France extends the interim restriction on formamide in toy puzzle mats to next October

On 4 November 2015, the Journal officiel de la République Française (JORF, Official Gazette of the French Republic) published Decree EINC1521729A (dated 26 October 2015) to extend a further year for interim restriction on formamide in toy puzzle mats from 26 October 2015 to 25 October 2016. The limit remains 200mg/kg.

Country	Substance	Scope	Requirement	Validity
France	Formamide	Toy puzzle mats	≤ 200 mg/kg	26 October 2015 to 25 October 2016

It is December of 2010 that France and Belgium first required to withdraw toy puzzle mats with excessive levels of formamide. In July 2011, France issued interim restriction on formamide in toy puzzle mats, set forth that toy puzzle mats whose concentration of formamide exceeded 2mg/kg should be prohibited from import or sale and also designated three test methods (see the chart below) with a validity of one year (as of July 2012).

According to Directive EFIC1118446A, the import or sale of toy puzzle mats that meeting any of the following criteria is allowed:

SN	Limit	Standard
1	Formamide in toy puzzle mats≤2mg/kg	Analyze by GC-MS as per Annex A to EFIC1118446A for acetone extraction
2	Formamide release of toy puzzle mats within 28-day test≤20μg/m3	ISO 16000-6 or EN ISO 16000-9
3	Formamide release of toy puzzle mats within 7-day test≤40μg/m3	ISO 16000-6 or EN ISO 16000-9

However, its limit was altered as 200 mg/kg in 2012. This interim restriction has since been extended in 2012, 2013 and 2014; each for a period of one year.

Formamide (CAS NO 75-12-7) is classified as reprotoxic 1B (toxic to reproduction 1B) under Regulation (EC) 1272/2008 on classification, labelling and packaging of substances and mixtures (CLP Regulation). It is widely used in organic synthesis, paper treating agents, fibre softeners and animal glue softeners due to its active properties and special solvency. It is of high likelihood that its level in foam materials is excessive.

Formamide is included in SVHC list in 2012 with the limit of 1000mg/kg; its concentration shall not exceed 2mg/kg in CNS 15493-2012 Safety requirements of plastic puzzle ground mat of Taiwan. Furthermore, the European Union Commission of Toy Safety proposed to add formamide in Schedule C of Annex II to Toy Safety Directive 2009/48/EC in the meeting of June 2015. The nickel release test is required on foam toy materials when the concentration of formamide exceeds 200 mg/kg and the release volume shall not exceed 20 μg/m3 within 28-day test.

Reminder: The restriction for formamide may be applicable to all foam toy materials. In this case, toy companies are facing severe challenges. The customs clearance for products can be ensured only by tracking amendments to regulations and testing products in accordance with applicable stipulations.

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Further information
Decree EINC1521729A (in French)
Toy safety directive proposes to ban six substances--News on C&K Testing