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Blog/Compliance

The 2023 workplace mandate, explained

2026-07-187 min read
Facility service cart with clipboard, supplies and paper stock in a washroom

Since December 15, 2023, federally regulated employers must provide free menstrual products in every workplace washroom, men's and universal rooms included, plus a covered disposal receptacle. Here's what that means operationally.

Key takeaways

  • Since December 2023, federally regulated employers must provide free menstrual products in every toilet room plus covered disposal in every stall.
  • Coin-operated dispensers do not comply, existing units need free-vend conversion.
  • Provincial rules vary but move in one direction; early voluntary adoption beats a deadline retrofit.
  • Compliance needs an audit trail: service logs proving products were available, not just installed.

The rule sits in the Canada Occupational Health and Safety Regulations under the Canada Labour Code. It covers federally regulated employers: banks, telecoms, airlines, interprovincial transport, federal Crown corporations and the federal public service, roughly 6% of Canadian workers, but a large share of major office tenants.

The operational checklist is short: products available at no cost in every washroom; a covered receptacle for disposal in each; and the sense to keep both stocked and serviced, because an empty dispenser fails the requirement as surely as no dispenser.

Coin units don't comply. Free of charge means free at the point of use. Converting sound coin units to free-vend is usually cheaper than replacement. A kit swap, not a rebuild.

Every washroom means every washroom. The most common gap we find on audits is men's and universal rooms. The requirement includes them, and so should your placement plan.

Provincially regulated employers aren't covered by this rule, but it has become the benchmark employees cite. Our province pages break down what applies where you are.

Who the federal rule actually covers

The December 2023 amendment to the Canada Labour Code covers federally regulated employers — banks, telecommunications, interprovincial transportation, airlines, marine shipping, federal Crown corporations and the federal public service. That is roughly six per cent of Canadian employees, but the list includes some of the country's largest washroom portfolios: every bank branch, every airport terminal under federal jurisdiction, every rail yard.

The requirement itself is specific: menstrual products, tampons and pads, provided free of charge in every toilet room, regardless of the gender marking on the door, plus a covered disposal container in each toilet stall. An employer who provides products in the women's washroom only has not met the requirement.

What compliance looks like in practice

  • Coverage: every toilet room, including single-occupancy and accessible washrooms. Not just multi-stall women's rooms.
  • Availability: products stocked continuously, not a starter box that runs out. An empty dispenser is a compliance gap, not a supply hiccup.
  • Disposal: a covered container in each stall, serviced on a schedule that prevents overflow.
  • No cost recovery: coin-operated dispensers do not comply; existing coin units need free-vend conversion.

Where provincially regulated employers stand

Most Canadian workplaces fall under provincial jurisdiction, and the provinces are moving at different speeds. British Columbia amended its regulation ahead of the federal change; Ontario has requirements in specific sectors; several provinces have active consultations. The direction of travel is one way. No jurisdiction is loosening washroom requirements. Which is why many provincially regulated employers are adopting the federal standard voluntarily now rather than retrofitting under deadline later.

Adopting the federal standard before your province requires it costs a fraction of a rushed compliance retrofit, and employees notice the difference immediately.

The audit trail employers underestimate

The mandate's quiet requirement is proof. If a labour affairs officer asks, an employer needs to show products were actually available. Not just that dispensers were installed. A service log showing scheduled restocking visits, fill levels and dates is the difference between a policy on paper and demonstrated compliance. Employers running informal top-up-when-someone-notices arrangements have no such record, and reconstructing one after a complaint is not possible.

Budgeting the rollout

The cost structure surprises most employers on the low side. Product cost for an office population runs one to three dollars per employee per year. Dispensers are a one-time capital item, commercial twin-column units land in the low hundreds each installed, and conversions of existing coin units cost less. Disposal service is priced per bin per visit and scales with the washroom count, not the headcount. For a two-hundred-person federally regulated office, the full program, dispensers in every toilet room, covered bins in every stall, scheduled service, typically prices below a single catered staff lunch per month.

The rollout sequence that avoids rework: washroom audit first (count toilet rooms and stalls. The number is always higher than the facilities plan says, because single-occupancy and accessible rooms get missed), then dispenser placement and conversion in one visit per building, then the service schedule starts the same week. Retrofitting disposal after the dispensers are in means opening every washroom twice.

One warning from real rollouts: starter-kit compliance fails within a quarter. An employer who installs dispensers and hands facilities a case of product has met the requirement for exactly as long as the case lasts. The mandate's availability requirement is continuous, and continuous availability is a route and a schedule, not a purchase order.

Frequently asked

Yes, if the tenant is a federally regulated employer. The obligation follows the employer, not the building.

Dated service records per washroom, stock levels, receptacle service, technician sign-off. That's what an inspection asks for.

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