In December 2018, the European Commission (EC) proposed to set limits for formaldehyde in different toy materials. The Commission finally published the Directive (EU) 2019/1929 on 20 November 2019 to amend Appendix C to the Toy Safety Directive 2009/48/EC by adding a new entry of formaldehyde. Appendix C only applies to toys intended for use by children under 36 months or other toys intended to be placed in the mouth. The new requirement will come into effect from 21 May 2021. The new restriction is summarised in Table 1 below.
Table 1. Summary of new formaldehyde restriction
Toy material | Limit value |
Polymeric | 1.5 mg/l (migration limit) |
Resin-bonded wood | 0.1 ml/m3 (emission limit) |
Textile | 30 mg/kg |
Leather | 30 mg/kg |
Paper | 30 mg/kg |
Water-based | 10 mg/kg |
Formaldehyde (CAS no. 50-00-0) is classified as carcinogenic category 1B under Regulation (EC) No 1272/2008; and it also shows skin sensitising property. Formaldehyde is used as a monomer in the manufacture of polymers. It is also used in the manufacture of textile, leather, paper and resin-bonded wood products such as particle board, medium density fibre board (MDF) and plywood. Owing to its function as a preservative, formaldehyde could also be used in water-based materials as well as dry materials which are intended to be mixed with water prior to use.
The use of formaldehyde has already been regulated in various European countries such as Finland, Netherlands and Germany, where a new test method for formaldehyde emission from wood-based material has been adopted this year. At EU level, formaldehyde is one of the CMR substances being restricted in clothing, textiles and footwear under Annex XVII in REACH, which will take effect from 01 November 2020.