Deeenamic Insights

Toy Safety Regulation: ECHA’s New Role in Chemical Safety Assessments : Deenamic Ltd

Deenamic — Wed, 19 Aug 2026 08:54:37 GMT

The EU’s new Toy Safety Regulation (TSR) entered into force in January to strengthen the way chemical risks in toys are assessed across the EU. The European Chemicals Agency (ECHA) will now play a central role in evaluating chemical safety in toys. The Regulation aims to strengthen protection for children by introducing stricter requirements, improved product transparency and enhanced oversight of toys sold both online and through traditional retail channels.

What’s Changed: ECHA’s New Responsibilities

Under the Toy Safety Regulation, ECHA will assess chemical risks in toys and evaluate requests from companies seeking permission to use substances otherwise restricted under the Regulation.
Through these activities, ECHA will help determine whether specific uses of chemicals in toys can be considered acceptable under the new regulatory framework.

Why This Matters

For manufacturers, importers and supply-chain actors, the changes represent a shift in how chemical risks in toys are assessed and governed. In practical terms, companies can expect greater scrutiny of the chemical substances used in toy materials and components.

Practical Considerations for Industry

Organisations involved in manufacturing or placing toys on the EU market should consider how their internal processes align with the requirements of the new Regulation.

Key considerations may include:

• reviewing product formulations to determine whether substances fall within newly restricted categories
• ensuring robust internal processes are in place to manage obligations under the Toy Safety Regulation
• strengthening supply-chain transparency to ensure visibility of chemical substances used in materials and components
• aligning internal compliance systems with best practice to demonstrate due diligence and regulatory preparedness
• ensuring processes are in place to respond to consumer enquiries regarding the presence of Substances of Very High Concern (SVHCs) within the required regulatory timelines
• ensuring internal data, testing strategies and supplier communication support regulatory assessments

Establishing clear internal governance processes will be particularly important where legacy substances or complex formulations are involved.

Deenamic Insight

Consistent engagement with evolving regulatory requirements can significantly reduce downstream compliance risks. Recent product recalls linked to chemical safety concerns in consumer products illustrate how regulatory scrutiny across product categories has been ongoing and is likely to intensify further for toys. Such cases highlight the importance of robust internal processes for substance identification, supplier communication and regulatory compliance.

As ECHA’s role under the Toy Safety Regulation develops, organisations that align scientific, regulatory and strategic considerations early in the product lifecycle will be better positioned to manage regulatory expectations, respond to market scrutiny and maintain continuity of supply.

“ECHA’s new responsibilities require us to perform rigorous scientific assessments and provide clear advice on the safe use of chemicals in toys. Through this work, we will contribute to the protection of children’s health across the EU.”

— Peter van der Zandt, Director for Risk Management, ECHA

The Toy Safety Regulation represents an important step in strengthening chemical safety governance for children’s products in the EU. Sound regulatory strategy will be key for organisations navigating this evolving regulatory landscape.

Poison Centre Notifications: What Recent EU Enforcement Findings Mean for Industry : Deenamic Ltd

Deenamic — Wed, 19 Aug 2026 08:53:59 GMT

Recent enforcement activity coordinated by the European Chemicals Agency (ECHA) highlights ongoing challenges in meeting Poison Centre Notification (PCN) obligations. Under the CLP Regulation, PCN is a requirement intended to ensure that medical professionals can quickly access product information during exposure incidents.

What’s Changed: Enforcement Findings

Of over 1,500 hazardous mixtures placed on the market, it was found that approximately 19% had not been notified to poison centres as required under CLP Annex VIII. Meanwhile, 15% of products inspected did not display a Unique Formula Identifier (UFI) on the label as required. The UFI is a critical link between a product placed on the market and the mixture information submitted to poison centres.

Why This Matters

These regulatory measures are intended to enable rapid identification of chemical composition during emergency response. With approximately one in five hazardous mixtures placed on the market not being adequately notified, this represents a significant impediment to coordinated medical response in the event of an exposure incident.

As Chris Van den Hove, Chair of the enforcement project working group, noted:

“Missing notifications of the necessary information to poison centres undermine the effectiveness of emergency response. Inspectors take these findings very seriously and initiated numerous enforcement actions to bring companies into compliance.”

While this level of non-compliance is concerning in itself, the findings also suggest that approximately 4% of products displayed a Unique Formula Identifier (UFI) despite the associated Poison Centre Notification (PCN) not having been completed. This creates a particularly challenging scenario, as the presence of a UFI may give the impression that the relevant compliance steps have been fulfilled while poison centres may not yet have access to the necessary composition data.

In practice, this means that some products may appear compliant at first glance while a critical regulatory step remains outstanding. For actors across the supply chain, this creates a potential visibility gap when assessing whether the products they manufacture, distribute or trade fully meet regulatory requirements.

Implications for Supply Chain Due Diligence

The findings also highlight an important consideration for organisations operating across complex supply chains. The presence of a UFI on a product label should not automatically be interpreted as confirmation that all Poison Centre Notification obligations have been fulfilled. As a matter of good practice, organisations trading hazardous mixtures may wish to request confirmation from suppliers that the relevant PCN submission has been completed and review supporting regulatory documentation. Strengthening internal verification processes can help ensure that products placed on the market meet regulatory requirements and that poison centres have access to the information necessary to support effective emergency response.

Practical Considerations for Industry

In light of the enforcement findings, organisations placing hazardous mixtures on the EU market may wish to review whether their internal compliance processes adequately address Poison Centre Notification obligations under the CLP Regulation. CLP applies to consumer, industrial and professional-use products and thus the potential compliance impacts are widespread. Key considerations may include:

• confirming that all hazardous mixtures placed on the market have been notified through the Poison Centre Notification (PCN) portal
• ensuring consistency between mixture composition data, Safety Data Sheets and Poison Centre Notifications

• verifying that any Unique Formula Identifier (UFI) appearing on product labels corresponds to a completed Poison Centre Notification
• strengthening internal processes linking formulation data, regulatory submissions and product labelling
• improving supply chain transparency so that distributors and downstream users can verify regulatory compliance status

These considerations relate specifically to the findings of the enforcement project; however, organisations should also ensure that broader regulatory obligations, including those arising under REACH and other applicable product legislation, are addressed.

Deenamic Insight

This review highlights the importance of close alignment between formulation data management, regulatory submissions and product labelling processes, as fragmentation across these functions can lead to gaps in compliance implementation. The possibility that some products carry a UFI while the associated notification remains incomplete illustrates how products may appear compliant while key regulatory steps remain outstanding.

In practice, the same underlying data management and supply chain transparency challenges can also affect compliance under related regulatory frameworks, including REACH and other product legislation.

Future enforcement projects coordinated by ECHA and national authorities will continue to highlight key compliance priorities across the EU chemicals framework. These developments will be explored further in future regulatory updates.

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Microplastics reporting deadline - 31st May 2026 : Deenamic Ltd

Deenamic — Wed, 19 Aug 2026 08:53:22 GMT

The first annual reporting deadline for synthetic polymer microparticles (SPMs) is approaching on 31 May 2026. Companies affected need to prepare the report on annual releases in IUCLID format and submit it to ECHA through REACH-IT. The first deadlines are:

31 May 2026 – for manufacturers and industrial downstream users of SPMs in form of pellets, flakes and powders, used as raw material in plastic production at industrial sites; and
31 May 2027 – for all other manufacturers and industrial downstream users of SPMs at industrial sites, as well as for suppliers placing products containing SPMs on the market for the first time for specific exempted uses (medicines, food additives, in vitro diagnostic devices, and other specified uses)

Navigating the SPM reporting format presents a steep learning curve, with its specialised terminology, complex structure, and highly interconnected data fields. ECHA’s 2024 Annual Work Report recorded 669 dossier failures for comparable submissions. While ECHA encourages companies to familiarise themselves with guidance materials and support tools well in advance of reporting deadlines, this expectation highlights the significant practical burden placed on the polymer sector — particularly for organisations with limited prior experience of ECHA systems or IUCLID.

Deenamic has developed technology-enabled workflow solutions to support SPM reporting by streamlining data preparation, improving consistency and reducing administrative friction. These approaches provide practical support for meeting reporting obligations while enabling more effective emissions tracking, data governance, and environmental stewardship.

If you would like to discuss how these developments may affect your products or regulatory strategy, you can contact us for a preliminary consultation at info@deenamicltd.com.

Toy Safety Regulation: ECHA’s New Role in Chemical Safety Assessments : Deenamic Ltd

Deenamic — Fri, 06 Feb 2026 14:30:00 GMT

Ensuring the safety of toys sold in the EU increasingly depends on robust chemical oversight. With the entry into force of the new EU Toy Safety Regulation (TSR) on 1 January, the European Chemicals Agency (ECHA) has assumed expanded responsibilities that will significantly shape how chemical risks in toys are assessed and managed.

The Toy Safety Regulation aims to strengthen protections for children by introducing stricter standards for chemical safety, enhanced product transparency, and increased digital accountability for toys sold both online and in physical stores across the EU.

What’s Changed: ECHA’s New Responsibilities

Under the Toy Safety Regulation, ECHA will work closely with the European Commission to:

Conduct chemical safety assessments of substances used in toys at the request of the Commission, supported by expert opinions from the Committee for Risk Assessment (RAC)
Evaluate derogation requests from companies seeking permission to use substances otherwise prohibited under the Regulation
Provide assessments for derogations through both RAC and the Committee for Socio-Economic Analysis (SEAC)

Through these activities, ECHA will contribute directly to determining whether specific chemical uses in toys can be considered acceptable under the new regulatory regime.

Why This Matters

These changes represent a meaningful shift in how chemical risks in toys are assessed and governed in the EU.

For manufacturers, importers, and supply-chain actors, the Regulation introduces:

Increased scrutiny of chemical composition
Higher expectations for scientific justification where derogations are sought
A clearer role for expert committee opinions in regulatory outcomes

For regulators and policymakers, ECHA’s involvement ensures that decisions are underpinned by rigorous, transparent scientific evaluation, supporting consistent protection of children’s health across the EU.

Practical Considerations for Industry

Organisations involved in the manufacture or placing on the market of toys should consider:

Whether substances used in products fall within newly restricted categories
The potential need to prepare robust derogation dossiers, including hazard, exposure, and socio-economic justifications
How internal data, testing strategies, and supply-chain communication support regulatory defensibility
Early engagement with regulatory expertise to anticipate assessment expectations under RAC and SEAC review

Proactive planning will be particularly important where legacy substances or complex formulations are involved.

Deenamic Insight

Experience across EU regulatory frameworks shows that early, well-structured engagement with evolving requirements significantly reduces downstream risk. As ECHA’s role under the Toy Safety Regulation develops, organisations that align scientific, regulatory, and strategic considerations from the outset will be best positioned to maintain compliance and continuity of supply.

According to the European Chemicals Agency, “ECHA’s new responsibilities require us to perform rigorous scientific assessments and provide clear advice on the safe use of chemicals in toys. Through this work, we will contribute to the protection of children’s health across the EU.”
— Peter van der Zandt, Director for Risk Management, ECHA
(Helsinki, 7 January 2026)

The Toy Safety Regulation marks an important step in strengthening chemical safety governance for children’s products in the EU. With ECHA now playing a central role in scientific assessment and derogation evaluation, clarity, preparedness, and sound regulatory strategy will be key for organisations navigating this evolving landscape.

If you would like to discuss how these developments may affect your products or regulatory strategy, get in touch to start a conversation.

You can contact us for a preliminary consultation at info@deenamicltd.com or use the form below.

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