Industry guidance related to the Corded Window Coverings Regulations: Scope
Scope of the Corded Window Coverings Regulations
A window covering product is within scope of the Regulations, and all the requirements apply, if:
- it is a "corded window covering" as defined in the Regulations; and
- it is a "consumer product" as defined in the CCPSA
In the Regulations,
"corded window covering means an indoor window covering that is equipped with at least one cord."
The first concept of the definition is as follows:
"an indoor window covering"
To be in scope of the Regulations, a product must first be an indoor window covering, where it can conceal the window by extending over the interior area of the window. In doing so, it serves the conventional purposes of a window covering: light control or enhancing privacy.
The Regulations do not capture exterior window coverings such as shutters, exterior window screens or shades, storm panels, awnings, or any other outdoor window coverings.
The second concept of the definition is:
"that is equipped with at least one cord"
The phrase "is equipped with" means that a cord is incorporated into the design of the finished product. Factors to consider in determining whether a product is equipped with a cord may include:
- whether the product is provided with a cord or if a cord is specified for the product in the installation instructions, even if the specified cord may be obtained separately;
- whether the cord is integral to the product in terms of being part of the whole (not separate);
- whether the cord is necessary for its operation.
A primary consideration concerning the scope of the Regulations is whether the corded window covering qualifies as a "consumer product" as defined in the CCPSA. In the CCPSA,
"consumer product means a product, including its components, parts or accessories, that may reasonably be expected to be obtained by an individual to be used for non-commercial purposes, including for domestic, recreational and sports purposes, and includes its packaging."
Corded window coverings may be installed in both non-commercial buildings (residences) and commercial buildings (hotels, office buildings, schools, etc.). However, where the product is found, or what type of building the product has been installed in, does not determine whether the corded window covering is a "consumer product". Rather, whether a product meets the definition of "consumer product" is determined by whether it may reasonably be expected to be obtained by a consumer for a non-commercial purpose.
A corded window covering that could reasonably be expected to be obtained by a consumer for a non-commercial (residential) purpose is a "consumer product" and subject to the Regulations, even in circumstances where the sales transaction for the corded window covering is between two commercial entities (for example, a manufacturer sells a corded window covering to a home builder).
If the corded window covering is not made available to consumers for non-commercial purposes, it is not a "consumer product", and therefore, not subject to the Regulations. Corded window coverings sold exclusively to commercial entities for commercial purposes are not subject to the Regulations (for example, a manufacturer sells a unique corded window covering design to a restaurant chain that is not available to consumers).