Allergenic Fragrance Requirements Strengthened in EU Toy Safety Directive

On December 15, 2020, the European Union (EU) published two directives to revise the two lists regulating the presence of allergenic fragrances in toys. The provisions in the directives will strengthen EU requirements on allergenic fragrances under Directive 2009/48/EC, the Toy Safety Directive (TSD).

The two directives – (EU) 2020/2088 and (EU) 2020/2089 – update the lists under Point 11 of Part III in Annex II of the TSD. These lists are:

  • ‘Prohibited List’ – contains 55 allergenic fragrances. Their presence is allowed if it is technically unavoidable under good manufacturing practice (GMP) and each fragrance is no more than 100 mg/kg. These substances should not be used intentionally
  • ‘Labeling List’ – contains 11 allergenic fragrances. These require their name to be listed on the toy, on an affixed label, on the packaging, or in the accompanying leaflet if their concentrations are greater than 100 mg/kg

The changes brought in by the two directives are:

Directive (EU) 2020/2089:

  • Deletes methyl heptine carbonate (CAS 111-12-6, entry 10) from the ‘Labeling List’
  • Three allergenic fragrances added to the ‘Prohibited List’:
    1. Atranol (CAS 526-37-4)
    2. Chloroatranol (CAS 57074-21-2)
    3. Methyl heptane carbonate (CAS 111-12-6)

Directive (EU) 2020/2088:

  • Two additional enantiomers (CAS 1117-61-9 and 7540-51-4) added to citronellol under Entry 4 of the ‘Labeling List’
  • 61 new entries added to the ‘Labeling List’ – some of which contain more than one CAS number

Following these changes, the ‘Prohibited List’ now contains 58 fragrances and the ‘Labeling List’ now contains 71 entries.

Member States are required to transpose these provisions into their national laws by July 4, 2022, with the provisions becoming effective on July 5, 2022.

SGS EU Toy Directive Services

SGS offers a wide range of services to ensure that products comply with the EU Toy Safety Directive. They offer training, safety/risk assessment, technical documentation check, labelling review, testing according to harmonized standards, SVHC screening, inspections and audits. They have the world’s largest network of toy experts and testing facilities, including around 20 toy laboratories and three 3 EU Notified Bodies (France, Germany and Netherlands). In the end, it’s only trusted because it’s tested. Learn more about SGS’s EU Toy Directive Services. 

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