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The new European Toy Safety Directive (TSD) 2009/48/EC


The new European Toy Safety Directive (TSD) 2009/48/EC was a major focus of the Commission for materials and articles in the BFR meeting on 26. June 2009 (see detailed log: http://www.bfr.bund.de/) Focus of the directive are particularly laying down rules concerning the CMR substances (carcinogenic, mutagenic and toxic for reproduction), the allergenic fragrances and migration limits of each element.


In the new Toy Safety Directive the usage ban of CMR substances is lifted indirectly by usage requirements, as for example a permissible maximum concentration, which based on the chemical law provisions (this is 0.1% in many cases). In toys the allowable content of CMR substances as an example of polycyclic aromatic hydrocarbons (PAHs) is much higher than for example in car tires. (see link: polycyclic aromatic hydrocarbons (PAHs) in toys).

 

The usage of 55 allergenic fragrances is forbidden in the future, but levels of 100 mg/kg considered as technical not avoidable. Another 11 allergenic fragrances must be declared from a content of 100 mg/kg. There are now many perfumed toys on the market. As fragrances are used predominantly benzyl benzoate, benzyl alcohol, linalool and hexylcinnamaldehyde.

 

The list of regulated items/heavy metals has been extended from 8 to 18 (Directive 88/378/EEC), and organo-tin compounds. The defined migration limits are however, some higher than the current EN71-3. This concerns especially the toxicologically critical lead as it has a negative affect on the intelligence power of children.

 

Reported was on a research project funded by the BfR for analytical methods for the release of formaldehyde from wooden toys. In the ChemVerbotsV the limit for formaldehyde release from wood-stuff articles is defined with 0.1 ppm, which means you have to check the limit with the technical complex inspection chamber method or the WKI bottle method.

 

Different data sources and information from investigation offices of federal states evaluated to determine which substances belong to the critical dangerous substances in toys. Most often following substances led to complaints: softener/phthalates, solvent/volatile organic compounds (VOCs), allergenic disperse dyes, primary aromatic amines, PAHs migration of phenol and some heavy metals.

 

According to research of a federal state laboratory in toy paints there is a more and more usage of di-iso-butyl phthalate (DIBP) detectable. Obviously, the regulated di-n-butyl phthalate (DBP) are increasingly being replaced by the non-regulated iso-connection. Therefore also DiBP should be included in addition to DBP in the future to the Appendix 1 of articles and materials regulation.

 

Through the monitoring of toys and other materials and articles there was noted that repeatedly products with higher VOC apparent, which showed a very intensive sensory odour. Substances with skin, mucosa and / or eye irritation as well as toxic and carcinogenic properties have been frequently detected. In the future there should be determined exposure data, for these odorous products, to allow a clear legal assessment.

 

Furthermore the BfR has proposed, that also toys made of metal should be listed on a sample list (based on the Directive 94/27/EC nickel directive or REACH annex XVII No 27), which was drawn up from the European Commission, so as to proof that the limited value for the nickel release is also applicable for these product group, because while playing a longer skin contact is possible.

 

If you have any additional questions regarding the implementations and improvements of the Toy Safety Directive, we are always at your disposal.

 

 

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REACH
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