Formaldehyde and formaldehyde-releasing substances were recently added to the REACH Regulation as restricted substances under Regulation (EU) 2023/1464. From August 2026, articles that emit formaldehyde above the specified limits must no longer be placed on the EU market.
In addition to the new REACH restriction, a number of existing regulations and standards already limit formaldehyde content or emissions in product groups such as food contact materials, construction products, toys, and childcare articles. This article summarizes these requirements and outlines the methods commonly used for compliance testing.
Table of contents
Addition of formaldehyde-releasers to the REACH Regulation
Commission Regulation (EU) 2023/1464 amends Annex XVII of the REACH Regulation by adding formaldehyde and formaldehyde-releasing substances under entry 77.1 From 6 August 2026, articles placed on the market must not exceed the following emission limits:
0.062 mg/m3 for furniture and wood-based articles
0.080 mg/m3 for other articles
Substances and components used in vehicle interiors will have to comply with the 0.062 mg/m3 limit from 6 August 2027.
The restriction includes several exemptions. These cover second-hand articles, products used exclusively outdoors, and articles intended solely for industrial or professional use. Biocidal products, medical devices, food contact materials, and personal protective equipment (PPE) are also exempted, as they are regulated under their own product-specific frameworks.
Compliance testing with the chamber method
Compliance with the REACH formaldehyde restriction is assessed using the chamber method described in Appendix 14. In the test, a representative specimen is placed in the chamber and kept at the defined reference conditions until a steady-state concentration is reached, or for a maximum of 28 days. Formaldehyde concentration in the chamber air is measured at least twice a day using appropriate analytical methods. When a steady state is reached, the measured value is contrasted with the REACH restriction limit.
European standard method EN 717-1, which is already widely used to measure formaldehyde emissions from wood-based panels, meets the technical requirements outlined in REACH Appendix 14 and can therefore be used for compliance testing without modifications. It is also possible to follow standard EN 16516, but measured formaldehyde release may be higher due to the different testing conditions, making EN 717-1 the preferred method when it is directly applicable to the material. For vehicle interior components, standards ISO 12219-1 and ISO 12219-10 must be followed.2
Current rules for formaldehyde release from construction materials
Until the new REACH restriction takes effect, formaldehyde emissions from construction materials are evaluated using the relevant harmonized standard or European Assessment Document (EAD). For wood-based panels, the applicable standard is EN 13986, which defines two emission classes: E1 and E2. Panels may be classified in the higher E1 class if formaldehyde emissions do not exceed 0.124 mg/m3 (or 0.1 ppm) when tested in accordance with EN 717-1.
As the new REACH limit of 0.062 mg/m3 is half the current E1 threshold, many manufacturers will have to adjust their production processes to ensure wood-based boards and panels comply with the new restriction by August 2026.
Rules for formaldehyde in food contact materials
Formaldehyde can be used as an additive or starting substance in the manufacture of plastic food contact materials (FCMs) as long as the conditions outlined in Annex I to Regulation (EU) No 10/2011 are met.3 For materials without harmonized EU-level legislation (e.g., paper, board, wood, rubber), maximum migration or extraction limits are established through national regulations and recommendations.4
Table 1 summarizes the limits for formaldehyde release from different types of FCMs, together with the regulatory references and commonly applied test methods.
Table 1: Restrictions on formaldehyde release from food contact materials
Material type | Regulatory reference | Migration/extraction limit | Test methods |
Plastic | Regulation (EU) 10/2011 | 15 mg/kg* | EN 13130-1 (migration), CEN/TS 13130-23 (analysis) |
Paper and board | German BfR Recommendation XXXVI | 1 mg/dm2 | EN 645 or EN 647 (extraction), EN 1541 (analysis) |
Wood | French Note d'information n° 2012-93 | 15 mg/kg | EN 645 or EN 647 (extraction), EN 1541 (analysis) |
Natural and synthetic rubber | German BfR Recommendation XXI/1 | 6 mg/kg | In-house method |
* The limit applies to the sum of formaldehyde, hexamethylenetetramine, and 1,4-butanediol formal, expressed as formaldehyde.
Formaldehyde restrictions in other product groups
In addition to the requirements described above, several REACH entries and product-specific EU regulations set limits for formaldehyde content or release:
Entry 72 of REACH Annex XVII states that formaldehyde content in textiles, clothing, and footwear intended for consumers must not exceed 75 mg/kg of homogenous material.
Entry 75 of REACH Annex XVII limits formaldehyde concentration in tattoo inks to a maximum of 0.00005 % by weight (0.5 mg/kg), due to its classification as a category 1B carcinogen under the CLP Regulation.5
Regulation (EC) 1223/2009 on cosmetic products lists formaldehyde as a prohibited substance and limits its release from mixtures where it is known to form.6
Directive 2009/48/EC on the safety of toys specifies content, migration, and emission limits for formaldehyde, with the type of limit depending on material type. 7
Standard EN 14350 on children’s drinking equipment sets a 0.5 mg/l migration limit for formaldehyde from silicone, rubber, and thermoplastic elastomers.
Standard EN 14372 on children’s cutlery and feeding utensils specifies a migration limit of 15 mg/kg for components composed of wood or thermosetting plastics.
Compliance with the textile limit can be assessed by testing the product according to the ISO 14184-1 standard, which uses water extraction to extract formaldehyde from the matrix. The same method can be applied to textile components in toys. Other relevant standards for toys and childcare articles include Parts 9, 10, and 11 of the EN 71 series, EN 645 and EN 1541 (paper), and EN 717-3 (wood).
There is currently no harmonized standard method for the determination of formaldehyde in tattoo inks. As the limit is extremely low, compliance testing requires high-performance liquid chromatography techniques, such as HPLC-FLD.8
Our testing solutions
Measurlabs offers a broad range of formaldehyde testing services to support EU compliance assessments. These include:
Formaldehyde emissions from wood-based panels and other construction materials (EN 717-1)
Specific migration of formaldehyde from plastic food contact materials
Full EU compliance testing packages for wooden food contact materials and nitrile gloves, both covering formaldehyde release
Additional testing options are available for other products and materials. For further information or a quotation, please contact our experts using the form below.
References
1 Commission Regulation (EU) 2023/1464 as regards formaldehyde and formaldehyde releasers. The REACH Regulation (Regulation (EC) No 1907/2006 on the Registration, Evaluation, Authorisation and Restriction of Chemicals) is a central pillar of EU chemicals legislation.
2 European Chemicals Agency (ECHA): Guidelines for the measurement of formaldehyde releases from articles and formaldehyde concentrations in the interior of vehicles, April 2025
3 In Regulation (EU) 10/2011, formaldehyde is listed as FCM number 98 and under group restriction 15.
4 German BfR Recommendations XXXVI (paper and board) and XXI/1 (rubber), and French Note d'information n°2012-93 (wood) are commonly used as safety references for non-harmonized materials. They all set maximum limits for formaldehyde release from food contact articles.
5 This entry also applies to other hazardous chemicals listed in Part 3 of Annex VI to Regulation (EC) No 1272/2008 on classification, labelling and packaging of substances and mixtures (i.e., the CLP Regulation).
6 Formaldehyde is listed under reference number 1577 in Annex II to Regulation (EC) 1223/2009, and several other substances are prohibited if the maximum theoretical concentration of releasable formaldehyde in the final mixture exceeds 0.1 % w/w.
7 The limits are listed in Appendix C to Directive 2009/48/EC.
8 See Table 2 of German BfR’s opinion titled Tattoo inks: minimum requirements and test methods from October 2021. At the time, the institute was uncertain whether the required limit value could be achieved.