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Entry 51 and 52 of Annex XVII to REACH - Phthalates in toys and childcare articles
Do blankets and objects to facilitate the transport of children fall within the scope of Entries 51 and 52 of Annex XVII?
The Guideline on the concept "which can be placed in the mouth" [See Q&A 748], provides certain clarifications concerning the types of childcare articles within the scope of Entries 51 and 52 of Annex XVII. For instance, sleeping bags are claimed to be articles designed to facilitate sleep, and should therefore fall under the scope of Entries 51 and 52. In addition, the guidance document explicitly contains a photo of a mattress cover which is considered as childcare articles, also explaining that certain parts (e.g. mattress protectors) can be placed in the mouth by children. [See Q&A 675].
Blankets are, in nature, articles similar to mattresses as both used in bed to facilitate the sleeping of children and therefore can be claimed to meet the broad definition of childcare articles. Furthermore, since blankets can be commonly placed in mouth by children, these can be considered within the scope of both Entries 51 and 52 of Annex XVII.
The Guideline clarifies that "entry 52 of Annex XVII on what can be placed in the mouth by children also covers the accessible parts of articles such as push chairs, car seats, sleeping bags and bike seats which are intended to facilitate sleep and relaxation during transport". Given that child seats and items which are used for transportation of children are quite similar in function and design to the above mentioned types of articles, they can be broadly considered as childcare articles [See Q&A 983]. In addition, it is noted that pictures of such types of childcare articles are also provided at the end of the Guideline. Over there, examples of mouthed items of such articles are provided to assist enforcers conclude whether they fall (or not) under the scope of entry 52.