Hotel Cribs on Canadian Projects: What the Cribs, Cradles and Bassinets Regulations (SOR/2016-152) Say About the Product, the Label and the Importer’s Records
Definitions, construction numbers, labels and the importer’s records, read from the text of SOR/2016-152
A hotel, an apartment-hotel or a student-accommodation project that supplies cribs for guests is buying a product with its own Canadian regulation. The Cribs, Cradles and Bassinets Regulations (SOR/2016-152) fix the construction of the product to the millimetre, set what has to be printed on it in English and French, and put a records duty on the “responsible person”, who for an imported product is the importer.
This article reads the full text of the Regulations on the Justice Laws website (SOR/2016-152), which states that the Regulations are current to 30 September 2026 and were last amended on 19 December 2022; we read it on 27 October 2026. FBM Furniture works with companies only: Developers · General Contractors · Builders · Commercial Project Owners · Interior Design & Construction Companies · FF&E Solution Providers. The Regulations are made under section 37 of the Canada Consumer Product Safety Act. We did not read the Act here and do not decide whether a given hotel or accommodation order falls within it; counsel confirms that. We also did not read the test schedules, the two standards the text cites, the warning wording for cradles, bassinets, accessories and stands, or Health Canada guidance. For the US counterpart see our reading of 16 CFR Parts 1219, 1220 and 1130.
Three products defined by sleeping area, and who the responsible person is
Section 1 defines the three products by the same two tests. Each has, as its primary function, sleeping accommodation for a child, with sides to confine the child, and each can be used alone or as an accessory. What separates them is the sleeping surface:
| Product | Sleeping surface area in the text | Other characteristics in the text |
|---|---|---|
| Bassinet | 4,000 cm² or less | Primary function is sleeping accommodation for a child, with sides to confine the child; can be used alone, or both alone and as an accessory |
| Cradle | More than 4,000 cm² and up to 5,500 cm² | Same |
| Crib | More than 5,500 cm² | Same |
The Regulations also cover accessories, which include change table accessories and sleep accessories designed or advertised to be used with a crib, cradle or bassinet, and stands, which are designed or advertised to elevate one. Section 1 defines the responsible person in two limbs: the manufacturer, for a product manufactured in Canada for commercial purposes, and “the importer, in the case of a crib, cradle, bassinet, accessory or stand that is imported for commercial purposes”. For a project that imports its cribs from China, the duties below sit with the importer.
Construction rules for every product: sections 2 to 22
Sections 2 to 22 apply to cribs, cradles, bassinets, accessories and stands, with some provisions limited to particular products. Section 2 requires every key structural component, meaning a side, mattress support, stabilizing bar, structural cover or stand, to be made so that “it can only be assembled correctly one way according to the manufacturer’s instructions”, or to carry permanent markings that show how to assemble it. The rest are in this table:
| Section | Subject | What the text sets |
|---|---|---|
| 4 and 5 | Angle | The mattress support does not exceed 7° from the horizontal; a product that rocks or swings does not go beyond 20° and rests at no more than 7° |
| 7 | Sides | Only stationary sides and access sides |
| 10 | Openings | No completely bounded opening through which a block of 60 mm × 100 mm × 100 mm can pass in any orientation, tested under Schedule 2 |
| 12 | Mesh | Textile or pliable mesh in the sides or bottom does not tear or detach under Schedule 3, and its openings stop the hemispherical probe tip of Schedule 4 |
| 13 | Flammability | Textile or pliable parts have a flame spread time greater than seven seconds, tested to CAN/CGSB-4.2 No. 27.5 |
| 15 to 17 | Exposed parts | Hard parts free from cracks and burrs and smooth; metal smooth; cut metal tubing smooth or capped with a cap that stays on at 90 N; bolt ends above the mattress support covered with an acorn nut or equivalent; small parts held at 90 N; slots and notches meet the 5.33 mm and 9.53 mm probe rule |
| 18 | Restraints | No child restraint system |
| 19 and 20 | Cords and straps | A cord attached at one end is not longer than 188 mm when stretched with 22 N; no loops that pass the small head probe under Schedule 7 |
| 22 | Mattress | No thicker than 150 mm for a crib mattress and 38 mm for a cradle, bassinet or sleep accessory mattress; no gap over 30 mm to any side; lock-stitched |
The numbers come with test methods in the schedules, which we did not read. A catalogue photograph does not show these dimensions; a test report against the Regulations does, and it is the document to ask for. Section 9 also deals with posts: a post may not extend more than 1.5 mm, measured within 76 mm of its outermost surface, above the lowest point on the upper surface of the higher of the sides that adjoin it, and may extend more than 406 mm only if the product meets the cut-out test in section 7.9 of the ASTM International standard F1169.
Additional rules for cribs: sections 23 to 30
Sections 23 to 30 add rules that apply to cribs only, including the heights that matter for a child climbing out and the latches that matter for an adult closing a side:
| Section | Subject | What the text sets |
|---|---|---|
| 23 and 24 | Strength | No damage, latches that stay engaged and fasteners that stay tight under Schedule 8 sections 1 to 3; mattress support holds under Schedule 9 section 1 |
| 25 | Side height, mattress support lowest | Side upper surface at least 660 mm above the mattress support; stationary part of an access side at least 510 mm |
| 26 | Side height, mattress support highest | Upper surface at least 230 mm above the mattress support for a stationary side, and for the stationary part of an access side |
| 27 and 28 | Latches | Access side and folding mechanisms latch automatically and need two separate, deliberate and simultaneous actions to release |
| 29 | Slats | No slat completely breaks or separates at either end under Schedule 10 |
| 30 | Toeholds | No horizontal slat, rail, projection or ledge usable as a toehold between more than 76 mm and less than 510 mm above the mattress support; one 10 mm deep or more is deemed capable of being a toehold |
Section 27 uses the words that a procurement team can check on a sample: the movable part of an access side must be held in each adjustment position by a mechanism that latches or locks automatically and “requires two separate, deliberate and simultaneous actions to unlatch or unlock it”. Section 30 states the toehold rule as a measured band: nothing that a child could use as a toehold between 76 mm and 510 mm above the mattress support in its lowest position.
Coatings and heavy metals: section 3
Section 3 applies to stickers, films and surface coating materials on accessible parts. It says they must not contain, when tested by a method that conforms to good laboratory practices, more than 90 mg/kg total lead; any compound of antimony, arsenic, cadmium, selenium or barium that migrates from the material above a limit of 1,000 mg/kg of the compound; or more than 10 mg/kg total mercury. Accessible part and surface coating material have the meanings in section 1 of the Surface Coating Materials Regulations. How that wider lead rule treats furniture is in our reading of SOR/2016-193 and the other Canadian lead regulations.
Planning a crib and guestroom package for a Canadian project?
Send your guestroom schedule and the model list. Our team will review them and get back to you.
Labels, instructions and warnings: sections 45 to 53
Section 47 requires the information the Regulations call for to be “displayed in English and French”, printed on the product or on a label permanently affixed to it, in contrasting colour, legible throughout the useful life of the product. Section 48 requires a standard sans-serif type. Under section 49 the signal words WARNING and MISE EN GARDE appear in boldfaced upper case type not less than 5 mm high, and all other required information appears in type not less than 2.5 mm high.
Section 50 requires the model name or model number, and a manufacture date made up of the year and either the month or the week, to appear on every crib, cradle and bassinet. Section 51 requires assembly and use information, including assembly instructions and a parts list where the product is sold not fully assembled, folding instructions for a folding product, instructions on adjusting the mattress support height, and the mattress dimensions the manufacturer recommends. Section 45 adds an unusual rule: the information on the product, with it or in an advertisement “must not make any direct or indirect reference to the Canada Consumer Product Safety Act or these Regulations”.
Section 53 sets the warning that appears on every crib, in English and in French. It includes, among others, “Do not use this crib for a child who can climb out of it or who is taller than 90 cm.” and “Children can suffocate on soft bedding. Do not place pillows, comforters or soft mattresses in this crib.” Sections 54 to 58 add warnings by type of crib, such as one with an access side or one sold with or without a mattress, which we did not read in full.
The importer’s records: section 80
Section 80(1) says the responsible person “must keep documents that show that a crib, cradle, bassinet, accessory or stand meets the requirements of these Regulations, for a period of at least three years after the day on which it is manufactured in Canada or the day on which it is imported”. Section 80(2) requires the responsible person to give an inspector any document requested in writing “within 15 days after the day on which the request is received”. For an importer, the practical reading is that the factory’s test documents have to be in the importer’s hands, not only in the factory’s.
What to put in writing before cribs are ordered
The text turns into a short list of items to settle with the project’s compliance lead and the factory before an order is placed. Each item maps to a provision above.
- The product type by sleeping surface area, crib, cradle or bassinet, with the dimension (section 1).
- A test report against the construction rules for the exact model: opening block, slat strength, side heights, latch actions, toeholds, mesh, flammability, cords and small parts (sections 2 to 30 and the schedules).
- Lead, antimony, arsenic, cadmium, selenium, barium and mercury results for coatings, stickers and films on accessible parts, from a laboratory working to good laboratory practices (section 3).
- The English and French labels, warnings and instructions as they will appear, with the type heights and the model name or number and manufacture date (sections 47 to 53).
- The mattress supplied with the crib, with its thickness, gap to the sides and stitching (section 22).
- Who will hold the documents in Canada for at least three years, and how quickly they can be produced within 15 days (section 80).
- Whether the order is a crib, a portable folding crib or both, because section 28 applies to folding cribs.
Send the schedule and the model list together so that the package is quoted against the rooms it will sit in. For the rest of Canadian compliance for contract furniture, see our Canada compliance page and our reading of SOR/2021-148 on formaldehyde; the Act itself is read on our main site in the Canada Consumer Product Safety Act article. For how FBM Furniture works with FF&E contractors, see our page for FF&E contractors.
Frequently asked questions
What do the Canadian Cribs, Cradles and Bassinets Regulations cover?
SOR/2016-152 sets construction, labelling, information and record-keeping requirements for cribs, cradles, bassinets, their accessories and stands. A crib is a sleeping product with sides to confine the child and a sleeping surface area greater than 5,500 cm²; a cradle is greater than 4,000 and up to 5,500 cm²; a bassinet is 4,000 cm² or less.
Who is the responsible person under the Regulations?
Section 1 defines it as the manufacturer for a product made in Canada for commercial purposes and the importer for a product imported for commercial purposes.
How high must the sides of a crib be?
With the mattress support in its lowest position, section 25 requires the side upper surface to be at least 660 mm above the mattress support and the stationary part of an access side at least 510 mm; with the support in its highest position, section 26 requires at least 230 mm.
What must be printed on a crib in Canada?
Sections 47 to 53 require English and French text on the product or a permanently affixed label, the model name or number, a manufacture date as year and month or week, assembly and use information, and the section 53 warning, with signal words in boldfaced upper case type not less than 5 mm high.
How long must an importer keep the documents?
Section 80 requires the responsible person to keep documents showing that the product meets the Regulations for at least three years after the day it is manufactured in Canada or imported, and to give an inspector requested documents within 15 days of receiving the written request.
How does FBM Furniture support a hotel crib or guestroom package?
We review the brief, collect comparable quotations and manage the package for the project. For suppliers you nominate, we charge a 5% commission; for products we source for you, we quote a direct price. Our own team performs one inspection after bulk production is complete and before shipment, and your team is welcome to attend.
Planning a crib and guestroom package for a Canadian project?
Send your guestroom schedule and the model list. Our team will review them and get back to you.