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UK Proposes to Strengthen Chemical Safety in Toys for Great Britain

SafeGuardSToys and Juvenile Products26 Apr, 2022

The UK has informed the WTO of its intention to revise its legislation on toy safety for GB. The new law would be implemented in phases, starting October 15, 2022.

On April 13, 2022, the World Trade Organization (WTO) announced a draft regulation from the United Kingdom (UK) on its intention to revise the Toys (Safety) Regulations 2011 (UK SI 2011 No. 1881, ‘the Toys Regulations’) and the Cosmetics Regulation 1223/2009, as applicable in Great Britain (GB – England, Wales and Scotland).

The draft regulation, attached to WTO document number 22-3025 and notified under G/TBT/N/GBR/47, contains several important changes to chemical requirements for toys. It:

  • Expands the number of allergenic fragrances from 55 entries to 58 entries by adding atranol, chloroatranol and methyl heptane carbonate (Schedule 2, Part 3, Point 11). These allergenic fragrances are prohibited, but their presence is allowed if they are technically unavoidable under good manufacturing practice (GMP) and each fragrance is no more than 100 mg/kg
  • Strengthens the migration of aluminum 2.5-fold for all three categories of toy materials (Schedule 2, Part 3, Point 13, see Table 1 below) 
  • Restricts aniline and formaldehyde in certain toys/toy materials (Schedule 2, Appendix C, see Table 2 below)

These further align Great Britain’s chemical requirements on toy safety with those in Directive 2009/48/EC on (Toy Safety Directive, TSD) in the European Union. 

According to the draft regulation, there are two important effective dates for toys:

  • October 15, 2022, for provisions other than those specified below
  • December 15, 2022, for the migration of aluminum as well as requirements for aniline and formaldehyde

Notwithstanding the provision for the three new allergenic fragrances, toys that are made available on the market before October 15, 2022, can be made available on the market until December 15, 2022.

Notwithstanding the provisions for aniline and formaldehyde, toys that are made available on the market prior to December 15, 2022, can be made available on the market until December 15, 2023.

Highlights of the proposed requirements for aluminum, aniline and formaldehyde are in Tables 1 and 2.

Point 13 under Part 3 of Schedule 2
Migration for Aluminum

Toy Material


Category I
(Dry, brittle, powder like or pliable)

Category II
(Liquid or sticky)

Category III

Effective Date

Toy Regulations

5,625 mg/kg

1,406 mg/kg


In force

Draft Toys and Cosmetic Products (Restriction of Chemical Substances) Regulations 2022

2,250 mg/kg

560 mg/kg 

28,130 mg/kg

Proposed December 15, 20


Table 1

WTO Document Number 22-3025, April 13, 2022
Draft Toys and Cosmetic Products (Restriction of Chemical Substances) Regulations 2022 amending The Toys (Safety) Regulations, Schedule 2, Appendix C ‘Toys intended for children under 36 months or other toys intended to be placed in the mouth’


Unless otherwise Stated, Requirement is Total Content of Substance

Proposed Effective Date


  • ≤ 30 mg/kg after reductive cleavage (textile and leather materials)

  • ≤ 30 mg/kg after reductive cleavage (finger paints)

  • ≤ 10 mg/kg free aniline (finger paints)

December 15, 2022


  • ≤ 1.5 mg/L (migration, polymeric)

  • ≤ 0.1 ml/m³ (emission, resin-bonded wood)

  • ≤ 30 mg/kg (textile, leather and paper materials)

  • ≤ 10 mg/kg (water-based)

Table 2

Definitions and examples of toy materials

Toy Category


Category I:
Dry, brittle, powder-like or pliable 

  • Chalk, compressed paint tablets, crayons, plaster of Paris, magic sand, modelling compounds and plasticine

  • Oven hardened PVC modeling compounds and bouncing putties

Category II:
Liquid or sticky toy 

  • Bubble solutions, finger paints, liquid adhesives, poster paints and slime

Category III:

  • 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

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