REACH stands for the Registration, Evaluation, Authorisation and Restriction of Chemicals. REACH came into force on 1st June 2007 and the central aim of the legislation is to reduce risks to human health and the environment from the use of chemicals. The Directive intends to make companies that place articles, substances and mixtures on the market (the importer) responsible for understanding and managing the chemical risks associated with their use. It also ensures that companies are aware of the substance content of chemical mixtures and articles.

REACHReady is available to assist BTHA members with REACH, CLP and BPR needs at a 25% discount off a REACHReady Gold Membership. For more information and to subscribe email to

The BTHA has produced guidance on REACH for toy manufacturers in the following areas considered to concern toy companies.

The BTHA Overall Guide covers the following areas:

  • Operator Roles
  • Reach Definitions
  • Safety Data Sheets
  • Registration of substances
  • Annex XIV
  • Annex VII
  • Substances of Very High Concern


Imminent restriction on Microplastics under the EU REACH Regulation

After many delays, an agreement on the EU Commission’s proposal for a restriction for microplastics in REACH Annex XVII was reached and published in the Official Journal of the European Union.

Annex XVII of REACH has been amended by regulation 2023/2055 to restrict the placing on the market of microplastics on their own and in mixtures. The requirements apply from 17 October 2023. Products that are already on the market will not be affected. Later in-force dates apply for cosmetic products and encapsulated fragrances.

SCIP database

There is an existing obligation to communicate the presence of SVHCs in articles along the supply chain and to consumers upon request. The amendment to the Waste Framework Directive (EU) 2018/851 (WFD) generated an additional requirement to upload the presence of SVHCs in products above 0.1% to the ECHA SCIP database. The BTHA has produced a short guide outlining obligations for this companies supplying goods into the EU from 5th January 2021. Since this implementation date is after the UK has left the EU, this guidance explains the impact on UK based companies and the effect of Brexit on their obligation to submit SCIP notifications.


This subject is covered in the main guide and in addition the BTHA has published a full searchable Excel spreadsheet detailing all the SVHC’s on the website which can be used in conjunction with this guide. The spreadsheet includes a summary of the SVHC’s which are considered to be at a High, Medium or Low risk of being found in toys. The spreadsheet will show how many SVHC’s have been analysed at the date of use. It is checked and if necessary updated three times each year.

Each SVHC has been categorised by its likely risk for inclusion in an article above the 0.1% limit.


This REACH ANNEX XVII guide is intended to help with the substance restrictions under Annex XVII of REACH only.

Please note that Annex XVII of REACH has been amended by regulation 2023/2055 to restrict the placing on the market of microplastics on their own and in mixtures.  For more information see the Microplastics section above

It is important to note that this guide only covers the Annex XVII substances that are considered to be at risk of being found in typical toys.  However, the use of unusual materials or applications may mean unexpected substances could be found. Users should always refer back to the original legislation and may need to take expert third party advice.

In writing this guide, all entries in Annex XVII have been assessed. Certain entries are not relevant to toy products and are not covered by this guide. These include those that are not ever used or found in typical toys, those restricted in materials or products not used in toy products (e.g. paint strippers), and those entries that specifically exclude toys. For this reason, it is not recommended that this guide is used for non-toy products.