Denmark has issued a draft order on toy safety to implement new requirements for allergenic fragrances. The draft order is proposed to be adopted on June 1, 2022.

SAFEGUARDS | Toys & Juvenile ProductsNO. 035/22

 SG 03522 Children DIY Perfume

In Denmark, toy safety requirements are specifically regulated under Executive Order No. 1800 of December 3, 2020 (BEK No. 1800 of 12/3/2020). This piece of legislation implemented Directive 2009/48/EC, as last amended by Directives (EU) 2019/1922 on strengthened limits for aluminum migration and (EU) 2019/1929 on the restriction of formaldehyde in toys intended for children under 36 months of age, or in other toys intended to be placed in the mouth (SafeGuardS 166/19 and 169/19).

Point 11 under Part III of Annex II to BEK No. 1800 of 123/2020 regulates 66 allergenic fragrances in toys:

  • 55 allergenic fragrances are prohibited, but their presence is allowed provided these are technically unavoidable under good manufacturing practice (GMP)and each fragrance is no more than 100 mg/kg (the ‘Prohibited List’)
  • 11 allergenic fragrances require their names to be listed on the toy, an affixed label, the packaging or in an accompanying leaflet, if their concentrations are greater than 100 mg/kg (the Labeling List’)

In February 2022, the World Trade Organization (WTO) announced a draft executive order from Denmark on its intention to set out new rules for toys (the draft order). The draft order, attached to WTO document 22-1771 and notified under G/TBT/N/DNK/126/Rev.1, transposes Directives (EU) 2020/2088 and (EU) 2020/2089 on the use of two categories of allergenic fragrances (SafeGuardS 188/20 and references therein) into Denmark’s national law on toy safety. 

The draft Order contains two important changes to the two lists of allergenic fragrances:

  • Expands the number of entries on the ‘Prohibited List’ from 55 to 58
  • Adds 61 new entries to ‘Labeling List’ (entries 12 to72)

The draft Order would repeal Executive Order No. 1800 of December 3, 2020, on toy safety.

According to the WTO document and the draft order, it is proposed that the draft order is:

  • Adopted on June 1, 2022
  • Brought into force on July 1, 2022
  • Brought into effect on July 5, 2022, for the new allergenic fragrance requirements

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. We operate the world’s largest network of toy experts and testing facilities – around 20 toy laboratories worldwide, including 3 EU Notified Bodies (France, Germany and Netherlands). In the end, it’s only trusted because it’s tested. Contact us for more information or visit our website

For inquiries, please contact:

Dr. Hingwo Tsang
Global Information and Innovation Manager
t: (+852) 2774 7420

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