What is SOR/2024-217?

SOR/2024-217 is a mandatory regulation issued by Health Canada on November 20, 2024, replacing the previous regulation SOR/2016-185. Its core objective is to reduce the flammability risk of tent materials while minimizing the excessive use of flame retardant chemicals.

Scope of Application

To fall under this regulation, a product must meet the following conditions:

- Portability: Must be movable and easy to set up.

- Protective Function: Must provide protection against rain, wind, and insects.

- Material Composition: Must be fully or partially made of fabric/flexible materials.

- Top Structure: Must have a roof.

- Exit Restrictions: Must have at least one restricted entry/exit side.

- Exclusion from Building Codes: Large, permanent tents are not covered.

CAN/CGSB-182.1-2020: Referenced Technical Standard

SOR/2024-217 references CAN/CGSB-182.1-2020, a standard that specifies flammability performance and labeling requirements for tent materials, including test methods, evaluation criteria, and label durability.

Key differences from the previous CPAI-84 standard:

- Increased number of test samples: Raised from 3-5 to 30.

- Additional testing for weathering effects: Evaluates flammability after exposure to leaching and weathering.

- New requirements for bottom material testing.

Key Requirements Analysis

(1) Flammability Testing

1. Vertical Flame Test (CAN/CGSB-182.1-2020 §5.2.1)

- Applicable to: Main tent materials (e.g., fabric, coatings).

- Method: The material is hung vertically, ignited at the bottom, and observed for flame spread, burn duration, and molten dripping.

- Pass Criteria:

- Damage length ≤ 200 mm

- Mass loss ≤ 10%

- No flaming debris

2. Horizontal Flame Test (CAN/CGSB-182.1-2020 §5.3.1)

- When applied: Used only if the bottom material fails the vertical test.

- Requirements:

- Flame spread rate ≤ 100 mm/min

- Burn damage length ≤ 150 mm

(2) Labeling Standards and Durability

1. Labeling Requirements

- Basic Information: Product name, model, manufacturer/importer details.

- Warning Labels: Must include warnings such as “Keep away from heat and open flames” in a font size of at least 3 mm, along with a flame icon of at least 6 mm.

- Bilingual Labeling: Must be in both English and French.

2. Durability Testing

Labels must withstand simulated tests such as abrasion, washing, and sun exposure to ensure readability throughout the tent’s lifespan.

Regulatory Adjustments

1. Toy Regulations (SOR/2011-14)

- Expanded Scope: Children's play tents (e.g., teepees, bed tents) must meet ISO 8124-2 flammability requirements and have permanent warning labels.

- Exclusion Clause: Tents compliant with SOR/2024-217 are exempt from this regulation.

2. Textile Flammability Regulations (SOR/2016-194)

- Clarification: Excludes "toys that children can enter" to avoid redundant regulations.

Implementation Timeline & Transition Period

- November 20, 2025: Manufacturers/importers must fully comply with the new regulation.

- November 20, 2026: All advertising and sales materials must conform.

- Transition Benefit: Existing inventory compliant with SOR/2016-185 can still be sold until November 20, 2026.

Compliance Recommendations for Businesses

1. Prioritize Testing: Use ISO 17025-certified laboratories for flammability and labeling tests.

2. Labeling Self-Check: Ensure compliance with bilingual warnings, icon sizes, and durability requirements.

3. Product Category Differentiation: Treat children's tents separately under toy regulations.

By incorporating CAN/CGSB-182.1-2020, SOR/2024-217 systematically enhances fire safety standards for tents while streamlining alignment with toy and textile regulations. Businesses must pay close attention to the upgraded flammability testing methods, refined labeling requirements, and transition arrangements to mitigate compliance risks.