EN71-3 Testing
Compliance with EN 71-3:2013 will offer a presumption of conformity to the migration of certain elements requirements of the Toys Safety Directive 2009/48/EC, which take effect from 20 July 2013.
EN 71-3:2013 already includes the new lower migration limits for barium than those originally published in the Directive. This interim discrepancy has now been resolved through a further amendment to the Directive by Regulation (EU) No 681/2013.
he new chemical requirements of the EU Toys Safety Directive, which take effect from 20 July 2013. The main changes and issues are as follows:
The main changes and issues are as follows:
Toy materials are now divided into three categories, as follows, based on their type, which determines the extent to which they may be ingested by the child. (See Table 1 overleaf.)
- Category I - Dry, brittle, powder-like or pliable materials
- Category II - Liquid or sticky materials
- Category III - Scraped-off materials
Testing now includes 19 elements (or rather 17 different elements, with chromium (III) and (VI), along with both tin and organic tin counted twice).
The original 8 elements are retained (chromium, now being split as the two oxidation states above), along with another 9 different elements.
Migration limits have been revised, with many reduced (see Table 2 overleaf).
Barium migration limits have been reduced further from those in the Directive (with another reduction in the lead limits expected in due course).
The migration limits for chromium (VI) in Categories I and II toy materials are too low to be measured directly by the new EN 71-3 method. Hence other means will have to be used to demonstrate compliance.
The large analytical correction factor applied has been deleted.
- Under the previous version, only the adjusted analytical result was used to verify compliance. That is, for a toy material to be deemed non-compliant, the analytical result had to exceed the migration limit by such a considerable margin that it still exceeded the migration limit after subtraction of the analytical correction factor (which was 30 %, 50 % or 60 %, per each element).
Laboratories now have to determine their measurement uncertainty and use it to interpret whether their analytical result shows compliance with the migration limit.
- The margin by which the analytical result could now “exceed”the migration limit before its deemed non-compliant will be drastically reduced. That is, assuming that a lab’s measurement uncertainty is significantly lower than the former 30 % to 60 % analytical correction factor.
Table 1 - Toy Material Categories
|
Criteria
|
Toy Materials
|
|
Category
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Category I
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Category II
|
Category III
|
|
Toy Material Type
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Dry, brittle, powder-like or pliable materials
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Liquid or sticky materials
|
Scraped-off materials
|
|
Definition
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Solid materials which may leave residues on the hands
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Fluid or viscous materials which can be ingested or have skin contact
|
Solid materials which can be ingested by biting, tooth scraping, sucking or licking
|
|
Examples
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1. Compressed paint tablets
2. Colouring pencil cores
3. Chalk
4. Crayons
5. Other solid materials intended to leave a trace
6. Pliable modelling clays
7. Plaster of Paris
|
1. Finger paints
2.Paints, varnishes, lacquers
3. Ink in pens
4. Liquid adhesives
5. Glue sticks
6. Slimes
7. Bubble solutions
8. Other accessible liquids
|
1. Coatings (e.g., paints, varnishes, lacquers, inks, polymers, etc.)
2. Plastics, rubbers, silicones and other polymeric materials
3. Paper and paper board
4. Textile materials
5. Glass, ceramic, metallic materials
6. Wood, fibre board, hard board, bone, leather, etc.
|
|
Assumed ingestion by the child
|
100 mg/day
|
400 mg/day
|
8 mg/day
|
Table 2 - Migration Limits
|
Element
|
Migration Limits (mg/kg)
|
|
Category I
Dry, brittle, powder-like or pliable materials
|
Category II
Liquid or sticky materials
|
Category III
Scraped-off materials
|
|
Aluminium (Al)
|
5,625
|
1,406
|
70,000
|
|
Antimony (Sb)
|
45
|
11.3
|
560
|
|
Arsenic (As)
|
3.8
|
0.9
|
47
|
|
Barium (Ba)
|
1,500
|
375
|
18,750
|
|
Boron (Bo)
|
1,200
|
300
|
15,000
|
|
Cadmium (Cd)
|
1.3
|
0.3
|
17
|
|
Chromium (III) (Cr III)
|
37.5
|
9.4
|
460
|
|
Chromium (VI) (Cr VI)
|
0.02
|
0.005
|
0.2
|
|
Cobalt (Co)
|
10.5
|
2.6
|
130
|
|
Copper (Cu)
|
622.5
|
156
|
7,700
|
|
Lead (Pb)
|
13.5
|
3.4
|
160
|
|
Manganese (Mn)
|
1,200
|
300
|
15,000
|
|
Mercury (Hg)
|
7.5
|
1.9
|
94
|
|
Nickel (Ni)
|
75
|
18.8
|
930
|
|
Selenium (Se)
|
37.5
|
9.4
|
460
|
|
Strontium (Sr)
|
4,500
|
1,125
|
56,000
|
|
Tin (Sn)
|
15,000
|
3,750
|
180,000
|
|
Organic tin (Otc)
|
0.9
|
0.2
|
12
|
|
Zinc (Zn)
|
3,750
|
938
|
46,000
|
|
