On June 4, 2026, the Food Packaging Forum (FPF) submitted comments to the European Commission’s public consultation on its draft amendment to Annex XVII of REACH ((EC) No 1907/2006) (FPF reported). The proposed amendment “aims to protect children from substances that are carcinogenic, mutagenic or toxic for reproduction (CMR) and may be present in childcare articles (such as products intended to facilitate sleep, relaxation, hygiene, the feeding of children or sucking on the part of children).”
In its submission, FPF welcomed the proposed restriction on CMRs in childcare articles, noting that for many products such restrictions currently do not exist and that the measure would therefore add a layer of protection for children in Europe.
However, FPF highlighted inconsistencies in regulatory approaches and limits compared with existing EU legislation, including on toy safety ((EU) 2025/2509) and plastic food contact materials (FCMs) ((EU) No 10/2011). Notably, the proposed restriction could allow higher concentrations of the same CMR substances in certain childcare articles than are permitted under existing EU legislation for other children’s products. “Given their well-established mouthing behavior, children’s exposure is unlikely to follow regulatory boundaries between these product categories,” FPF wrote.
FPF gave the example that “a child sitting in a highchair for a meal may mouth different components, such as the plastic tray (an FCM), the armrest, and the included textile belt strap, which may each be subject to different CMR concentration limits for the same substance,” even after the amendment is in place.
FPF therefore encouraged the Commission to align the proposed limits with existing EU legislation to ensure a consistent and higher level of protection.
The consultation period ended on June 5, 2026. In addition to FPF, the Commission received 36 comments from stakeholders, including trade associations, civil society organizations, and private EU citizens. The timeframe for comments to be reviewed and the amendment adopted is not currently stated on the Commission’s website.
To see ongoing policy feedback opportunities from around the world, check out FPF’s consultations page.
Reference
European Commission (May 8, 2026). “Childcare articles – restriction on substances classified as carcinogenic, mutagenic or toxic for reproduction (CMR).”
Food Packaging Forum (June 4, 2026). “FPF Comments on ‘Childcare articles – restriction on substances classified as carcinogenic, mutagenic or toxic for reproduction (CMR)’.” European Commission.
