TRANSPOSITION OF DIRECTIVE 2020/2089/EU by DM 30 JUNE 2022

Directive 2009/48/EC, in Annex II, establishes a general ban on the use of 55 allergenic fragrances in toys, which are listed in the table in Annex II, Part III, point 11, first paragraph, of the same directive, to protect children from the allergies which these fragrances may cause when used in toys.

A survey of allergenic substances in children's products conducted by the Danish Environmental Protection Agency found allergenic fragrances in toys (modelling clays, slime, doll, teddy bear and rubber bands).

An allergenic substance always remains an allergenic substance regardless of whether it is found in cosmetic products or toys. This "intrinsic property" of the substance is independent of its use and therefore exists regardless of whether the allergenic substance is used in cosmetic products or toys.

DM 30/06/2022 implements Commission Directive 2020/2089/EU of 11/12/2020 amending Annex II of Directive 2009/48/EC of the European Parliament and of the Council regarding the ban on allergenic fragrances in toys.

In particular, the Decree brings important changes:

Annex II Part III first paragraph of DL 11/04/2011 No. 54, the following entries are added to the table.


In Annex II part III third paragraph of DL 11/04/2011 No. 54, item 10 in the table is deleted.

These provisions shall apply from 5/07/2022