The EU has strengthened the migration limit for aluminum in all three categories of toy materials 2.5-fold. The new restrictions will become effective on May 20, 2021.

SAFEGUARDS | Toys & Juvenile ProductsNO. 166/19


In 2018, the European Union (EU) informed the World Trade Organization (WTO) of its intention to amend the migration limits for aluminum in toys falling under Directive 2009/48/EC, the Toy Safety Directive (TSD, SafeGuardS 3/19).

On November 19, 2019, the EU published Directive (EU) 2019/1922 to strengthen aluminum migration in all three categories of toy materials as part of its technical and scientific developments under the TSD. Since the publication of TSD in June 2009, migration limits have been revised for all three categories of toy materials for barium, cadmium and lead, and category III toy materials for chromium (VI) – the latter became effective on November 18, 2019 (SafeGuardS 69/18). 

Highlights of aluminum migration limits falling under Directive (EU) 2019/1922 and a comparison with the TSD are summarized in Table 1.

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

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

 Category II
(Liquid or Sticky)

Category III 

 TSD  5,625 mg/kg  1,406 mg/kg  70,000 mg/kg  In force
 Directive 2019/1922 amending TSD  2,250 mg/kg  560 mg/kg  28,130 mg/kg  May 20, 2021
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:
  • 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

The EN 71-3:2019 standard (Migration of certain elements) does not include the new aluminum limits. It will need to be amended in order to include the new limits. Please note that irrespective of the EN 71-3 amendment, the new limits must be respected by May 20 2021.

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
Tel: (+852) 2774 7420

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