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REACH

Restrictions

Entry 20 of the Annex XVII to REACH - Organostannic compounds

(a) Do toys fall within the scope of the dioctyltin (DOT) compounds restrictions of entry 20 (paragraph 6)? (b) Can toys benefit from the derogations for organotins in entry 20 of the Restriction List (Annex XVII)? (c) Would a paint coating on a toy that contains dibutyltin (DBT) as a biocide and not as a catalyst fall within the derogation?

(a) Yes, they do. Entry 20 in the Restriction List (Annex XVII) to REACH imposes DOT compounds restrictions for childcare articles, which are not toys. The REACH Regulation does not contain a definition of toys. The definition of toys in Directive 2009/48/EC on the Safety of Toys is illustrative in determining what should be considered as a “toy” in the context of this restriction (see Q&A 0982).

However, paragraph 6(a) of entry 20 restricts DOT compounds in textile toys as in any other textile article intended to come into contact with the skin. Furthermore, organic tin (including DOT) in toys is restricted by paragraph 13 of Part III (Chemical Properties) of Annex II to Directive 2009/48/EC on the safety of toys, which specifies maximum migration limits.

(b) and (c)

In addition to derogation in paragraph 5(d), the other derogations currently applicable to TBT, DBT and DOT compounds in articles relate to the continued placing on the market of articles that were already in use in the EU before the 1 July 2010 for TBT (paragraph 4(b), before the 1 January 2012 (paragraph 5(b)) for DBT and before the 1 January 2012 for DOT (paragraph 6(b)).

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