EU Proposes to Amend REACH Annex XVII to Restrict CMR 1A/1B Substances in Childcare Articles

On May 8, 2026, the European Union submitted a formal notification (G/TBT/N/EU/1206) to the WTO Committee on Technical Barriers to Trade, proposing to amend Annex XVII of the REACH Regulation to prohibit the use of chemicals classified as carcinogenic, mutagenic or toxic to reproduction (CMR) categories 1A and 1B in childcare articles. The draft is currently open for comments from WTO members, with the deadline for public comments set for July 7, 2026.

Main Provisions

1. Product Scope

Childcare articles: Products intended for use by children, other than toys, designed to facilitate seating, sleeping, relaxation, hygiene (bathing, changing, body care), feeding, sucking, transportation or protection.

2. Core Restrictions

• Default limit: The concentration of CMR substances in homogeneous materials shall not exceed 10 mg/kg (0.001%).
• Specific limits: More stringent individual or cumulative limits are set for certain substances (e.g., dibutyltin (DBT), dioctyltin (DOT)).
• Dynamic updating: Substances newly classified as CMR 1A/1B in the future will be automatically included in the restriction scope 36 months after their classification takes effect.

3. Exemptions

• Second-hand products: Second-hand childcare articles already lawfully placed on the market are not subject to the restriction.
• Medical devices: Products and their accessories falling within the scope of the Medical Devices Regulation (EU) 2017/745.
• Food contact materials: Products governed by the Food Contact Materials Regulation (EC) 1935/2004.
• Inaccessible parts: Substances contained in homogeneous materials that children cannot access in any form under reasonably foreseeable conditions of use.

4. Implementation Timeline

The regulation will become formally applicable 36 months after its entry into force, to allow companies to complete method development, identify substitute substances, and deplete existing stock.

About the CIRS Group

Established in China in 2007, the CIRS Group is a global product safety and regulatory consultancy with a strong presence across the UK, EU, Asia, and the United States.

CIRS provides end-to-end regulatory compliance solutions for the chemical industry, including UK/EU REACH, GB/EU CLP, global GHS compliance, SDS authoring, and chemical risk management. Our multidisciplinary services also include laboratory testing, regulatory strategy, product stewardship, R&D support, and global market access consulting.

With extensive expertise in both Europe and Asia-Pacific regulatory systems, CIRS helps businesses reduce compliance risk, improve operational efficiency, and accelerate access to international markets across chemical, biocides, cosmetics, food, and consumer goods.

If you need any assistance or have any questions, please get in touch with us via service@cirs-group.com.

Further Information

Document