The European Furniture Industries Confederation (EFIC), representing around 80% of the European furniture sector, welcomes the opportunity to share comments on Slovenia’s TRIS notificationregarding the draft Slovenian Regulation on the restriction of CMR 1A/1B substances in childcare articles (TRIS notification 2026/0059/SI).
EFIC fully supports the considerations shared in EDANA’s assessment that the proposed national measure constitutes an unjustified restriction on intra-EU trade, contrary to Articles 34–36 of the Treaty on the Functioning of the European Union (TFEU) and the framework established under Regulation (EC) No 1907/2006 (REACH). By introducing a national restriction in an already harmonised area, Slovenia risks undermining the integrity of the Single Market and creating fragmentation through diverging national requirements.
We also note that the European Commission is actively preparing an EU-wide restriction on CMR 1A/1B substances in childcare articles under REACH. In this context, the Slovenian initiative appears premature and inconsistent with the obligation to avoid national measures where harmonised EU rules are under development. Such unilateral action risks duplicating or conflicting with forthcoming EU legislation.
Furthermore, EFIC supports EDANA’s concerns regarding the lack of demonstrated necessity and proportionality of the proposed measure. The draft Regulation does not appear to be supported by a detailed risk assessment demonstrating a concrete risk to children’s health that would justify immediate national intervention. At the same time, existing EU legislation already provides a robust framework ensuring the safety of consumer products, including childcare articles.
From a practical perspective, the proposal raises significant concerns regarding enforceability and compliance. The introduction of extremely low threshold limits, combined with the absence of validated analytical methods across different materials, would make it difficult—if not impossible—for manufacturers to reliably demonstrate compliance. This creates legal uncertainty for economic operators and enforcement authorities.
Considering the above, EFIC fully supports EDANA’s call on the European Commission to issue a detailed opinion requesting Slovenia to:
- postpone the adoption of the draft Regulation for 12 months, in line with Single Market safeguards and ongoing EU-level work;
- refrain from adopting national legislation that would conflict with EU law and the Treaties.
