SAFEGUARDS | Toys & Juvenile Products NO. 149/17

SafeGuardS Girl playing with play dough

The EU is proposing to strengthen the migration limit for chromium (VI) in scraped-off toy materials. If approved, the new restrictions could become effective in Q3 2019.

On September 6, 2017, the World Trade Organization (WTO) circulated a notification announcing a draft regulation from the European Union (EU) to strengthen the migration limit for chromium (VI) in scraped-off toy materials by approximately 4-fold. The draft Directive, attached to WTO document No. 17-4740 [1], also retains the existing migration limits for chromium (VI) in dry, brittle, powder-like or pliable toy materials and liquid or sticky toy materials.

According to the draft Directive, the European Committee for Standardization (CEN, Comité Européen de Normalisation) is reviewing EN 71-3, with a view to improve the detection of chromium (VI) to allow a reliable measurement for this substance at concentrations down to 0.0025 mg/kg. This revised method is expected to be available soon.

The new draft Directive is expected to be adopted in Q1 2018 and the provisions will take effect 18 months after publication in the Official Journal; Q3 2019.

Highlights of chromium (VI) migration limits falling under Directive 2009/48/EC, the so-called Toy Safety Directive (TSD), and the draft Directive under WTO document 17-4740 are summarized in the table below.

Migration Limit for Chromium (VI) in Toy Material (mg/kg)
Category I
(Dry, brittle, powder-like or pliable)
Category II
(Liquid or sticky)
Category III
Effective Date
TSD 0.02 0.005 0.2 July 2013
Draft Directive 0.02 0.005 0.053 Q3 2019
Strengthened by approximately -- -- 4-fold


Category Toy Material Example
I Dry, brittle, powder-like or pliable
  • Chalk, compressed paint tablets, crayons, plaster of Paris, magic sand, modeling compounds and plasticine
  • Oven hardened PVC modeling 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 bone, leather and natural sponges


Stakeholders are advised to comply with the latest requirements for the Toy Safety Directive (TSD) for the EU market.

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

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