The EU has strengthened the migration limit for aluminum in all three categories of toy materials 2.5-fold. The new restrictions will become effective on May 20, 2021.
In 2018, the European Union (EU) informed the World Trade Organization (WTO) of its intention to amend the migration limits for aluminum in toys falling under Directive 2009/48/EC, the Toy Safety Directive (TSD, SafeGuardS 3/19).
On November 19, 2019, the EU published Directive (EU) 2019/1922 to strengthen aluminum migration in all three categories of toy materials as part of its technical and scientific developments under the TSD. Since the publication of TSD in June 2009, migration limits have been revised for all three categories of toy materials for barium, cadmium and lead, and category III toy materials for chromium (VI) - the latter became effective on November 18, 2019 (SafeGuardS 69/18).
Highlights of aluminum migration limits falling under Directive (EU) 2019/1922 and a comparison with the TSD are summarized in Table 1.
Point 13 under Part III of Annex II to Directive 2009/48/EC (TSD) Migration Limit for Aluminum
| Toy Material | Toy Material | Toy Material | Toy Material | |
| Category I (Dry, brittle, powder like or pliable) | Category II (Liquid or Sticky) | Category III (Scraped-Off) | Effective Date | |
| TSD | 5,625 mg/kg | 1,406 mg/kg | 70,000 mg/kg | In force |
| Directive 2019/1922 amending TSD | 2,250 mg/kg | 560 mg/kg | 28,130 mg/kg | May 20, 2021 |
Table 1
Definitions and Examples of Toy Materials
| Toy Material | Example |
|---|---|
| Category I: Dry, brittle, powder-like or pliable |
|
| Category II: Liquid or sticky toy | Bubble solutions, finger paints, liquid adhesives, poster paints and slimes |
| Category III: Scraped-off |
|
The EN 71-3:2019 standard (Migration of certain elements) does not include the new aluminum limits. It will need to be amended in order to include the new limits. Please note that irrespective of the EN 71-3 amendment, the new limits must be respected by May 20 2021.
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 harmonized 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.
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