Toy Association Advocates Against EU Scientific Committee’s Recent Stance on Titanium Dioxide in Toys

July 14, 2022 | The Toy Association submitted comments to the EU Scientific Committee on Health, Environmental, and Emerging Risks (SCHEER), pushing back on the committee’s preliminary opinion on the use of titanium dioxide (TiO₂) in toys. Titanium dioxide is a mineral that is bright white in color, making it valuable as a pigment in plastics, paints and inks, finger paints, modeling clay, crayons and pencils, etc.

The preliminary opinion comes as a result of a request from the European Commission (EC) to reevaluate titanium dioxide’s use in toys. Findings that titanium dioxide is unsafe are only marginally supported for occupational settings where dust is not controlled, but, as stated by The Toy Association in its comments, irrelevant to consumer products like toys. As per the EU CLP regulation, bulk chemical mixtures containing concentrations above 1% must carry cautionary labeling; this also triggers the “CMR restriction” in the EU Toy Safety Directive, prohibiting its use in toys above 1% unless an exemption is granted.

While SCHEER agreed that some uses may be allowed in toys, such as for fillers in plastics, it would not approve use above 1% in modeling clay, finger paints, pencils, and crayons despite a lack of valid scientific data calling into question the safety of such exposure. The Toy Association argued that there is minimal, if any, respirable titanium dioxide released by the previously noted uses in toys and that SCHEER’s opinion runs counter to a recent Scientific Committee on Cosmetic Safety (SCCS) approved use of the substance in powder cosmetics at up to 25%, a use in which the amount of respirable particles is potentially much greater than in toys.

“Given the known risks and identified mechanism of action of TiO₂, cautionary labeling may make sense for industrial settings, but warnings and prohibitions are completely unnecessary and irrelevant for toys,” said Alan Kaufman, senior vice president of technical affairs at The Toy Association.

Members will be kept informed on the issue as new updates are made. Members can contact The Toy Association’s Alan Kaufman for more information.