EU NGO calls for limit on aniline in toys

The European Association for the Coordination of Consumer Representation in Standardisation (ANEC) is calling for an aniline limit for toys intended for use by children under 36 months, or to be placed in the mouth under Appendix C of Annex II to Toy Safety Directive.

Aniline (CAS NO: 62-53-3) is a toxic organic compound with the formula C ₆H ₇N. Consisting of a phenyl group attached to an amino group, aniline is the prototypical aromatic amine. Its main use is in the manufacture of precursors to polyurethane and other industrial chemicals. Aniline has a mandatory classification in the EU, which includes listing as a category 2 carcinogen and mutagen and a category 1 skin sensitiser. ANEC says test publications and reports show that it has been found at levels up to 1,200mg/kg in articles for babies.

It is recommended to adopt for aniline in the position paper:

• a limit of 30 mg/kg for toy articles made of textile and leather in line with REACH provisions for carcinogenic primary aromatic amines released from azo colourants including any "free" aniline;
• corresponding test methods given in EN ISO 17234-1 for leather and EN 14362-1 for textiles adapted to detect aniline;
• the application of the provisions included EN 71-7 on finger paints (i.e. 10 mg/kg for the "free" aniline and 30 mg/kg for aniline cleaved from azo dyes) for all liquid toys.

Here is a list for existing aniline limits on toys:

Regulation	Limits and applicability
REACH Regulation	At present aniline included in articles for consumers is not restricted in REACH.
Toy Safety Directive	As a substance classified Carc. 2 and Muta. 2 the aniline limit in (accessible parts of) toys is 1% (= 10.000 mg/kg) based on the generic exclusion of CMR substances and applicable thresholds.
EN 71-9:2005+A1:2007 (organic chemical compounds)	Action limit (= 5 mg/kg) when tested in accordance with EN 71-10:2005 and EN 71-11:2005 It applies to a broad range of toys including those intended for children under 3 years of age made of textile and leather where the first action method given in EN 71-10 (colour fastness test) gives a negative result.
EN 71-7:2014 (finger paints)	10 mg/kg when tested in accordance with Annex D In addition, 4.2.2 disallows azo colourants that by cleavage of one or more azo groups can produce the primary aromatic amines listed in Tables 1 and 2 (including aniline) when tested in accordance with the test method specified in Annex D. This Annex provides that "A prohibited azo colourant is deemed to be present in the finger paint if, on reductive cleavage, one or more of the amines listed in Tables 1 and 2 is present in a concentration exceeding 30 mg/kg".

Reminder: Five restricted substances (totalling nine restrictions) were inserted in Appendix C to Toy Safety Directive last year. Furthermore, the limits on TCEP, TCPP, TDCP and bisphenol A (BPA) has applied since 21 December 2015. Toy businesses should pay due attention in case aniline is included in Appendix C.