Two effective dates are approaching for the European Union’s (EU) new Restriction of Hazardous Substances (RoHS 2) directive 2011/65/EU for electrical and electronic toys (E&E), which has been modified to include all toys with an E&E function.

Beginning on January 2, 2013 toys that have a major E&E component must meet the RoHS 2 limits. For toys where the E&E component is a minor/secondary one one (e.g. a plush toy that sings), compliance with RoHS 2 limits must be met by July 22, 2019.

E&E equipment in toys is defined by the EU as equipment which is dependent on electric currents or electromagnetic fields in order to work properly. The new definition of “dependent” in RoHS 2 includes toys that need electric currents or electromagnetic fields to fulfill at least one intended function.

Additionally, RoHS 2 introduces labeling requirements of a CE mark to denote compliance with European norms reserved for electronic products that also respect RoHS requirements.

The new law is a revision of the RoHS Directive first launched in 2003 to set strict limit values for lead, mercury, cadmium, hexavalent chromium, polybrominated biphenyls or polybrominated diphenyl ethers in specified types of electrical and electronic equipment and toys to prevent these banned substances from being disposed of and potentially released into the environment. Limits for all of the above substances remain at 0.1%; limits for cadmium remain at 0.01%.