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Ukraine Issues Draft Resolution on Toy Safety to Further Align with the EU

SafeGuardSToys and Juvenile ProductsSeptember 23, 2020

Ukraine has published a draft resolution on toy safety. If approved, the new law will enter into force six months from the date of publication in the Official Journal.

In 2018, Ukraine approved its 'Technical Regulations on the Safety of Toys' ('Technical Regulations') - a piece of legislation that is largely similar to Directive 2009/48/EC, the European Toy Safety Directive.

On September 15, 2020, the Ukrainian Ministry for Development of Economy, Trade and Agriculture published its 'Draft Resolution of the Cabinet of Ministers of Ukraine On Amendments to the Technical Regulations for Toy Safety' to amend and further align its Technical Regulations with those in the TSD.

This draft law contains, inter alia, several important changes. It:

  • Strengthens the migration of aluminum 2.5-fold for all three categories of toy materials
  • Strengthens the migration of chromium (VI) approximately 4-fold for category III toy materials
  • Adds three levels of requirement for formaldehyde (migration, emission and content) in toys for children under 36 months or in other toys intended to be placed in the mouth:
    • ≤ 1.5 mg/l for formaldehyde migration in polymeric materials
    • ≤ 0.1 ml/m³ for formaldehyde emission in resin-bonded wood
    • ≤ 30 mg/kg for formaldehyde content in each of textile, leather and paper materials
    • ≤ 10 mg/kg for formaldehyde content in water-based toys

Highlights of the draft resolution on aluminum and chromium (VI) migration limits and a comparison with their corresponding limits in the 'Technical Regulations' are summarized in Table 1.


Point 25 to Table 3 in Annex 2 of the 'Technical Regulations' Migration Limits for Aluminum and Chromium (VI) (Toy Material)
Soluble elementDraft Resolution to Amend 'Technical Regulations''Technical Regulations'
Aluminum2,250 mg/kg (category I) 560 mg/kg for (category II) 28,130 (category III)5,625 mg/kg (category I) 1,406 mg/kg (category II) 70, 000 mg/kg (category III)
Chromium (VI)0.053 mg/kg (category III)0.2 mg/kg (category III)
Effective Date6 months from publication in Official JournalIn force

Table 1

Definitions and examples of toy materials

Toy materialExample
Category 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
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

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