Offering endless creative possibilities, modelling dough and modelling clay are popular toys for stimulating children’s creativity, improving concentration, and developing fine motor skills. However, the Consumer Council’s test on 15 styles of modelling dough and modelling clay revealed that 3 samples were detected with 2 allergenic preservatives, namely methylchloroisothiazolinone (CMIT) and methylisothiazolinone (MIT), at levels higher than the European Union’s (EU) upper limit for aqueous toy materials intended for use by children under 36 months of age. The detected CMIT level of 1 sample was even higher than the EU limit by more than tenfold. The Council has referred the test results to the Customs and Excise Department for follow-up. In addition, 6 samples were detected with migration of certain elements, while 8 samples were found with aerobic microorganisms, all levels did not exceed the relevant EU safety thresholds. Furthermore, most of the samples (11) lacked any labelling to remind users to wash their hands after use. The Council has referred the test results to the Customs and Excise Department for follow-up. The Council urges manufacturers to improve product formulations and enhance information transparency by clearly labelling production dates, best before dates, and expiry dates, as well as including relevant warnings such as “Wash hands thoroughly before and after use”, so as to reduce the potential health risks of children being exposed to expired or microbiologically contaminated products.
The Council purchased 15 modelling dough and modelling clay samples from various retail outlets, including 6 wheat dough, 3 rice dough, and 6 clay samples, priced from HK$12 to HK$128. For the samples that required hardening, high temperature treatments were not necessary. While some included moulds or shaping tools, the current test only covered the dough or clay components and did not test the safety performance of the accessories. Conducted with reference to the European Toy Safety Standard EN 71-3:2019+A1:2021, the tests assessed the migration of 19 certain elements in red, yellow, blue, and green-coloured dough or clay in each style. Furthermore, in accordance with the upper limit stipulated in the EU Toy Safety Directive[1], the concentrations of the preservatives BIT, CMIT, MIT were tested in one colour per style. Microbiological test was also conducted on one colour of each style using methods from the European and British Pharmacopoeias.
2 Allergenic Preservatives Detected in 3 Samples at Levels Exceeding EU Limit
Preservatives such as BIT, CMIT and MIT are commonly used in modelling dough and modelling clay to reduce risks of microbial contamination during production and use. However, all 3 types are known allergenic substances which may trigger allergic reactions with prolonged skin contact, with MIT named as “Allergen of the Year” in 2013 by the American Contact Dermatitis Society. Children often have prolonged skin contact when playing with these dough and clay toys with their hands, increasing the risk of skin sensitisation. Moreover, if the hands are not washed thoroughly after playing, residual dough or clay on the fingers or under the nails may also lead to allergic reactions if it comes into contact with the eyes or mouth.
3 tested samples were found to contain CMIT and MIT. Detected levels of CMIT ranged from 3.1mg/kg to 8.5 mg/kg, approximately 3.1 to 10.3 times higher than the EU Toy Safety Directive’s upper limit (0.75mg/kg) for aqueous toy materials intended for use by children under 36 months or intended to be placed in the mouth. The detected MIT levels of the same 3 samples ranged from 0.30mg/kg to 0.50mg/kg, also higher than the EU’s upper limit (0.25mg/kg) by at most onefold. Considering that the detected CMIT and MIT might have been added to the samples in the form of a CMIT/MIT mixture (3:1 in ratio), the calculation used the detected amounts of CMIT and MIT to compute the potential maximum content of CMIT/MIT mixture in the 3 samples, which was estimated to be 1.2mg/kg to 2.0mg/kg, also above the EU’s limit of 1mg/kg. Although Hong Kong currently has no relevant requirements on the BIT, CMIT, or MIT content in toys, the Council recommends manufacturers to improve their product formulation with reference to relevant EU standards to better safeguard children.
Migration of Certain Elements and Microbial Count of All samples Models Within Limits
Apart from preservatives, the migration of 19 certain elements (including aluminium, antimony, arsenic, boron, mercury, lead, etc.) in the samples was also tested in accordance with the European Toy Safety Standard EN 71-3:2019+A1:2021. Results showed that 2 samples had aluminium migration in all 4 colours, ranging from 280mg/kg to 700mg/kg; 3 samples were detected with strontium migration from 150mg/kg to 250mg/kg; 1 sample had boron migration in its 3 colours, ranging from 930mg/kg to 970mg/kg, among which 1 colour was also detected with copper migration of 250mg/kg; 1 sample was found with barium migration at 140mg/kg. However, all migration amounts were within the European Toy Safety Standard’s limit.
Furthermore, 8 samples were found with total aerobic microbial count ranging from 15 CFU/g (colony-forming units per gram) to 650 CFU/g, below the EU’s recommended voluntary limit (not higher than 1,000 CFU/ml or CFU/g) for microorganisms in toys containing aqueous media. None of the samples were detected with other related microorganisms, such as Pseudomonas aeruginosa, Staphylococcus aureus, or other pathogens.
Insufficient Labelling Information for Some Products
Urged to Include Expiry Date and Reminder to Wash Hands
Among the 15 samples , 3 had minimal labelling and lacked even basic precautionary wordings or warnings; 11 samples did not remind users to wash hands before and after use. While current legislation and standards in Hong Kong do not mandate labelling of usage period information for these types of toys, such as the manufacturing date, best before date or expiry date, the Council urges suppliers to clearly indicate this information in both Chinese and English on the product labels or packaging of modelling dough or modelling clay toys. Labels should also highlight potential allergenic substances, and include reminders to clean hands thoroughly before and after use, so as to help consumers stay mindful when giving these toys to their children.
When purchasing modelling dough or modelling clay for children and when using such toys, consumers should pay heed to the following:
- Carefully read product information before purchase, including the suitable age, ingredients, and expiry date;
- Wash hands thoroughly before use to prevent contaminating the dough/clay with bacteria on hands, and wash hands again after to prevent accidental ingestion or contact of residue with the eyes or mouth;
- Avoid use if the child has open wounds on the hands or skin infections. Discontinue use immediately in case of allergic reactions or if discomfort occurs on the skin;
- Store dough or clay in its original packaging or a sealed container after each use to prevent contamination. Stop use and discard immediately if the toy is visibly dirty with dust or hair;
Discard dough or clay toys that have been used by children with communicable disease or shared among multiple users, to reduce the risk of disease transmission.
[1] Among the 15 tested samples, 5 did not label the suitable age in Chinese or English, another 3 were labelled as suitable for age 1 or above to age 2 or above, 1 model was labelled as suitable for age 4 or above, while the remaining 6 models were labelled as suitable for age 3 or above. Considering that the outcome of age grading assessment by the laboratory and all the modelling dough and modelling clay samples in the current test had similar methods of use, parents may give them to younger children. Therefore, the preservative test was conducted in accordance with the upper limit set by the EU for aqueous toy materials intended for use by children under 36 months of age in comparing the preservative content of the samples.
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