Industry guidance related to the Corded Window Coverings Regulations: Safety requirements

Safety Requirements

Small parts

Section 2 of the Regulations addresses choking hazards by restricting the size of small parts that a child may gain access to during reasonably foreseeable use of the corded window covering. Accordingly, Health Canada's test method assesses small parts to which a child may gain access. This includes external components of a headrail, including parts that have outward-facing surfaces or protrude beyond the confines of the headrail.

Components that are entirely inside the headrail when the product has been installed are excluded from testing.

Lead content

Section 3 of the Regulations addresses the risk associated with lead exposure by restricting the lead content found on external components of corded window coverings, which is harmful for young children. Similar to the testing of small parts, components that are outside the headrail, including outward facing surfaces are considered external components subject to lead testing.

Requirements for cords

The Regulations restrict the length of reachable cords and the size of loops that can be created to help eliminate the risk of strangulation. Regulations require that any cord that can be reached must be too short to wrap around a one-year-old child's neck (in other words, not more than 22 cm in length) or form a loop that can be pulled over a one-year-old child's head (in other words, not more than 44 cm in perimeter) when pulled by a force that a child is able to exert (in other words, 35 N). Section 4 of the Regulations states the requirement for unreachable cords, while sections 5 through 8 state the requirements for reachable cords.

In the Regulations, "reachable" with respect to a cord, "refers to the part of the cord that any person can touch when the corded window covering has been installed, whether the window covering is fully opened, fully closed or in any position in between."

The assessment of whether a cord is reachable takes place when the window covering is in a resting state (in other words, a static assessment). Health Canada's test method assesses whether a cord is reachable by attempting to contact it with a reachability probe.

Unreachable cords

Unreachable cords are cords that cannot be touched when the product is at rest.

A cord inside a channel, a retractable cord, or any other cord that cannot be touched when the window covering is in its resting state, would be considered an unreachable cord. In other words, if a cord can only be touched while the product is being operated, it would be considered an unreachable cord.

Unreachable cords are subject to section 4 of the Regulations. Section 4 states that unreachable cords "must remain so … throughout the useful life of the corded window covering." Therefore, a cord that is not reachable when the product is at rest must remain unreachable when the product is at rest throughout its useful life.

Reachable cords

A corded window covering must be installed before assessing if any of its cords are reachable. A properly installed product is one that has been installed in accordance with the instructions provided pursuant to section 14 of the Regulations.

After a cord is determined to be reachable, a pull force attaining 35 N is gradually applied (in any direction) and the resulting length or loop measurement is taken. The word attaining means that the force is applied from 0 N (in other words, cords at rest) to 35 N. In strict terms, all reachable cords are subject to the length and loop restrictions for all forces between 0 and 35 N. If, for example, a reachable cord is found at rest (in other words, 0 N) exceeding 22 cm, it would be non-compliant to section 5 or 6 of the Regulations, which describe the requirements for reachable cords with a free end, or no free end, respectively.

Guidance on additional components or accessories that help to achieve compliance for unreachable and reachable cords

The requirements for unreachable cords are found in section 4 of the Regulations, while sections 5 through 8 describe the requirements for reachable cords. In short:

• unreachable cords must remain unreachable throughout the useful life of the corded window covering, and
• reachable cords must not exceed 22 cm in length nor have any loops that exceed 44 cm in perimeter when pulled by the gradual application of force attaining 35 N

If a component or accessory that makes a cord unreachable is not assembled onto the corded window covering, can be easily removed, or fails, the cord would be non-compliant with the requirement to remain unreachable "throughout the useful life of the corded window covering".

More specifically, the following circumstances would result in non-compliance with section 4 of the Regulations. This applies specifically to cords that are made unreachable due to an additional component or accessory:

• the gradual application of force attaining 35 N applied to the reachable part of a cord dislodges or breaks an assembled component or accessory, exposing the unreachable part of the cord
• an assembled component or accessory that makes a cord unreachable can be removed by hand (without the use of a tool), or
• a component or accessory intended to make a cord unreachable is not assembled on the product as received by the consumer, and it is reasonably foreseeable that it will not be assembled

Health Canada's test method assesses additional components or accessories that help to achieve compliance with sections 5 through 8 for reachable cords in a similar manner. A corded window covering will be assessed without the additional component or accessory assembled onto the product if:

• the additional component or accessory that helps to restrict the length of a cord or size of loop can be removed by hand, without the use of a tool, or
• it is not pre-assembled onto the product and is not necessary for the product to function either in full or in part

Therefore, Health Canada advises that all components necessary for achieving compliance be pre-assembled on the finished product (as received by the consumer) such that they cannot be removed without the use of a tool.