PPAI Petitions Health Canada On CCPSA Writing Instrument Exemption


On April 16, PPAI reached out to Health Canada to support a recent petition by the Writing Instrument Manufacturers Association (WIMA) requesting the exclusion of general purpose ballpoint pens from the Canada Consumer Product Safety Act (CCPSA).

PPAI members who manufacture ballpoint pens are concerned that the regulatory proposal has the potential to eliminate ballpoint pens from major segments of the market. Writing instruments represent 9 percent ($1.5 billion) of the industry’s sales. Extending the domain of the CCPSA’s Consumer Products Containing Lead (Contact with Mouth) Regulations to include “products intended for use in play or learning by children aged 3-13” has the potential to include many ballpoint pens. PPAI and WIMA are requesting a specific exemption be created within the regulation for ballpoint pens, or that written policies or guidelines be drafted to provide that pens not be considered by Health Canada as to fall within the legislation.

A similar situation was encountered in legislation in the United States. The solution adopted is often referred to as the “WIMA Rule,” with CPSC comments indicating that ball point pens are typically general use items, and thus exempt from testing associated with children’s products.  PPAI and WIMA are seeking a similar or equivalent approach be adopted by Health Canada. This makes sense, not only inherently, but also so as to harmonize the Canadian and U.S. systems.

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