Chemical Migration in Wooden Toys

Reviewed 29 October 2026. This is a buyer guide, not legal advice.

Where chemicals enter a wooden toy

Chemical compliance is a material question before it is a testing question. Two toys can share the same shape and the same factory and still have different chemical profiles, because the paint, glue, board, cord or printed insert changed. The practical starting point is a bill of materials that names every material and every supplier, not just the species of wood.

The last row is easy to miss. A printed card that a child is expected to handle is part of the toy for safety purposes, while a plain outer carton is packaging. The classification changes which evidence belongs in the toy file.

EN71-3 in plain terms

EN71-3 deals with migration, not total content. The test simulates what a child could dissolve from the material in the digestive tract and measures the amount of certain elements that passes into the extraction solution. That is why a part can contain a substance and still meet a migration limit, and why a part with a low total content can still fail if the substance is easily released.

• The result depends on the material category. The standard separates dry and brittle materials, liquid or sticky materials, and scraped-off material such as coatings, and applies different limits to each. A painted wooden block therefore has more than one relevant surface.
• The scope is elemental. The standard covers a defined list of elements, including lead, cadmium, mercury, arsenic, chromium and others, rather than every possible organic chemical.
• Sample preparation matters. The laboratory has to test the coating as applied, not the liquid paint, and has to identify which part of the toy the result belongs to.
• Age grading matters. A toy intended for a younger group is used differently, and the choice of test method and evaluation has to match the actual age grade on the label.
• The report has a scope. A report for a red painted car does not automatically cover a blue painted train, a different board or a different clear coat.

Ask the laboratory to state the material tested, the colour, the supplier batch and the part identity. A report that only names the finished SKU is difficult to defend when the paint supplier changes and nobody can tell which result still applies.

REACH and the SVHC candidate list

REACH is not a single test. It is a framework with restrictions, authorisation and communication duties. For a wooden toy the three practical threads are restricted substances, substances of very high concern and the information that has to pass along the supply chain.

Restricted substances

Annex XVII of REACH restricts or conditions the use of specific substances in articles. The list changes, so a declaration that was correct three years ago is not proof of today's position. The relevant question is not "is the toy REACH compliant" in the abstract, but which entries apply to the materials actually used and what evidence supports each one.

SVHC communication

Where an article contains a candidate-list substance above 0.1% by weight of that article, the supplier has to give the recipient enough information for safe use, and a consumer can ask for it. The candidate list is updated periodically, so the declaration needs a date and a method, not only a tick box.

For EU-market supply, the SCIP database is part of the picture for articles containing candidate-list substances. The notification is normally made by the EU supplier that places the article on the market. A Chinese factory can supply the part and material data but does not replace that EU obligation.

Formaldehyde and wood-based panels

Plywood, MDF and HDF bring resin chemistry into the file. Buyers commonly ask for the board grade and a formaldehyde release declaration, and some markets apply their own panel rules in addition to the EU framework. The declaration should identify the board supplier and the class, because the same factory can buy boards from more than one mill.

Changes that should trigger a new review

Most chemical failures do not come from a new factory. They come from an unannounced substitution inside an approved product. Treat the following as change-control events rather than purchasing details:

• A new paint, lacquer, primer or ink supplier, or a new colour in an existing range.
• A new adhesive, or a change from one board grade or mill to another.
• A new plastic, masterbatch, cord or metal fastener supplier.
• A move of production line, sub-contractor or spray booth.
• A formulation change notified by a chemical supplier, even when the product code stays the same.
• A change in the age grade, the intended use or the market where the toy is sold.
• A new decoration method, such as a transfer, a laser etch or a printed film that was not in the original sample.

The useful control is a written change notification with a material code and a date, plus a rule that the chemical file is re-checked before the first shipment of the changed build. Without that rule, the test report becomes a historical document rather than a statement about the goods in the container.

The document pack a buyer should hold

Keep the documents together and keep them dated. A file that can be read as a set is more useful in an audit than a folder of reports from different years with no note on which build each one covers.

What BETTERMU can supply

• A material and component BOM for the build being quoted, with supplier codes for wood, board, coating, adhesive, cord and hardware.
• Supplier SDS and material declarations collected against that BOM, including panel grade and coating batch information.
• Test coordination with accredited laboratories for EN71-3 and the other EN71 parts that apply to the toy, with the tested material and colour stated in the report.
• Dated SVHC and heavy-metal declarations based on supplier information, with the parts and candidate-list version identified.
• Written notification when a material, colour, supplier or production line changes before the affected goods ship.

We do not issue the chemical supplier's own SDS, sign the importer's Declaration of Conformity or act as the EU responsible person. Those documents and roles belong to the parties that hold them.

Buyer checklist: eight questions before you approve

1. Does the BOM name every material and supplier, including paint, glue, board and cord?
2. Does the EN71-3 report state the material, colour and part tested, not only the SKU?
3. Is there a dated SVHC declaration that names the candidate-list version and the parts assessed?
4. For wood-based panels, is the board grade and formaldehyde release class documented?
5. Are heavy-metal statements on file for every coating and ink used on a child-accessible surface?
6. Does the file explain how a material or supplier change is notified and re-reviewed?
7. Is the age grade consistent across the label, the instructions and the test scope?
8. Can the factory trace a tested batch to the production records for the goods being shipped?

Related: EN71 for wooden toys · Battery-powered wooden toys · GPSR for wooden toys · Toy safety standards · Factory audit checklist · Request a quotation