As an ANEC Member , InfoCons Supports Stronger EU Protection Against Hazardous Chemicals in Childcare Products
As a member of ANEC – the European consumer voice in standardisation – InfoCons supports the joint position submitted by ANEC and BEUC regarding the European Commission’s draft REACH restriction on CMR Category 1A and 1B substances in childcare products.
The proposal represents an important step towards strengthening the protection of children’s health by limiting exposure to hazardous chemicals in products intended for their care and daily use. ANEC and BEUC welcome the initiative and call for additional measures to ensure a high level of consumer protection, including stricter concentration limits, broader restrictions on harmful substances, and stronger safeguards for vulnerable groups.
InfoCons shares the view that children deserve the highest level of protection from hazardous chemicals and supports efforts aimed at ensuring that childcare products placed on the European market are safe, compliant, and aligned with the objectives of the EU Chemicals Strategy for Sustainability.
Below are the key recommendations submitted by ANEC and BEUC to the European Commission regarding the draft REACH restriction.
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ANEC and BEUC comments to Draft REACH restriction of CMR 1A/1B substances in childcare products
ANEC, the European consumer voice in standardisation and BEUC – The European Consumer Organisation welcome the opportunity to provide comments in support of the draft REACH restriction on CMR 1A/1B substances in childcare products.
Children are particularly vulnerable to hazardous chemicals, as rightly observed in draft restriction. Unlike toys, existing EU legislation is however insufficient to safeguard children’s health against CMR substances in childcare products. Product tests by European consumer groups thus frequently detect chemicals of concern in children’s products e.g., in 2023 seven BEUC and ANEC members found hazardous bisphenols such as BPA, BPAF, and BPS in 60% of tested children’s products.
Against this background, we strongly support the proposed restriction as an essential safeguard of children’s health. We in particular welcome that the draft restriction aligns with the approach recommended by the 2023 ECHA investigation report on CMR category 1A/1B substances in childcare articles.
ANEC and BEUC recommendations
To adequately safeguard children’s health, we encourage the European Commission to take the following recommendations into account when finalising the draft restriction:
- Definition (point 2): We overall support the proposed definition of ‘childcare products’. To enable effective enforcement of the foreseen restriction, an age limit should however be included, as also proposed by ECHA. Accordingly, we recommend aligning the restriction with the age limit established in EU toy safety legislation i.e., 14 years.
- Restriction scope (point 1): We strongly support the proposal to restrict all CMR 1A/1B substances with a current and future harmonized classification. Similar to EU toy safety legislation, this approach will effectively prevent children’s exposure to such substances in childcare products. As observed by ECHA, this approach will also contribute to avoiding regrettable substitution in a more efficient way than an approach based on a narrower closed list of substances.
- In line with the ECHA investigation report, we likewise support the generic 0.001 % (w/w) concentration limit for the unavoidable presence of CMR 1A/1B substances in childcare products. As noted by the ECHA Enforcement Forum, this generic limit will allow practical and efficient enforcement of the foreseen restriction.
- We likewise support overall the specific concentration limits for the substances listed in the Appendix. We however consider that lower limits should be established for: ▪ Bisphenol AF: as proposed by ECHA, we recommend introducing a specific limit for bisphenol AF aligned with the limits for BPA and BPS i.e., 1 mg/kg. To avoid situations where one hazardous bisphenol is replaced with another, we in addition encourage the Commission to introduce specific concentration limits for all bisphenols which meets the criteria for classification as CMR category 1A/1B.
- Polycyclic-aromatic Hydrocarbons (PAH): we recommend relying on the lower limit set out by the German Federal Institute for Occupational Safety and Health. This limit is specifically established in view of the particular vulnerability of children whereas the existing REACH restriction primarily is meant to protect the general population. Evidence from our members’ tests also broadly confirms that it is possible for economic operators to comply with this lower limit and that it therefore would be enforceable.
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Exemptions (point 4): Second-hand childcare products: we recommend aligning the restriction with the EU Toy Safety Regulation which notably applies to “new toys made by a manufacturer established in the Union and to toys, whether new or second-hand, imported from a third country and placed on the Union market.” (see recital 11, our emphasis). This approach would thus ensure both consistency with other Union legislation as well as a high level of protection of children’s health from CMR 1A/1B substances present in imported second-hand childcare products – while also ensuring that the consumer does not become responsible for compliance when buying or selling such articles.
- Inaccessible parts: to adequately protect children’s health, the restriction should be aligned with the EU Toy Safety Regulation i.e., the exemption in point 4 should be limited to “components necessary for electronic or electric functions […] where the substance or mixture is fully inaccessible to children, including by inhalation.” (see Annex II, Part III, Point 9 of Regulation (EU) 2025/2509).
- Medical devices: Regulation (EU) 2017/745 allows the presence of CMR 1A/1B substances in devices intended to come into direct contact with the human body up to 0.1% (w/w). This default limit is however too high to adequately safeguard children’s health. We therefore recommend that the proposed exemption for medical devices is reformulated i.e., the restriction should apply to childcare products that are also medical devices unless a derogation is justified according to Section 10.4 of Annex I to Regulation (EU) 2017/745.
- Food contact materials: we do not support the proposed exemption for substances in childcare products within the scope of Regulation (EC) No 1935/2004. Most food contact materials other than plastics are not subject to harmonised EU rules. As evidenced by the 2020 Commission evaluation, this implies that the safety of CMR substances present in non-plastic materials are not sufficiently ensured. For plastic materials, the evaluation likewise concluded that risk assessment and management of authorised substances is not always assured, in part because the most up-to-date science is not routinely incorporated into the regulatory process while it is also unclear whether vulnerable populations are sufficiently addressed. Accordingly, we recommend deleting the exemption. Where stricter limits for childcare products are established under Regulation (EC) No 1935/2004 or other Union legislation, those limits should however prevail over the restriction, cf. point 5.
Transitional measures: Entry into application: children should benefit from the proposed new safeguards as soon as possible. Therefore, we encourage the Commission to reduce the transition period from 36 to 18 months. Many economic operators already adhere to voluntary schemes that establish strict concentration limits or bans for CMR 1A/1B substances in childcare products i.e., an 18-months transition period will be sufficient since the restriction as noted by ECHA is in line with the common practice and procedures implemented by manufacturers of materials used for childcare products.
- For newly classified substances, we recommend aligning the proposed transition period in point three with the entry into application of new harmonized classifications i.e., 12 to 18- months. This approach would be consistent with the EU Toy Safety Regulation while also ensuring sufficient time for the Commission to implement – if relevant – specific concentration limits for newly classified CMR substances.
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The EU must safeguard children against all harmful chemicals
As noted in the draft restriction, the Chemical Strategy for Sustainability commits the Commission to ensure the safety of children from hazardous chemicals in childcare articles and other children’s products by providing at least the same level of protection as in toys.
EU toy safety legislation protects children’s health against further hazardous substances in addition to CMR 1A/1B substances i.e., the EU Toy Safety Regulation prohibits the presence in toys also of CMR 2 substances, endocrine disruptors for human health, substances targeting a specific organ, as well as respiratory and skin sensitisers. Product tests by our members meanwhile show that such chemicals are widely present in children’s products.
To adequately safeguard children’s health, we therefore strongly encourage the Commission to initiate work on a complementary restriction proposal to prevent children’s exposure to CMR category 2 substances, endocrine disruptors and other hazardous chemicals in childcare products.
Signature: InfoCons Communication Department
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