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SAFEGUARDS | Toys & Juvenile Products NO. 063/17

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Turkish Toy Safety Regulations have been amended to include permitted uses of nickel in certain toy applications and the restriction of three flame retardants, Bisphenol A (BPA), formamide and four preservatives in certain toys. The effective dates are substance dependent and started on April 4, 2017.

In October 2016, we [1] informed you that Turkey had published Toy Safety Regulations to meet modern day toy safety requirements. That piece of landmark legislation was essentially adopted from Directive 2009/48/EC [2], the so-called European Toy Safety Directive (TSD).

On April 1, 2017, Turkey published an amendment to its Toy Safety Regulations under Regulations Number 30025 [3] (Regulations 2017/30025) in the Resmi Gazette, the Official Gazette of the Republic of Turkey. This amendment contains, among others, several important changes:

  • Permitting the use of nickel, a carcinogenic category 2 substance, in toys or toy components made of stainless steel, and toy components which are intended to conduct an electric current. This revision is now consistent with Appendix A to Annex II of the TSD
  • Recognizing both European Standards (EN) and their corresponding Turkish Standards (TS) for presumption of conformity with the Toy Safety Regulations. The list of corresponding Turkish Standards is under Notification 30025 of April 1, 2017 [4] (Notification 2017/30025) and entered into force on April 4, 2017
  • Restricting nine chemicals (Items 1 to 9, Table 1) in toys intended for children under 36 months or other toys intended to be placed in the mouth. This modification is now consistent with Appendix C to Annex II of the TSD 

The technical requirements for these nine chemicals (Table 1) are essentially identical to those for Appendix C to Annex II of the TSD:

  • Directives 2014/79/EU for TCEP, TCPP and TDCP & 2014/81/EU for BPA [5]
  • Directives (EU) 2015/2115 for formamide, 2015/2116 for BIT & 2015/2117 for CMI:MI (3:1), CMI and MI [6]

There are three effective dates for these nine chemicals:

  • April 4, 2017 for TCEP, TCPP, TDCP and BPA
  • May 24, 2017 for formamide and BIT
  • November 24, 2017 for CMI:MI (3:1), CMI and MI

Highlights of Regulations 2017/30025 amending Part C to Annex 2 of the Turkish Toy Safety Regulations are summarized in Table 1.

Regulations 2017/30025 amending Part C to Annex 2 of the Toy Safety Regulations under Regulations 2016/29847
Item Substance Scope Requirement, unless otherwise stated, is total content [scope of toy material] Effective date
1 TCEP
  • Toys intended for children under 36 months
  • Other toys intended to be placed in the mouth
≤ 5 mg/kg April 4, 2017
2 TCPP ≤ 5 mg/kg
3 TDCP ≤ 5 mg/kg
4 BPA ≤ 0.1 mg/kg (migration) using TS EN 71 Parts 10-11
5 Formamide

≤ 200 mg/kg otherwise 

≤ 20 ug/m³ (emission for a maximum of 28 days) [foams]

May 24, 2017
6 BIT ≤ 5 mg/kg using TS EN 71 Parts 10-11 [aqueous]
7 CMI:MI (3:1) ≤ 1 mg/kg [aqueous] November 24, 2017
8 CMI ≤ 0.75 mg/kg [aqueous]
9 MI ≤ 0.25 mg/kg [aqueous]

Table 2 Definitions

Item Acronym Name CAS
1 TCEP Tris(2-Chloroethyl) Phosphate 115-96-8
2 TCPP Tris(2-Chloro-1-methylethyl) Phosphate 13674-84-5
3 TDCP Tris[2-Chloro-1-(chloromethyl)ethyl] Phosphate 13674-87-8
4 BPA Bisphenol A 80-05-7
5 ---- Formamide 75-12-7
6 BIT 1,2-Benzisothiazol- 3(2H)-one 2634-33-5
7 CMI:MI (3:1) 5-Chloro-2-methylisothiazolin-3(2H)-one (CMI) and 2-methylisothiazolin-3(2H)-one (MI) (3:1) 55965-84-9
8 CMI 5-Chloro-2-methylisothiazolin-3(2H)-one 26172-55-4
9 MI 2-Methylisothiazolin-3(2H)-one 2682-20-4

SGS offers a wide range of services to ensure that your products comply with the EU Toy Safety Directive. We offer training, safety/risk assessment, technical documentation check, labelling review, testing according to harmonised standards, SVHC screening, inspections and audits. With the largest global network of toy experts and testing facilities around the world - around 20 toy labs worldwide including 3 EU Notified Bodies (France, Germany and Netherlands), SGS is the partner to trust. Please do not hesitate to contact us for further information or visit our website.

For enquiries, please contact:

Hingwo Tsang
Global Hardlines Information and Innovation Manager
t: +852 2774 7420

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