Key takeaway
What This Development Means
Draft EU toy chemical restrictions would list Lilial as a prohibited allergenic fragrance, lower the BPA migration limit and update test references for BIT and phenol. Technically unavoidable Lilial traces would remain permitted up to 100 mg/kg. National application is proposed 12 months after publication in the Official Journal.
Are The Proposed Toy Chemical Limits Already Applicable?
No. The Commission text is a non-final draft Directive. The proposed Lilial listing, revised BPA limit and test-reference changes do not yet amend applicable law. Final wording, adoption and Official Journal publication are still required. National application is proposed 12 months after publication, not 12 months after the draft posting.
What Should Toy Manufacturers Investigate First?
Toy manufacturers should identify relevant products containing Lilial, BPA, BIT or phenol, obtain updated formulation declarations and review current laboratory methods. Procurement teams should engage suppliers early, while compliance teams assess reformulation, retesting, stock transition, technical-file updates and evidence needs without treating the non-final draft as applicable law yet carefully.
Source basis: European Commission, non-final draft Directive amending toy chemical restrictions (7 August 2026)
Toy manufacturers, importers and material suppliers could face tighter chemical controls under a draft European Commission Directive posted on 7 August 2026. The proposed EU toy chemical restrictions address Lilial, bisphenol A, BIT and phenol, creating potential reformulation, testing and supplier-assurance work across EU and international toy supply chains.
The text would amend Annex II to Directive 2009/48/EC. It is expressly non-final and does not yet change applicable law. Adoption and publication in the Official Journal would be required before the proposed 12-month national application period begins.
BPA Migration And Lilial Listing
The draft would add Lilial to the list of prohibited allergenic fragrances in toys. Under the unchanged Annex II trace rule, technically unavoidable traces arising under good manufacturing practice would remain permitted up to 100 mg/kg. Businesses should review fragrances, scented components and supplier formulations for intentional use and relevant residual presence.
For bisphenol A, the proposed migration limit is 0.005 mg/l, reduced from 0.04 mg/l. The lower value could affect polymer selection, coatings, adhesives and other components used in toys intended for children under 36 months or designed to be placed in the mouth.
Manufacturers may need more sensitive testing and clearer evidence concerning analytical uncertainty, sample preparation and laboratory capability.
BIT And Phenol Limits For Toy Materials
The draft would retain the existing BIT concentration limit of 5 mg/kg in aqueous toy materials while changing the referenced analytical approach. This can affect paints, inks, glues, gels, liquids and similar mixtures in which BIT may be used as a preservative.
For phenol, the existing 5 mg/l migration limit in polymeric toy materials and 10 mg/kg concentration limit where phenol is used as a preservative would also remain while testing references change.
Procurement and compliance teams should identify products that rely on these substances and ask suppliers for updated composition declarations. Existing declarations may not provide enough detail to confirm compliance with the proposed limits.
Toy Safety Testing And Implementation
The draft would delete the mandatory references to EN 71-10 and EN 71-11. EN 71-17, EN 71-18 and EN 71-19 may subsequently be assessed and, where appropriate, cited in the Official Journal to provide presumption of conformity.
Manufacturers should compare existing test programmes with the proposed BPA limit and reference changes. Early laboratory discussions can clarify detection capability, testing capacity, costs and sample requirements.
Stock planning will depend on the final Directive, its publication date and national implementation. Businesses should avoid treating the draft-posting date as the start of the proposed 12-month period, while considering reformulation lead times for products with long development or sourcing cycles.
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