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Turkey is proposing to align its chemical requirements for toys with those in the European Union (EU). The amendment would be implemented in phases starting six months after publication in the Official Gazette

SAFEGUARDS | Toys & Juvenile Products NO. 102/19

baby playing with toy

In October 2016, Turkey published its Toy Safety Regulation (Oyuncak Güvenliği Yönetmeliği) under Number 29847 in the Resmi Gazete (Official Gazette). That piece of legislation, essentially based on the European Toy Safety Directive 2009/48/EC (TSD), was amended in April 2017 to include many of the newly added chemicals specifically for toys intended for children under 36 months or in other toys intended to be placed in the mouth under Appendix C to Annex II of the TSD (Safeguard 63/17).

In May 2019, the World Trade Organization (WTO) circulated a revised proposal from Turkey announcing its intention to amend the Toy Safety Regulation. The draft regulation, attached to WTO document number 19-3702, and notified under G/TBT/N/TUR/80/Rev. 1, would revise the nation’s Toy Safety Law to align with EU rules. The proposal contains several important changes, including the following:

  • Strengthening the migration limit for chromium (VI) under category III toy materials
  • Strengthening the migration limits for lead in all three categories of toy materials
  • Strengthening the migration limit for bisphenol A (BPA) in certain toys under Annex II Appendix C
  • Adding phenol requirements to certain toys under Annex II Appendix C
  • Revising the term ‘aquatic toy’ to ‘aqueous toy’ for better clarity in Annex II Appendix C

According to the WTO announcement, it is proposed the amendment will be adopted on August 1, 2019. When/if accepted, the provisions would be implemented in two phases:

  • 6 months after publication in the Resmi Gazete for provisions other than chromium (VI) migration
  • 12 months after publication in the Resmi Gazete for chromium (VI) migration

Highlights of the proposal are summarized in Tables 1 (chromium (VI) and lead) and 2 (BPA and phenol)

Draft Regulation on the Amendment of Toy Safety Regulation
Part III to Annex II ‘Chemical Properties’
  Toy Material (mg/kg)
Soluble Element Dry, brittle, powder-like or pliable
(Category I)
Liquid or Sticky
(Category II)
Scraped-off
(Category III)
Chromium (VI) 0.02 (0.02*) 0.005 (0.005*) 0.053 (0.2*)
Lead 2.0 (13.5*) 0.5 (3.4*) 23 (160*)
Effective Date
  • 6 months after publication in the Resmi Gazete for lead (possibly early 2020)
  • 1 year after date of publication in the Resmi Gazete for chromium (VI) (possibly late 2020)
*Existing limit under Turkish Toy Safety Regulation, Number 29847 of October 4, 2016

Table 1

Toy Safety Regulation Number 29847 of October 4, 2016
Annex II Appendix C ‘Toys Intended for children under 36 months or in other toys intended to be placed in the mouth’
Substance Draft Regulation on the Amendment of Toy Safety Regulation Number 30025 of April 1, 2017 amending Number 29847 of October 4, 2016
BPA 0.04 mg/L migration 0.1 mg/L migration
Phenol
  • 5 mg/L migration for polymeric materials
  • 10 mg/kg content as a preservative
Not listed
Method EN 71 Parts 10 and 11 EN 71 Parts 10 and 11
Effective Date 6 months after publication in the Resmi Gazete (possibly early 2020) April 2017

Table 2

Definitions

Toy Material Category Toy material Example
I Dry, brittle, powder-like or pliable
  • Chalk, compressed paint tablets, crayons, plaster of Paris, magic sand, modelling 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

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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