Fragrant regard, Germany
May 7, 2012
The Federal Institute for Risk Assessment (BfR), the scientific agency of the Federal Republic of Germany, has released an "updated opinion" regarding fragrances in toys. 
The opinion of the BfR does not change the legal requirements of the Toy Safety Directive, but should be taken under consideration when importing products into the German/EU market.
The use of 55 allergenic fragrances and fragrance ingredients is banned in accordance with the new EU Toy Directive. 11 additional fragrances must be declared due to their allergenic potential. However, trace amounts of these banned substances up to 100 mg per kg of toy material are permitted in toys. Germany says this limit is too high.
BfR recommendations:
- 55 banned fragrances should not be detected (per the new EU Toy Safety Directive (TSD) 2009/48/EC, trace amounts up to 100 mg per kg toy material are permitted, but in the view of the BfR, this limit is too high)
- The threshold for 11 declared fragrances (as per the TSD) should be lowered from 100mg/kg to 10mg/kg
- Toys for children under three years of age should not contain fragrances
In the view of the BfR, this limit is too high. The institute holds that the 55 banned allergenic fragrances should not be detectable in toys. Information gathered in the area of cosmetic products show that such contaminations do not reflect good manufacturing practice, since such substances are not contained in perfume oils.
For the 11 fragrances that must by law be declared, BfR recommends that the declaration threshold is lowered. Suggested targets are: from currently 100 mg per kg of toy material to 10 mg per kg.
In the opinion of the BfR, toys for children under 3 years of age —and toys which are small enough so that children can put them in their mouth —should not contain any fragrances at all.
The institute also notes that liquid and pasty toy materials which, like finger paint or play dough, can come into direct contact with the skin contain preservatives to prevent germ growth. Many preservatives are known for their sensitisation properties. For this reason, the use of preservatives in such toys should be subject to the same requirements as those that apply to preservatives in cosmetic products.
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