Update on EU Toy Safety Rules Hong Kong Toy Fair

Transcription

1 Update on EU Toy Safety Rules Hong Kong Toy Fair 9 January 2019

2 EU TOY SAFETY RULES PAST & FUTURE CHANGES What has changed / happened recently? What is in the pipeline for the near future? Longer-term future expectations? 6

3 EU TOY SAFETY RULES PAST & FUTURE CHANGES What has changed / happened recently? What is in the pipeline for the near future? Longer-term future expectations? 6

4 TOY SAFETY DIRECTIVE AMENDMENTS Migration limits for lead are reduced by a factor of 7 As of 28 October 2018 mg/kg in dry, brittle, powderlike or pliable toy material mg/kg in liquid or sticky toy material mg/kg in scraped-off toy material Previous limits New limits Migration limit for bisphenol A (BPA) for toys < 36 months or intended to be placed in the mouth is reduced by a factor of 2.5 As of 26 November 2018 old limit = 0.1 mg/kg New limit = 0.04 mg/kg 4

5 TOY SAFETY DIRECTIVE AMENDMENTS Migration limit for phenol in polymeric materials As of 4 November 2018 New limit = 5 mg/l Restriction / ban for phenol as a preservative in liquid toy materials As of 4 November 2018 New limit = 10 mg/kg (content limit) Migration limit hexavalent chromium for scraped-off toy materials divided by four As of 18 November 2019 Current limit = 0.2 mg/kg New limit = mg/kg (limit of quantification from the current EN 71-3) Advice: start using new limit now 5

6 TOY SAFETY DIRECTIVE GUIDANCE Updated / new guidance: Musical instruments informal agreement on text, expected to be made available Q How to distinguish toys from real musical instruments? What is their appropriate age grade? Pools informal agreement on text, expected to be made available Q When is a pool a toy? Toy Puffer balls under discussion IF categorized for < 36 months, the whole category will effectively be banned 6

7 TOY SAFETY STANDARDS and OJEU publication Significant changes to EN 71-1 (mechanical & physical properties) Applicable as of 28 February 2019 Regarding cords requirements Regarding projectiles requirements Changes to EN 71-3 (migration of certain elements) to reflect TSD change to lead limits Already applicable (by law) since 28 October 2018 Changes to EN 71-7 (finger paints) to reflect TSD change re preservatives Already applicable (by law) since 24 November 2017 Significant changes to EN 71-8 (activity toys) As of 28 February 2019 Many technical changes & clarifications Clarification on presumption of conformity OJEU publication on 10 August February 2019 definitive date of application of revised standards 7

8 NANOMATERIALS REACH registration forms need to contain information on substances in nanoform As of 1 January 2020 concerns materials falling within the scope of REACH Materials containing particles where at least half of them are in the dimension range of 1 nm 100 nm (in some cases even where less than half are such) have special information requirements 8

9 TEXTILES FANCY DRESS & DISGUISE COSTUMES 33 CMR substances banned in textiles (incl. toy fancy dress & disguise costumes) As of 1 November 2020 Worry concerning articles that, under normal or reasonably foreseeable conditions of use, come into contact with human skin to an extent similar to clothing On top of TSD requirements if more stringent No other textile toys in scope 9

10 EU TOY SAFETY RULES PAST & FUTURE CHANGES What has changed / happened recently? What is in the pipeline for the near future? Longer-term future expectations? 6

11 TOY SAFETY DIRECTIVE AMENDMENTS Migration limits for aluminium Could start to apply end of 2020 (earliest) Limits divided by 2.5 mg/kg in dry, brittle, powderlike mg/kg in liquid or sticky toy mg/kg in scraped-off toy or pliable toy material material material Current limits Future limits Toy materials most likely to be affected are coloured pencils and finger paints (blue colours) Advice: start using new limit now 11

12 TOY SAFETY DIRECTIVE AMENDMENTS Restrictions for toys < 36 months or intended to be placed in the mouth: Formaldehyde Could start to apply end of 2020 (earliest) The new restrictions will target various toy materials and will be set at: - 1,5 mg/l (migration limit) in polymeric toy material ml/m³ (emission limit) in resin-bonded wood toy material - 30 mg/kg (content limit) in textile toy material - 30 mg/kg (content limit) in leather toy material - 30 mg/kg (content limit) in paper toy material -10 mg/kg (content limit) in water-based toy material Aniline Could start to apply end of 2020 (earliest) Limit set at 30 mg/kg after reductive cleavage in textile and leather toy materials (extension of the currently applicable REACH azodyes restriction to aniline). 12

13 TOY SAFETY DIRECTIVE AMENDMENTS List of banned and labelled fragrances New allergenic fragrances to be added to the ones already banned in the TSD (to align with the Cosmetic Product Regulation) - Adoption foreseen in March 2019 Could start to apply end of New allergenic fragrances to be added to the ones in the TSD that require labelling. Still under discussion since the Cosmetic Product Regulation has not adopted these changes Discussion and possible adoption in March

14 OTHER CHANGES TO BE EXPECTED Titanium dioxide: If TiO2 (in powder form) categorised as CMR, it will be banned in toys (anything above 1%) Can we prove no risks in certain toys? Possibly as of November 2020 Nickel guidance on direct and prolonged contact with the skin: Awaiting decision on which products will be concerned Not legally binding but probable that Member States will apply Squishy toys Possible decision on age grading could ban entire category Future decision on agreeing appropriate toxicological reference values 14

15 BREXIT 29 March 2019 Still unclear whether there will be a deal Possibly a customs union between EU and UK UK Standardisation body remains member of CEN UK address will not count as EU address on packaging / toy No UK Toy Notified Bodies for EC type examination Toy Safety Directive likely to remain more or less aligned but other legislation like REACH may diverge sooner or later 15

16 EU TOY SAFETY RULES PAST & FUTURE CHANGES What has changed / happened recently? What is in the pipeline for the near future? Longer-term future expectations? 6

17 LONGER-TERM EXPECTATIONS Environmental concerns affecting toys Packaging: some of the packaging already affected under the Single Use Plastics proposal which also targets balloons and balloon sticks 100% plastic packaging recycled by 2030 Microplastics in products Design requirements for products Scrutiny of Toy Safety Directive could lead to a re-opening! 17

18 Boulevard de Waterloo Brussels Tel Fax