CEN has published the 2019 version of EN 71-3 for the migration of certain elements in toys. Conflicting national standards are to be withdrawn by October 2019.

SAFEGUARDS | Toys & Juvenile Products NO. 062/19

SafeGuardS orig train toys

In May 2018, the European Union (EU) strengthened the migration limit for chromium (VI) in scraped-off toy materials (category III toy materials) approximately four-fold under Directive (EU) 2018/725, amending Toy Safety Directive 2009/48/EC (TSD) (Safeguard 69/18). This new limit will become effective on November 18, 2019.

In April 2019, the European Committee for Standardization (Comité Européen de Normalisation, CEN) published EN 71-3:2019, the new toy safety standard for the migration of 19 elements. This new standard contains substantial technical changes when compared to its previous version, EN 71-3:2013+A3:2018. These include:

  • Adapting the new legal migration limit for chromium (VI) for category III toy materials
  • Revising sampling and sample preparation procedures, including those for dewaxing and pH control
  • The use of sieving is no longer required
  • Revising calculation methods, including those for chromium (III)
  • Revising test methods for the stabilization of migration solutions, general elements and organic tin
  • Replacing test method for chromium (III) and chromium (VI) by test method for chromium (VI) which is capable of determining chromium (VI) at the limit values for all material categories
  • Changing Annex G from ‘informative’ to ‘normative’ and expanding the list of organic tin compounds from 10 to 11 by including dimethyl tin (DMT)

Interestingly, the informative section of the standard provides estimates of relative reproducibility derived from data obtained in an interlaboratory study.

It is also important to note that the new standard indicates that the detection of chromium (VI) using Ion Chromatography (IC) with post-column derivatization and ultraviolet-visible spectroscopy (UV/VIS) is suitable for category III toy materials.

According to EN 71-3:2019, this standard will be given the status of a national standard by October 2019 and conflicting standards are to be withdrawn by this date at the very latest. This standard is expected to be harmonized under the TSD upon official acceptance by the European Commission (EC) and by publication in the Official Journal of the EU (OJEU).

Highlights of the changes for chromium (VI) migration limits between EN 71-3:2013+A3:2018 and EN 71-3:2019 are summarized in Table 1.

  Toy Material
Migration Limit for Chromium (VI) (mg/kg) 
Standard Dry, brittle, powder-like or pliable
(Category I)
Liquid or Sticky
(Category II)
(Category III)
EN 71-3:2013+A3:2018* 0.02 0.005  0.2 
EN 71-3:2019**
0.02 0.005 0.2/0.053*** 
* Cited in OJEU for presumption of conformity with the TSD
** Expected to be cited in the OJEU for presumption of the conformity with the TSD
*** The strengthened limit of 0.053 mg/kg was amended by Directive (EU) 2018/725 and applies from November 18, 2019 

Table 1


Toy Material 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 slime
III  Scraped-off 
  • ­Ceramics, glass, metals & metal alloys, textiles and wood
  • Elastomers, leatherettes, polymers and surface coating materials
  • Other materials such as bone, leather and natural sponge

Table 2

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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