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More Safety for Toys: New Limits for Aluminum Migration and Formaldehyde

To protect our youngest consumers as effectively as possible, the EU Commission has once again proposed more stringent limits for substances in toys, which are potentially hazardous to health. This includes, among other things, aluminum. Legal restrictions already apply to the migration of the metal from toy materials. Based on a new classification by the Scientific Committee on Health, Environmental and Emerging Risks (SCHEER), however, changes are now planned. According to the planned regulation, which could take effect at the end of 2020, the previous migration limits in Part III of the Annex II to the Toy Directive 2009/48/EC will decrease as follows:

MaterialCurrent LimitProposed Limit
in dry, brittle, powdery, or pliable toy materials5,625 mg/kg5,625 mg/kg 2,250 mg/kg
in liquid or adhesive toy materials1,406 mg/kg560 mg/kg
in scraped-off toy materials70,000 mg/kg28,130 mg/kg

The chemical compound of formaldehyde is classified as a category 1B carcinogenic substance. It is used, among other things, in polymer materials, in adhesive components, in resin bonded wood (for example, MDF, HDF boards) as a preservative and in the manufacture of textiles, leather, and paper. In December 2018, the EU commission published a draft amending the Toy Directive 2009/48/EC. According to which, limits for formaldehyde are to be adopted in Appendix II of Annex C to the Directive. The new regulation applies to toys intended for small children under three years of age as well as other toys intended to be put in the mouth.

MaterialProposed Limit
Polymers1.5 mg/L (migration)
Resin-bonded wood0.1 ml/m³ (emission)
Textile30 mg/kg (total concentration)
Leather30 mg/kg (total concentration)
Paper30 mg/kg (total concentration)
Aqueous material10 mg/kg (total concentration)

The new planned regulations are based on the requirements of EN 71-9, but the limits for polymers and aqueous materials have been set somewhat lower. For wood materials, testing no longer has to be conducted in accordance with EN 717-3 (flask method), but rather in accordance with EN 717-1 (test chamber method) in the future. The draft is set to be adopted in the second quarter of 2019; the new regulation could take effect at the end of 2020.

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