Montenegro Aligns Toy Safety Requirements with EU

SafeGuardSToys and Juvenile Products23 Jul 2024

SG 117/24

Montenegro has further aligned its toy safety requirements with those in the European Union (EU). The latest amendment entered into force on July 13, 2024.

In 2015, Montenegro published its Rulebook on Toy Safety to prescribe the rules that toys should meet in terms of, among other things, children’s safety and health protection, conformity assessment procedures and the conformity mark in order to place these products on the market (Official Gazette of Montenegro, No. 4/2015 (OGM No. 4/2015)).

This Rulebook adopted EU Directive 2009/48/EC on the safety of toys (Toy Safety Directive, TSD, consolidated version to December 2022) and its subsequent five amendments. The provisions in the rulebook applied from July 2015.

According to Article 22 of OGM No.4/2015, the provisions of Articles 20 and 21 on the obligation to affix the CE mark on toys will apply from the day of Montenegro’s accession to the EU.

On July 5, 2024, Montenegro issued ‘Rulebook on Amendments to the Rulebook on Toy Safety’ (OMG No. 65/2024) to further align its toy safety requirements with those in the TSD. This amendment transposes the TSD into the nation’s Rulebook on Toy Safety.

The latest revision contains several important changes when compared to the Rulebook on Toy Safety under OMG No. 4/2015. It:

Expands the number of terms and definitions under Article 3 to include ‘designed speed’, ‘placing on the market’, ‘withdrawal of toy’ and ‘mark of conformity’
Provides the latest list of products that are not considered as toys (Annex I)
Details the updated particular safety requirements for physical and mechanical properties, flammability, chemical properties, electrical properties, hygiene and radioactivity (Annex II) – these include strengthened requirements for the migration of aluminum and lead (see Table 1 below) as well as allergenic fragrances
Amends the criteria for the classification of substances and mixtures (Appendix B)
Expands the number of restricted substances for toys intended for children under 36 months or in other toys intended to be placed in the mouth from 4 to 12 (Appendix C)

Highlights of Rulebook on Amendments to the Rulebook on Toy Safety (OMG No. 65/2024) in relation to the migration of aluminum and lead are summarized in Table 1.

Element	Category I Toy Material	Category II Toy Material	Category III Toy Material
Aluminum (Al)	2,250 mg/kg (5,625 mg/kg)*	560 mg/kg (1,406 mg/kg)*	28,130 (70,000 mg/kg)*
Lead (Pb)	2.0 mg/kg (13.5 mg/kg)*	0.5 (3.4 mg/kg)*	23 (160 mg/kg)*

Table 1

*Former migration limit falling under Rulebook on Toy Safety (OMG No. 4/2015)

This rulebook became effective on July 13, 2024.

Definitions and examples of toy material

Toy Material Category	Toy Material	Example
I	Dry, brittle, powder-like or pliable	Compressed paint tablets Chalk, crayons, magic sand, modeling compounds, plaster of Paris, plasticine, oven hardened PVC modeling compounds Bouncing putty and squishy toys
II	Liquid or sticky toy	Bubble solutions, finger paints, poster paints, Glue sticks, liquid adhesives and slime
III	Scraped-off	Surface coating materials (paints and varnish) Polymers (ABS, elastomers, EVA foam, leatherette, polypropylene (PP), polystyrene, PVC, rubber and uPVC,) Wood (chipboards, fiberboards and plywood) Textiles (cotton wool, fuzzy felts, polyester staple fibers and plush fabrics) Glass, ceramics (fiber glass and marbles) Metals and alloys (nickel-silver and steel) Other materials (bone, leather, natural sponge and paper/card)

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