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The EU is proposing to amend the migration limits for aluminum in toys. The proposed date of entry into force is late 2020.

SAFEGUARDS | Toys & Juvenile Products NO. 003/19

SafeGuardS colored crayons

In December 2018, the World Trade Organization (WTO) circulated a notification announcing a proposal from the European Union (EU) to amend its Toy Safety Directive 2009/48/EC (TSD). The draft Directive [1], attached to WTO document number 18-7767 and notified under G/TBT/N/EU/626 [2], would strengthen the migration limits for aluminum 2.5-fold in all three categories of toy materials.

This latest proposal stems from the preliminary opinion by the Scientific Committee on Health, Environment and Emerging Risks (SCHEER) (Safeguard 107/17 [3]), and their adoption of the final opinion in September 2017.

According to the WTO notification, the draft Directive is proposed to be adopted in Q2 of 2019 and the proposed date of entry into force is late 2020.

Highlights of the proposal are summarized in Table 1.

Point 13 under Part III of Annex II to Directive 2009/48/EC
Migration Limit for Aluminum (mg/kg)
Toy Material

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

Category II
(Liquid or Sticky)
Category III
(Scraped-Off)
TSD 5,625 1,406 70,000
Draft Directive under WTO Document
Number 18-7767
2,250 560 28,130

Table 1

Definitions and examples of toy materials

Toy material Example

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 modelling compounds and bouncing putties

Category II:

Liquid or sticky toy

Bubble solutions, finger paints, liquid adhesives, poster paints and slimes

Category 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 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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