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EU: European Commission proposes to strengthen aluminium limit in toys 

December 2018- Relevant for: Toys & children's products

On 10 December 2018, the European Commission (EC) notified the World Trade Organization (WTO) of the draft Directive1 to adopt the new aluminium migration limit in toys with a feedback period opens until 8 February 2019. The limit values proposed by the EC are summarised 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
Current limit
5 625
1406 70 000
  Proposed limit 2 25 560 28 130

The toxicity of aluminium and adverse health effects it poses on human body had been studied by several regulatory bodies. By evaluating the available data and considering other exposure sources, the Scientific Committee on Health, Environmental and Emerging Risks (SCHEER) published its final opinion2 on the tolerable daily intake (TDI) of aluminium and migration limit in toys calculated based on the TDI in September 2017. The subgroup “Chemicals” of the Expert Group on Toys Safety adopted the proposed migration limits and recommended to amend the limit values for aluminium accordingly.

There have been recall cases on RAPEX for wax crayons which contained aluminium in a level exceeding the migration limit. Aluminium is one of the 19 elements which are not allowed to exceed the migration limits set out in the Toy Safety Directive. In light of the available scientific evidence, technical and scientific developments, the limit values are updated from time to time. The latest update3 was Chromium (VI) in scrapped-off toy material. The limit is lowered from 0.2 mg/kg to 0.053 mg/kg with the effective date from 18 Nov 2019.

[1] WTO Notification
[2] E-ssentials of SCHEER publishes final opinion on aluminum in toys
[3] E-ssentials of EC adopts lower chromium VI limit in toys

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