REACH is a chemical regulation, not a toy standard, and that distinction confuses buyers. The toy standards tell you how to test; REACH tells you which substances cannot be there at all. This guide covers the phthalate and heavy metal restrictions that affect moulded plastic toys sold in the EU.
Phthalates: the named six
Six phthalates are restricted in the EU for toys and child care articles at a 0.1 percent limit by weight of the plasticised material:
- DEHP, DBP and BBP are prohibited outright in toys and childcare articles for children under three.
- DIDP, DINP and DNOP are restricted under the same 0.1 percent threshold, with the restriction applied through the toys directive and REACH Annex XVII entries.
For moulding, the practical consequence is that the plasticiser in a soft PVC part has to be a certified non-restricted alternative. The claim phthalate-free is not enough on its own: ask which specific substances were tested for, by what method, and to what detection limit.
Heavy metals: two different limits
Heavy metals in toys come from two directions and are limited twice:
- Toy safety migration limits. EN 71-3 sets a soluble migration limit per element, because the hazard is a child mouthing the toy.
- REACH Annex XVII. Lead in articles that can be mouthed is limited to 0.05 percent by weight, and the REACH limit applies to the material, not the migration. A decorated part can pass migration and still exceed the total-content limit.
Cadmium is subject to a separate and much stricter restriction under REACH, effectively banned in plastics above 0.01 percent, which is why cadmium pigments are no longer used for reds and yellows in European toy production.
SVHC and the candidate list
Substances of very high concern on the REACH candidate list carry a notification duty if they are present above 0.1 percent and the importer sells more than one tonne per year. Several phthalates, certain flame retardants and some metal compounds used as heat stabilisers in PVC appear on the list. A supplier should be able to state whether any candidate-list substance is present above the threshold, not simply answer no chemicals.
What to request
- A declaration naming the six phthalates with the test method and detection limit, not a generic phthalate-free statement.
- A heavy metal report on the finished, decorated part, covering both migration and total content where the part can be mouthed.
- A statement on candidate-list substances above 0.1 percent, with the article-level exposure estimate.
- Change control: a commitment that a plasticiser, pigment or stabiliser substitution triggers a re-declaration rather than a silent swap.
Related reading
Our food-grade silicone baby products avoid the plasticiser question entirely by using platinum-cured silicone, and the material guides cover the platinum silicone versus TPE comparison for parts that contact skin.
