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Industry guide for the classification of cribs, cradles, bassinets and sleep accessories

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Overview

This document sets out factors and considerations that Health Canada takes into account to determine whether a product manufactured, imported, advertised, or sold in Canada falls within the scope of the Cribs, Cradles and Bassinets Regulations(the regulations).

Who this guide is for

  • Manufacturers, importers, distributors, retailers, and advertisers of cribs, cradles, bassinets, and sleep accessories to these products
  • Other interested parties and stakeholders

Introduction

Cribs, cradles, bassinets, and sleep accessories to cribs, cradles and bassinets that are manufactured, imported, advertised or sold in Canada are regulated under the Cribs, Cradles and Bassinets regulations. A product that falls within the scope of the regulations must meet the applicable requirements set out in the regulations. This guide does not discuss all the regulatory requirements; for these, see the regulations. This guide does not present an exhaustive list of discussion factors and considerations involved in Health Canada's classification of these products; additional considerations may be appropriate depending on a product's characteristics.

This document may be updated from time to time. For the most recent version, consult the latest reports and publications. This document is not intended to substitute for, supersede or limit the requirements under the applicable legislation. In case of any discrepancy between this document and the legislation, the legislation will prevail.

For more information about the regulations or this document, contact a Health Canada consumer product safety office via email at cps-spc@hc-sc.gc.ca or telephone at 1-866-662-0666 (toll-free within Canada and the United States).

Legislation

Cribs, cradles, bassinets, and sleep accessories that are manufactured, imported, advertised or sold in Canada are subject to the Canada Consumer Product Safety Act (CCPSA) and the Cribs, Cradles and Bassinets Regulations.

In addition to the product-specific requirements of the regulations, it is prohibited to manufacture, import, advertise or sell any consumer product that is a "danger to human health or safety" as defined in the CCPSA (see paragraphs 7(a) and 8(a)).

Industry is responsible for ensuring their products comply with the legislation.

Background

Cribs, cradles, bassinets, and their sleep accessories are used by infants and toddlers without adult supervision. These children represent part of the population that is particularly vulnerable, both physiologically and because they cannot recognize potentially hazardous conditions. The regulations were introduced in 1974 as a measure to reduce deaths and injuries associated with the use of these products. Since then, the regulations have been updated several times to strengthen the requirements and address emerging hazards.

Classification considerations

Classification considerations for cribs, cradles, bassinets, and sleep accessories are related to the definitions of these terms in the regulations. A product that meets the definition of one of these terms is subject to the applicable requirements in the regulations.

Cribs, cradles, and bassinets

The definitions of crib, cradle and bassinet each include information on:

  • the product's sleeping surface area
  • whether the product's sides confine a child
  • whether the product can be used alone, or both alone and as an accessory
  • whether the product has a primary function of providing sleeping accommodation for a child

Sleep accessories

In the regulations, an accessory to a crib, cradle, or bassinet can be either a sleep accessory, a change table accessory, or an accessory that provides a play area for a child or enables child-caregiver interaction.

The definition of sleep accessory in the regulations includes that it:

  • is designed or advertised to be used with a crib, cradle or bassinet
  • can be placed on or fixed to the crib, cradle or bassinet
  • supports the weight of a child
  • has sides to confine a child
  • has a primary function of providing sleeping accommodation for a child

The following aspects of the definitions of cribs, cradles, bassinets and sleep accessories are discussed below:

  • sleeping surface area
  • sides to confine a child
  • the product can be used alone or both alone and as an accessory
  • primary function of providing sleep accommodation for a child

This guide discusses Health Canada's classification of sleep accessories and not the other types of accessory because classification of the other types does not require a determination of "sides to confine" and "primary function of providing sleeping accommodation."

Sleeping surface area

Cribs, cradles, and bassinets are distinguished from each other in the regulations by their sleeping surface areas. This is because certain requirements in the regulations are different for cribs, cradles, and bassinets. These differences are primarily based on the potential hazards that a child could be exposed to as a result of their size, weight and developmental abilities. For example, the minimum side height requirement for cribs is greater than the minimum side height requirement for bassinets and cradles because a crib's larger sleep surface area can accommodate older children with potentially more advanced developmental abilities.

Note that sleep accessories are not defined in the regulations by their sleep surface area.

  • In the regulations, a bassinet has a sleeping surface area that is less than or equal to 4000 cm2. In general, bassinets are meant to be used by infants until they are capable of rolling over. Children often reach this milestone between the ages of 3 to 4 months but may reach it earlier or later.
  • In the regulations, a cradle has a sleeping surface area that is greater than 4000 cm2 but less than or equal to 5500 cm2. In general, cradles are meant to be used by infants until they are capable of pushing up on their hands and knees. Children often reach this milestone between the ages of 5 to 6 months but may reach it earlier or later.
  • In the regulations, a crib has a sleeping surface area that is greater than 5500 cm2. In general, cribs are meant to be used by infants until they are capable of climbing out of the crib or reach a height of more than 90 cm. Children often reach this milestone between the ages of 18 to 24 months but may reach it earlier or later.

Note that a product that is marketed as suitable only for children 24 months of age or older is not necessarily out of scope of the regulations. For example, if it is reasonably foreseeable that a product is likely to be used by children younger than 24 months of age, and the product also meets the definition of a crib, cradle, or bassinet, then the product may fall within the scope of the regulations.

Sides to confine the child

Cribs, cradles, bassinets, and sleep accessories are defined in part by the presence of sides to confine the child. A product's sides confine the child when the sides limit the child's ability to get themselves out of the product. Considerations about the confining nature of a product's sides include:

  • the ages and abilities of a child that a caregiver will reasonably foreseeably place in the product
  • the design of the sides (their height, materials, construction, and other characteristics relevant to the side's ability to confine the child)

Note that sides do not have to meet the side height requirements in the regulations to be considered sides that confine.

The product can be used alone, or both alone and as an accessory

This means that a crib, cradle, or bassinet can also function as an accessory (such as a sleep accessory) to another crib, cradle, or bassinet. For example, a product can function interchangeably as a sleep accessory (when it is placed on or fixed to a crib), and a bassinet (when it is in stand-alone mode). A product with a sleep surface area of a crib can also function as a sleep accessory to another crib, as discussed in "Sleep Surface Area" above. Whether a product is a crib, cradle, or bassinet primarily depends on its sleep surface area (not its appearance).

A crib, cradle, or bassinet that can be used alone (that has a stand-alone mode) must meet the requirements for the specific product when it is used alone. A crib, cradle, or bassinet that can also be used as a sleep accessory to another product must meet the requirements for sleep accessories when it is placed on, or fixed to, the other product.

Playpen sleep accessories that can be used alone

Playpen sleep accessories are defined in and subject to the Playpens Regulations of the CCPSA. They are described in the Playpens Regulations' definition for accessory. Playpen sleep accessories attach to, or rest on, a playpen, have sides to confine the child, and have a primary function of providing sleeping accommodation to a child.

A playpen sleep accessory that can be used alone once it is removed from the playpen may be a crib, cradle or bassinet under the Cribs, Cradles and Bassinet Regulations, when it is used alone.

Figure 1 – Example of a sleep accessory for a playpen (shown in both stand-alone mode and attached to a playpen)
Figure 1: a bassinet on the floor and on a playpen

A playpen sleep accessory that cannot be used alone when it is removed from the playpen may not be a crib, cradle or bassinet under the Cribs, Cradles and Bassinet Regulations. For example, if the sleep accessory is designed to collapse and stay collapsed when it is removed from the playpen, it no longer provides sleeping accommodation for a child.

Stroller attachments that can be used alone

Stroller or carriage attachments that can be removed from the carriage or stroller, that can be used alone, and that meet the other aspects of the definitions in the Cribs, Cradles and Bassinet Regulations may be within the scope of the regulations.

Figure 2 – Example of a stroller attachment (shown in both stand-alone mode – on a stand – and attached to a stroller)
Figure 2: a bassinet on a stand and on a stroller

A stroller attachment that cannot be used alone when it is removed from the stroller might not be a crib, cradle or bassinet under the regulations. For example, if it is designed to collapse and stay collapsed when it is removed from the stroller, it no longer provides sleeping accommodation for a child.

Primary function of providing sleeping accommodation

Cribs, cradles, bassinets, and sleep accessories are defined in part by their primary function of providing sleeping accommodation for a child. A product can have several functions, but if its primary function is to provide sleeping accommodation, then it may be a crib, cradle, bassinet or sleep accessory under the regulations if it also meets the other aspects of one of the definitions.

Factors that contribute to a product's primary function of providing sleeping accommodation for a child include the product's:

  • name
  • marketing
  • listed functions and recommended use
  • design (including appearance, construction, and materials)

These factors contribute to the reasonably foreseeable use of the product by consumers. A description of each factor is provided in Table 1 below. Additional factors may be considered by Health Canada if they contribute to a product's primary function of providing sleeping accommodation. It is important to note that a manufacturer's, importer's, seller's, or advertiser's product warnings and recommendations to provide supervision at all times when using a product, as well as statements that a product is not intended for sleep, do not necessarily place a product outside the scope of the regulations. Those warnings and recommendations against sleep are considered by Health Canada contextually with other factors.

Table 1 - Non-exhaustive list of factors that contribute to the conclusion that a product's primary function is to provide sleeping accommodation for a child.
Factor Description
Name

The product's name:

  • includes "crib," "cradle," or "bassinet"
  • makes reference to sleep, such as "sleeper" or "baby bed"
  • is synonymous with a term used for crib, cradle or bassinet, such as "cot" or "Moses basket," or a term used in another jurisdiction
Marketing, listed functions, and recommended use

The pictures on the product's packaging, labelling, instructions, or advertising show:

  • a sleeping infant or toddler
  • the product placed next to or in the caregiver's bed (implying that the product can be used for sleep)
  • sleeping animals or characters
  • other images linked to sleep, such as the night sky, stars and the moon

The product's listed functions on its packaging, and/or instructions, include sleep.

Advertisements of the product include references to sleep (including napping, which is defined as sleeping briefly, especially during the day)

The product is otherwise promoted as a sleeping environment for a child.

The product has, in the past, been promoted as a sleeping environment for a child.

The product is marketed as sleeping accommodation in jurisdictions other than Canada, if the marketing and recommended use is directed at or readily accessible to consumers in Canada.
Design (including appearance, construction, and materials)

The product's design fits the traditional design of a crib, cradle or bassinet.

The product's design does not fit the traditional design of a crib, cradle or bassinet but the product lends itself as sleeping accommodation for a young child because of its appearance, construction, materials, or other characteristics or features.

Examples of products that have a primary function of providing sleeping accommodation for a child

Health Canada considers the following product categories to have a primary function of providing sleeping accommodation for a child. Therefore, when a product in one of these categories meets the definition of crib, cradle, bassinet, or sleep accessory, then the product would fall within the scope of the regulations. Health Canada's classification of these products as a crib, cradle, or bassinet takes into account the sleeping surface area of the product. Health Canada's classification of these products as a sleep accessory depends on whether the product meets the definition of sleep accessory, which is set out in the regulations' definition of accessory.

This list is non-exhaustive and Health Canada may add product categories at any time.

Moses baskets

These are small beds for infants. They are typically made of straw or wicker and often have handles to make them portable. They are often sold with stands or stands can be purchased separately.

Figure 3 - Example of Moses basket
Figure 3: a wicker baby bed with lining and a hood

Hammocks

These are suspended or hanging beds for infants. They are usually constructed mainly of fabric or textile. They are designed to hang from stands, ceilings, beams or doorways.

Figure 4 – Example of hammock
Figure 4: a baby hammock hanging from a stand

Crib hammocks

These are suspended beds for infants that attach to a crib. They are usually constructed mainly of fabric or textile.

Figure 5 – Example of crib hammock
Figure 5: a baby hammock hanging in a crib

Inclined sleep products

These products place infants in an inclined position for sleep.

Figure 6 - Examples of inclined sleep products
Figure 6: bassinets with inclined sleep surfaces

Bed-side sleepers

A bedside sleeper generally has three closed sides and one open side. It may also have four sides with one that can be lowered so an opening is created above the mattress support. The open side is meant to be placed next to an adult bed, often with the bed-side sleeper physically attached to the adult bed with the use of ties or cords.

Figure 7 - Example of bedside sleeper
Figure 7: a baby bed on legs next to an adult bed

Products for co-sleeping

These are small beds for infants designed to be placed in the caregiver's bed. They are often promoted as a means of safe bed-sharing. They may have built-in sleep positioners.

Figure 8 - Example of co-sleeping product
Figure 8: a baby bed in an adult bed

Baby nests/baby loungers

These are small beds for infants that are constructed much like a cushion. They typically have a quilted, cushioned, or fabric panel sleep surface that is surrounded by raised cushion sides (often bolster-type cushion sides).

Figure 9 – Example of baby nest/baby lounger
Figure 9: a cushion-like baby bed

Playpens

Playpens are regulated under the Playpens Regulations. A product that meets the definition of both a playpen and either a crib, cradle or bassinet must meet the applicable requirements in both the Cribs, Cradles and Bassinets Regulations and the Playpens Regulations. For example, some cribs or playpens would be required to have the more stringent warning statement concerning supervision, that is in the Playpens Regulations:

"Do not leave a child unattended in this playpen."

Quick reference overview of crib, cradle, bassinet, and sleep accessory characteristics for product classification

Table 2 compares the general characteristics of cribs, cradles, bassinets, and sleep accessories. Each of the characteristics is discussed in detail in the respective sections above in this document.

Table 2 - General overview of characteristics of cribs, cradles, bassinets, and sleep accessories
Crib Cradle Bassinet Sleep Accessory

The product has a sleeping surface area that is greater than 5500 cm2

The product has a sleeping surface area that is greater than 4000 cm2 but less than or equal to 5500 cm2

The product has a sleeping surface area that is less than or equal to 4000 cm2

The product does not have a defined sleeping surface area

The product has a primary function of providing sleeping accommodation for a child

The product has a primary function of providing sleeping accommodation for a child

The product has a primary function of providing sleeping accommodation for a child

The product has a primary function of providing sleeping accommodation for a child

The product has sides to confine the child

The product has sides to confine the child

The product has sides to confine the child

The product has sides to confine the child

The product can be used alone, or both alone and as an accessory

The product can be used alone, or both alone and as an accessory

The product can be used alone, or both alone and as an accessory

The product is designed or advertised to be used with a crib, cradle or bassinet

The product can be placed on or fixed to the crib, cradle or bassinet

The product is for children who cannot climb out or who have reached a height of more than 90 cm

The product is for children who cannot push up on hands and knees or who have reached the manufacturer's recommended weight limit

The product is for children who cannot roll over or who have reached the manufacturer's recommended weight limit

The product is for children who cannot roll over or who have reached the manufacturer's recommended weight limit

Information resources

For more information visit the resources below or contact a Health Canada consumer product safety office via email cps-spc@hc-sc.gc.ca or telephone at 1-866-662-0666 (toll-free within Canada and the United States).

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