SAFEGUARDS | Toys & Juvenile Products NO. 107/17

SafeGuardS crayons

The EU has recently launched a public consultation for a proposal to revise the migration limits for soluble aluminum under the Toy Safety Directive. The final date for comments is September 10, 2017.

In June 2009, the European Union (EU) published Toy Safety Directive 2009/48/EC (TSD) to regulate modern-day toy safety requirements. This piece of legislation includes, among other things, specific requirements for nineteen soluble substances (section 13 to Part III of Annex II). Since its publication, the migration limits have been strengthened for barium [1], cadmium [2] and lead [3]. The strengthened limits for soluble lead will become effective on October 28, 2017.

On July 5, 2017, the Scientific Committee on Health, Environment and Emerging Risks (SCHEER) adopted their preliminary opinion [4] on the migration of aluminum in toys. This opinion, based on the most recent set of data relating to tolerable intake levels for aluminum, would strengthen the existing migration limits for aluminum by approximately 2.5-fold in each of the three toy material categories.

The European Commission and SCHEER have recently announced a public consultation [5] on this preliminary opinion. According to the announcement, written comments on this opinion must be submitted by September 10, 2017, for future considerations.

Highlights of the preliminary opinion on aluminum migration and its comparison with the TSD are summarized in Table 1.

Migration Limit for Aluminum
Toy Material

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

Category II
(Liquid or Sticky)

Category III

TSD (In force) 5,625 mg/kg 1,406 mg/kg 70,000 mg/kg
Preliminary opinion from SCHEER 2,250 mg/kg 560 mg/kg 28,130 mg/kg
Strengthened by 2.5-fold 2.5-fold 2.5-fold


Toy Material Category Toy material Example
I Dry, brittle, powder-like or pliable
  • Chalk, compressed paint tablets, crayons, magic sand, modelling compounds, plaster of Paris and plasticine.
  • Oven hardened PVC modelling compounds and bouncing putties.
II Liquid or sticky 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 sponge.

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

For enquiries, please contact:

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

Stay on top of regulatory changes within your industry: subscribe to SafeGuardS!

Read more articles for the Consumer Goods and Retail industry

© SGS Group Management SA - 2017 - All rights reserved - SGS is a registered trademark of SGS Group Management SA. This is a publication of SGS, except for 3rd parties’ contents submitted or licensed for use by SGS. SGS neither endorses nor disapproves said 3rd parties contents. This publication is intended to provide technical information and shall not be considered an exhaustive treatment of any subject treated. It is strictly educational and does not replace any legal requirements or applicable regulations. It is not intended to constitute consulting or professional advice. The information contained herein is provided “as is” and SGS does not warrant that it will be error-free or will meet any particular criteria of performance or quality. Do not quote or refer any information herein without SGS’s prior written consent.