation.

The hazard basis

Health Canada's underlying data: 41 reported incidents involving button/coin batteries from June 2011 to June 2025, including four deaths, plus roughly 1,400 emergency department reports over the same period, 79% involving children under five. A swallowed battery can cause fatal internal chemical burns within two hours; depleted batteries still carry enough charge to trigger the reaction.

If you sell these products, you should:

• Audit any product containing a button/coin battery against ANSI/UL 4200A-2023 or ASTM F963-23, as applicable 

• Check battery compartments for child-resistant closures

• Verify bilingual warning labelling on product, packaging, and instructions

• Confirm garments cannot be laundered with the battery/electronics module installed unless those components are removable

• Confirm compliance with suppliers 

• Retain compliance documentation — even with HC's expectation that most products already comply, being able to demonstrate conformity is the practical protection if a product is questioned

 

---

 

Sources

• Health Canada, Information on Health Canada's Approach to the General Prohibitions under the CCPSA (Table 3 updated September 18, 2026)

• Health Canada, Danger to Human Health or Safety Assessment — Button/Coin Batteries

• Health Canada, Button Battery Safety