Phthalates banned for all toys?

Entry 51 of the EU REACH Annex XVII restricts the use of 3 phthalates - BBP, DBP and the very popular DEHP from use in toys and childcare articles above 0.1%. That effectively bans them as plasticizers and affects every company importing toys or childcare items into the European Union.

Child with Toy

It should however be noted that for once, the US is not far behind with Consumer Product Safety Commission (CPSC) publishing a final rule which has in effect restricted a total of eight phthalates in children’s toys and child care articles. It will become effective on April 25, 2018, and applies to children’s toys and child care articles that are manufactured or imported from this date. The restrictions will begin to bleed into other markets and products even though there are currently exemptions for cars, planes, buildings, etc...

This is just one of the many groups of targeted chemicals and substances that need to be understood within your products and your supply chain in order to address risks of obsolescence due to legislation. REACH is simplified as "no data, no market" and with the lists of chemicals on both Annex XIV Candidate List and XVII Restricted list growing every day (181 SVHCs!); it is not longer a valid strategy to get qualitative statements from your suppliers that they are 'compliant this year.'

Forward thinking companies realize there must be a predictive set of quantifiable data addressing their particular product and materials to know whether their biggest risk is critical minerals mined in questionable locations (ex. cobalt) or additive & material substitutions at sub-tier levels affecting product quality. For more info or a risk assessment, contact B Cubed Consulting with a message or at my website www.bcubedconsulting.com

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