UK Proposed Limits for Aniline, Formaldehyde, Allergenic Fragrances and Lower Migration Limits for Aluminium in Toys under Toys (Safety) Regulations
In April 2022, the UK Secretary of State has proposed The Toys and Cosmetic Products (Restriction of Chemical Substances) Regulations 2022 amending The Toys (Safety) Regulations 2011 (S.I. 2011 No. 1881) as regards specific limit values for aniline, formaldehyde in certain toys, for 3 allergenic fragrances in toys, as well as for the migration limits for aluminium in toys. These amendments were proposed to extend to UK Great Britain (England, Wales, and Scotland).
The UK Secretary of State has proposed to:
(1) add two entries regards aniline and formaldehyde in Appendix C to Schedule 2 to the Toys (Safety) Regulations 2011 (S.I. 2011 No. 1881), which specifies the limit values for chemicals used in toys intended for use by children under 36 months or in other toys intended to be placed in the mouth:
| Substance |
CAS No |
Limit value |
| Aniline |
62-53-3 |
- 30 mg/kg after reductive cleavage in textile and leather materials;
- 30 mg/kg after reductive cleavage in finger paints;
- 10 mg/kg as free aniline in finger paints |
| Formaldehyde |
50-00-0 |
- Polymeric: 1.5 mg/l (migration limit);
- Resin-bonded wood: 0.1 ml/m3 (emission limit);
- Textile: 30 mg/kg;
- Leather: 30 mg/kg;
- Paper: 30 mg/kg;
- Water-based: 10 mg/kg |
The amendment on aniline and formaldehyde was proposed to come into force on 15 December 2022. Toys that are made available on the market of UK Great Britain prior to 15 December 2022 can be made available on the market until 15 March 2023.
The proposed limits for aniline, are the same as EU’s requirement as laid down in the Directive (EU) 2021/903, which will apply from 5 December 2022 in EU Member States and UK Northern Ireland. (for details, please refer to Intertek Insight: link)
The proposed limits for formaldehyde, are the same as EU’s requirement as laid down in the Directive (EU) 2019/1929, which has applied from 21 May 2021 in EU Member States and UK Northern Ireland. (for details, please refer to Intertek Insight: link).
(2) amend the migration limits of aluminium in the table in Point 13 of Part 3 of Schedule 2, as below:
| Element |
mg/kg in dry, brittle, powder-like or pliable toy material |
mg/kg in liquid or sticky toy material |
mg/kg in scraped-off toy material |
| Aluminium (Al) |
2250 |
560 |
28130 |
The amendment on aluminium was proposed to come into force on 15 December 2022. Toys that are made available on the market of UK Great Britain prior to 15 December 2022 can be made available on the market until 15 March 2023.
The proposed new migration limits for aluminium, are the same as EU’s requirement as laid down in the Directive (EU) 2019/1922, which has applied from 20 May 2021 in EU Member States and UK Northern Ireland. (for details, please refer to Intertek Insight: link).
(3) add three entries of prohibited allergenic fragrances in Point 11 of Part 3 of Schedule 2, as below:
| No |
Name of the allergenic fragrance |
CAS number |
| (56) |
Atranol (2,6-Dihydroxy-4-methyl-benzaldehyde) |
526-37-4 |
| (57) |
Chloroatranol (3-Chloro-2,6-Dihydroxy-4-methyl-benzaldehyde) |
57074-21-2 |
| (58) |
Methyl heptine carbonate |
111-12-6 |
The above ban shall not apply to traces of the fragrances in which the presence is technically unavoidable under good manufacturing practice and does not exceed 100 mg/kg.
The amendment on three prohibited allergic fragrances was proposed to come into force on 15 October 2022. Toys that are made available on the market of UK Great Britain prior to 15 October 2022 can be made available on the market until 15 December 2022.
The proposed addition of three prohibited allergenic fragrances, are the same as EU’s requirement as laid down in the Directive (EU) 2020/2089, which will apply from 5 July 2022 in EU Member States and UK Northern Ireland. (for details, please refer to Intertek Insight: link). However, currently the UK has not proposed the addition of labelled allergenic fragrances for toys placed on the market of UK Great Britain yet.
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