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UK Approved Limits for Aniline, Formaldehyde, Allergenic Fragrances and Lower Migration Limits for Aluminium in Toys under Toys (Safety) Regulations

On 14 June 2022, the UK Secretary of State has approved and published The Toys and Cosmetic Products (Restriction of Chemical Substances) Regulations 2022 (S.I. 2022 No. 659) 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 amendment regulations have:

(1) added 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 amendments on aniline and formaldehyde shall come into force on 15 December 2022. The amendments on aniline and formaldehyde do not apply to toys that are placed on the market of Great Britain prior to 15 December 2022.

The 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 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) amended 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 shall come into force on 15 December 2022. The amendment on aluminium does not apply to toys that are placed on the market of Great Britain prior to 15 December 2022.

The 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) a. added three entries of prohibited allergenic fragrances in the first table of 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.

b. Omitted Entry 10 (Methyl heptine carbonate) in the second table of Point 11 of Part 3 of Schedule 2.

The amendments on prohibited allergic fragrances shall to come into force on 15 October 2022. The amendments do not apply to toys that are placed on the market on the market of Great Britain prior to 15 October 2022.

The 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.

About Intertek

Intertek is a leading Total Quality Assurance provider to industries worldwide. Our network of more than 1,000 laboratories and offices and more than 100 countries, delivers innovative and bespoke Assurance, Testing, Inspection and Certification solutions for our customers’ operations and supply chains. Intertek Total Quality Assurance expertise, delivered consistently with precision, pace and passion, enabling our customers to power ahead safely.

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