EU Proposes Amendment to Requirements on Lilial, Bisphenol A (BPA), Phenol and Benzisothiazolinone (BIT)

Targeted audience	EU/EEA manufacturers, EU/EEA importers and their upstream providers
Products concerned	Toys
Key industries concerned with this insight	Toys
Application date	12 months after publication
Main content or requirements	On 7 August 2026, the EU proposed to amend the EU Toy Safety Directive 2009/48/EC (TSD) to ban the allergenic fragrance lilial and lower the bisphenol A (BPA) migration limit from 0.04 mg/L to 0.005 mg/L. The amendment also removed the outdated methods EN 71-10:2005 and EN 71-11:2005.
Reference	Link 1 Link 2

On 7 August 2026, the European Commission proposed to amend Annex II to the EU Toy Safety Directive 2009/48/EC (TSD) as regards lilial, bisphenol A (BPA), phenol and benzisothiazolinone (BIT).

The highlights are as follows:

1. The allergenic fragrance lilial (CAS No. 80-54-6) (2-(4-tert-butylbenzyl) propionaldehyde) has been moved from the list of allergenic fragrances that require labelling to the list of banned allergenic fragrances.
2. The migration limit of bisphenol A (BPA) (CAS No. 80-05-7) is reduced from 0.04 mg/L to 0.005 mg/L.
3. The test methods EN 71-10:2005 and EN 71-11:2005 are removed for bisphenol A (BPA), phenol (CAS No. 108-95-2) and 1,2-benzisothiazol-3(2H)-one (BIT) (CAS No. 2634-33-5), since EN 71-10:2005 and EN 71-11:2005 no longer represent the state of the art.

The proposed amendment is scheduled to apply 12 months after date of publication in the Official Journal of the European Union (OJEU).

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