Restriction on CMRs in childcare articles

This initiative aims to protect children from carcinogenic, mutagenic or reprotoxic (CMR) substances that may be present in childcare articles (such as products intended to facilitate sleep and relaxation, products for the hygiene, feeding or sucking of children) by banning them.

Filed in Italian · English published by the European Commission

The Federal Office for Standardisation welcomes the opportunity to submit an opinion in support of the draft REACH restriction for CMR substances of categories 1A/1B in Child Care products and refers to the attached position paper.

Filed in German · English published by the European Commission

Bisphenols Europe, representing EU manufacturers of BPA, BPS and BPF, fully supports the objective of protecting childrens health and safety. To ensure this objective is achieved effectively, the proposed REACH restriction would benefit from further refinement to improve clarity, consistency and proportionality. Main concerns.

It is commendable to limit the content of CMR substances in childcare products. However, this should be done through a feasible, enforceable regulation that does not create legal uncertainties. The scope covers more than 1,000 individual substances and substance groups which are listed as relevant CMR substances under the CLP Regulation.

GROUPHYGIENE is the French professional association representing manufacturers of singleuse products for hygiene, health and wiping applications, such as tissuebased hygiene products (toilet paper, paper towels, facial tissues, table range, paper hand towels, wiping articles, etc.) and absorbent hygiene products (baby diapers, sanitary pads, tampons, incontinence products, etc.) available on the French market.

Toy Industries of Europe (TIE) are grateful for the opportunity to comment on the Commissions proposed restriction on childcare articles under the REACH Regulation. Since toys are a product category that is adjacent to childcare articles, and in some cases, products may sit in a grey zone between the two, it is important to clarify that toys are entirely covered by requirements in specific legislation and are out of…

EDANA, the trade association representing manufacturers of hygiene products, including baby diapers and baby wipes, and other nonwovens-based applications, fully supports the European Commission's objective of protecting children from CMR substances in childcare products.

textil+mode supports the objective of protecting children from CMR 1A/1B substances in childcare products. Our comments therefore do not concern the objective of the proposal, but its practical implementation. As set out in the attached statement, the proposed restriction should be revised to ensure that it can be implemented by companies and enforced by authorities.

EFIC supports the objective of ensuring a high level of protection of human health, particularly for children, and welcomes the establishment of a harmonised EU-wide approach to the restriction of CMR 1A/1B substances in childcare products under REACH.

We support the proposed restriction on CMR 1A and 1B substances in childcare products and agree with the amending Annex XVII proposition of Reach Regulation presented by the Commission regarding the need to provide a high level of protection for children. However, we would like to draw attention to the broader regulatory context in which this restriction will be implemented.

ChemSec welcomes and supports in general the proposed restriction of CMR substances in childcare articles. We urge the REACH Committee to conclude swiftly and the Commission to adopt the restriction as soon as possible. We support the dynamic link to CLP which makes the restriction effective, preventative and forward looking.

Consumentenbond, the Dutch consumer organisation representing consumers interests, welcomes the opportunity to provide input on the draft REACH restriction concerning CMR category 1A and 1B substances in childcare products. Unlike toys, childcare products are currently not subject to equivalent EU rules that adequately protect children from exposure to these harmful substances.

ClientEarth supports the European Commissions proposal to ban CMRs in childcare products. We urge the Commission to prioritize the highest level of protection for children above all other considerations. Additionally, the proposed exemptions require refinement, and further restrictions are necessary to ensure childcare products meet the same stringent safety standards as those set by the Toy Safety Regulation.

The Ordine Interprovinciale dei Chimici e dei Fisici del Veneto, i.e. the Veneto Professional Chamber of Chemists and Physicists, hereinafter referred to as the Order, represents licensed Chemists and Physicists working in sectors including research, industry, analytical laboratories, healthcare, environmental protection, product safety and technical-scientific consultancy.

Vienna Ombuds Office for Environmental Protection welcomes the opportunity for submitting feedback on the commission proposal of Draft regulation Ares (2026) 4697089 and draft Annex Ares (2026) 4697089 regarding CMR substances in childcare products. With that respect please find attached our detailed feedback.

The Food Packaging Forum Foundation (FPF) welcomes the opportunity to comment on the draft amendment to Annex XVII of Regulation (EC) No 1907/2006 (REACH) concerning the restriction of CMR substances in childcare articles.

Assogiocattoli, the leading national association for the toy and childcare products sector, wishes to submit the following comments to the European Commission regarding the proposed amendment to Annex XVII of the REACH Regulation, concerning the introduction of a generic concentration limit of 10 mg/kg in homogeneous materials of products intended for children for substances classified as CMR in categories 1A and…

ENPC supports measures that strengthen the protection of children from hazardous substances, including CMR substances in childcare articles. At the same time, the effectiveness of any restriction depends not only on its protective ambition, but also on whether it is proportionate, technically achievable, enforceable, and aligned with existing product safety and chemicals legislations.

Plastics Europe PC-group submission This input is provided by the Polycarbonate Product Group of Plastics Europe (PC-group). Its members comprise manufacturers and compounders of polycarbonate (PC) in the EU (Covestro, Sabic, Trinseo). We also refer to the Cefic Bisphenols sector group entry. We support targeted regulation to protect vulnerable consumer groups.

The Danish Consumer Council welcomes the Commission proposal to ban CMR 1A/1B substances in childcare products. Childcare products constitute a significant potential source of children's exposure to CMR substances.

UL Solutions feedback on the draft Regulation on Childcare articles restriction on substances classified as carcinogenic, mutagenic or toxic for reproduction (CMR) UL Solutions supports the objective of improving protection of children from exposure to substances classified as carcinogenic, mutagenic or toxic for reproduction (CMR) category 1A or 1B in childcare products.

As an Industrial Chemistry graduated, working in the plastic compound production since 24 years ago, specifically in Polyamides and Polyester families, I would like to support any sort of action which might prevent children to get in touch with any hazardous chemicals on products engineered for them and used by them for a large part of their life, especially in the first 6 years, when they are more vulnerable.

We support the objective of protecting children from hazardous chemicals in childcare products. However, the draft should be refined to ensure its practical implementation. No. 1 The scope of the restriction should be limited to specifically identified substances The restriction should focus on substances that require control in childcare products, rather than all current and future CMR category 1A or 1B substances…

The Consumer Unit of the Austrian Federal Chamber of Labour welcomes the Commission proposal to ban CMR 1A/1B substances in childcare products. According to ECHA, childcare products are a significant and largely unregulated source of childrens exposure to toxic chemicals. Also tests by European consumer groups regularly show hazardous chemicals are widely present in childrens products.

DECO welcomes the European Commission's proposal to ban CMR 1A/1B substances in childcare products. As extensively documented by ECHA, such products represent a substantial and largely unregulated pathway through which children may be exposed to CMR 1A/1B substances.

Toys are a product category adjacent to childcare articles and there are products that are sometimes in a grey area of the two categories. It is therefore essential to clarify that toys are excluded from the scope of this regulation or that this regulation does not apply to toys.

Filed in German · English published by the European Commission

ANEC, the European consumer voice in standardisation, appreciates the opportunity to submit input in support of the draft REACH restriction on CMR 1A/1B substances in childcare products. In contrast to toys, current EU legislation does not adequately protect children from exposure to CMR substances in these products.

BEUC welcomes the opportunity to provide comments in support of the draft REACH restriction on CMR 1A/1B substances in childcare products (please see enclosed). Unlike toys, existing EU legislation regulating childcare products is insufficient to safeguard childrens health against CMR substances. As such, we strongly support the proposed restriction as an essential safeguard of childrens health.

Scope and field of application In the current draft, under paragraph 2 of the Annex, there is the following definition of childcare product: childcare product means any product, other than a substance on its own or in a mixture, designed to facilitate seating, sleep, relaxation, hygiene, feeding, sucking, transportation or protection of children.

Please consider the attached document, which sets out the opinion on the CMR restriction, as part of the present review and decision-making process. Given its relevance to the matter under assessment, we respectfully request that it be taken into account in full when evaluating the applicable regulatory and technical considerations.

CHEM Trust welcomes the opportunity to submit comments regarding the proposed restriction of CMRs in childcare products. Children are particularly vulnerable to hazardous chemicals, and the current EU rules are insufficient to protect childrens health from CMR substances in childcare articles.