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SAFEGUARDS | Toys & Juvenile Products NO. 062/17

Girl playing with wooden toys

The EU has recently strengthened the migration of lead in toys by approximately 7-fold. The new restrictions will become effective on October 28, 2018.

In September 2016, we [1] informed you that the World Trade Organization (WTO) had circulated a notification announcing a draft regulation from the European Union (EU) to retain the proposed migration limits for lead in toys. This draft regulation strengthens each of the three toy material categories by approximately 7-fold and was adopted by the Council of the EU in Q1 of 2017 [2].

On April 27, 2017, Directive (EU) 2017/738 [3] was published in the Official Journal of the European Union (OJEU). This new piece of legislation amends Annex II of Directive 2009/48/EC, the so-called Toy Safety Directive (TSD), as an adaptation to technical progress (ATP).

The new restrictions will become effective on October 28, 2018.

Highlights of lead migration limits falling under the new Directive and the TSD are summarized in Table 1.

Migration Limit for Lead (mg/kg)
Toy Material
Category I (Dry, brittle, powder
like or pliable)
Category II (Liquid or sticky) Category III (Scraped-off) Effective Date
TSD 13.5 3.4 160 Jul, 2013
(EU) 2017/738 amending the TSD
2.0 0.5 23 Oct 28, 2018

Table 2.Definitions

Toy Material Category Toy material Example
I Dry, brittle, powder-like or pliable
  • Chalk, compressed paint tablets, crayons, plaster of Paris, magic sand, modelling compounds and plasticine.
  • Oven hardened PVC modelling compounds and bouncing putties.
II Liquid or sticky toy Bubble solutions, finger paints, liquid adhesives, poster paints and slimes
III Scraped-off
  • Ceramics, glass, metals and metal alloys, textiles and wood.
  • Elastomers, leatherettes, polymers and surface coating materials.
  • Other materials such as bones, leather and natural sponges.

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:

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

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