Important Update | Tiny Land Stain Safety Concerns

Please read if you’ve been using Tiny Land stains for children’s products and crafts.
The following contains critical information for you to consider. Footnotes are included at the bottom for your further research.

Intro

We’ve been a reseller of ‘food grade & toy-safe’ wood dyes manufactured by Tiny Land, UK for some time. We’ve been selling them under the safety claims of the manufacturer (Tiny Land) and following their recommendations.

The manufacturer’s safety claim is that they’re safe for a variety of applications for children’s toys, art & craft activities as they’re made of food grade colours.

We conducted our internal safety assessment for them and concluded that we do not agree with these safety claims at all. We’re immediately discontinuing the following product claims previously used for marketing purposes by Tiny Land.

Food Grade
Toy-Safe
Safe for children’s crafts
Plastic-free

So we urge you to read carefully if the above is relevant to your application.

‘Food Grade’ labelling

Some of the most commonly used ‘food grade’ colours in the UK are banned in many other countries.

Most of the synthetic food colourings are azo dyes derived from petroleum or coal tar.

Azo dyes are linked to carcinogenic effects [1] and coal tar used in coal tar dye is associated with skin tumours, as well as cancers for other organs through skin exposure. [2]

Regardless of the ‘approval’ of their use for food in some countries, the ‘safe’ claim for these dyes remains ‘highly controversial’.

Synthetic food colourings are linked to allergy, ADHD, carcinogenicity, reproductive toxicity and other various adverse health effects. These cheerful colours pose a ‘rainbow of risks’ to your health. [3]

All countries have different lists of banned colourings. An unfortunately, the UK has a very low standard on this.

It’s important to note that the fact that some of them are not yet ‘banned’ does not mean they’re ‘safe’. It just means that the regulation in that country hasn’t caught up with that particular substance. Of course there are industry lobbies and other interests affecting the standard as well.

For example, Titanium Dioxide was only banned in the EU in 2022 due to the high percentage of nanoparticles that’s linked to genotoxicity (damaging to DNA).

However, it was widely used as ‘safe’ for food until then and is still allowed in the UK as ‘food grade’. This has been also heavily used in one of the previous TL playdoughs as ‘safe to eat’ until 2022, which has now turned out to have never been safe.

Also, it is worth noting that even these ‘permitted’ food colours are banned for foods marketed for children under 36 months in the UK. Considering that these ‘food grade’ colours, as marketed by the brand, are used by parents, many of whom have specific concerns about mouth contact for under 36 months, using substances banned for this age group should not be promoted as ‘food grade’ at all, even in the relatively lax UK.

We may all agree that when it comes to children’s safety, parents should be ahead of the regulation instead of catching up with it.

To sell and market these stains as ‘food grade’ causes a lot of confusion & misunderstanding to customers. Not only for the mere regulatory compliance purpose in different countries, but for the actual safety aspects of them.

Here are some examples of common food grade colouring that are permitted in the UK (with restricted use) but banned in other countries for various reasons including DNA damage and carcinogenic effects [4]

E102 Tartrazine (Yellow): Banned in Norway, Finland and Austria
E110 (Sunset Yellow): Banned in Norway, Finland and Sweden
E104 (Quinoline Yellow): Banned in the US, Japan, Australia and Norway
E171 Titanium Dioxide (White): Banned in the EU
E122 Carmoisine (Red): Banned in the US, Norway, Sweden and Japan
E129 Allura (Food Red 40): Banned in France, Germany, Denmark, Belgium, Austria, Norway and Sweden.
E132 (Indigo Carmine): Banned in the US, Japan, Australia and Norway
E133 (Blue 1): Banned in Austria, Belgium, France, Norway, Sweden, Switzerland and Germany
E124 (Ponceau 4R): Banned in US, Canada, Norway, Sweden and Japan
Other E numbers banned in the US: E107, E123, E124, E125, E131, E142, E151, E153, E154, E155

Please note, even though not completely banned, the FSA (Food Standards Agency) recommends UK manufacturers not to use most of the synthetic food colourings and the products should always carry “may have an adverse effect on activity and attention in children” warning. (an extremely mild warning considering the mounting evidence for much worse.)

Misleading Recommendations

The claim that these stains are made of ‘food grade’ colours gives a misleading impression to customers that these are ‘safe’ to use in a variety of applications.

These stains have been recommended by the manufacturer for use in all types of children’s crafts as well as for making toys. We’ve even seen a video of the brand owner drinking a solution of the dye as a demonstration of safety on social media.

This is highly problematic.

There are people who consider food colours in candies and soft drinks as poison for children. It is not something that can be casually recommended without very careful consideration.

Particle Size, Nanoparticles & Chemical reactions

Disperse dye (the ones that dissolve in water like the food dye in TL stains) have smaller particle sizes than other pigments. Normally, if a dye particle is a pinhead, a pigment particle is a football. [5]

The smaller the particle sizes are, the more dangerous they are to our immune system. [6]

Small size particles have high ‘Immune reactivity’.

“The molecules of synthetic colourants are small, and the immune system finds it difficult to defend the body against them. They can also bond to food or body proteins and, thus, are able to act in stealth mode to circumvent and disrupt the immune system.” [7]

Not only that, food colourings also contain nanoparticles, such as metal oxide nanoparticles – even smaller particles with increasing health concerns that are not yet studied enough. [8]

As for the pigment versions of the same food colours, called ‘lake’, (used in the TL paints, finger paints and pigment stain), they’re pseudo-pigments (unlike ‘real’ mineral pigments), formed by absorbing the food dye on a hydrated aluminium substrate. Lake pigment particle sizes are very fine compared to mineral pigments. When we say ‘football size’ above, it’s referring to mineral pigments, not these extra fine pseudo-pigments.

Even mineral food colouring like Titanium Dioxide contain nanoparticles, the reason why it’s now banned in the EU.

We’re only seeing the beginning of the ban on these nanoparticles and more will be scrutinised in the coming years.

Migration & Permeability

If you’re making toys that children might put in the mouth, the most important thing is that no toxic elements leach out on contact with saliva or permeate the skin.

If you have used food colouring on bare hands you’ll know that they immediately permeate your epidermis on contact. If you stain your egg with food dye for Easter, you know that the colour particles go through the membrane.

Food colouring is a permeator “that can pass through the dermal layers and into the body, and can either expose the body to toxic effects of that chemical or act as a carrier for other toxic/hazardous chemicals”.

Azo dyes, such as food colourings, are some of the worst choices for kids’ crafts. Small particles like these can easily enter their bodies through the skin.

These stains have 20-100 times more concentration than the brightest coloured candies or soft drinks.

Children’s skin is more permeable than adult’s. Together with the high concentration and high solubility of these dyes, it make this particular scenario even more concerning. [9, 10, 11]

EN 71-3:2019 Safety of Toys – Part 3: Migration of Certain Elements

According to the manufacturer-Tiny Land’s claim, these dyes are tested for EN71-3. So that is good. Although we have not received the test certificate from the manufacturer, we trust the test was carried out.

However, EN71-3 only tests for migration of certain heavy metals.

The chemicals contained in these food dyes are not subject to EN71-3 and none of the safety concerns relating to azo dyes/coal tar dyes/nanoparticles etc. will be assessed within the EN71-3 criteria.

EN7-3 is a minimum standard for heavy metal levels that you must meet but it is simply not good enough.

The primary rule for children’s product safety is that the manufacturer ‘must carry out all due diligence so as not to jeopardise the health of the children’. It is not limited to simply meeting the minimum regulatory requirement.

You may recall that some children’s crayons in the market turned out to contain asbestos. [13] In our other business, we sell crayons and we get them tested for asbestos voluntarily, even though EN71 doesn’t require it. If you know your product contains asbestos, for example, it would be unethical to claim they’re safe for children.

It is normally the practice of large corporations to make safety claims based on the mere regulatory requirements, but turn a blind eye to other obvious safety risks.

In our opinion, we should all set higher standards than that. These dyes should not be recommended for use in toys & children’s crafts.

What is Safe for Children’s Toys?

The safety of the final wooden toy depends solely on how they are finished to prevent the chemical compounds or heavy metals leaching out when in contact with saliva. For toys for over 3 years old, if the surface does not migrate any toxic elements through skin, especially when wet, that would be considered safe (although it’s always good to consider a situation where other younger children may have access to it.)

The ideal solution is to use pigments with a larger particle size (instead of dispersant dye) that are encapsulated with a binder polymer, so after its dried, it does not reactivate again when wet and does not migrate the toxin.

For example, ‘encapsulated cadmium’ stains used in safe ceramic dinnerware is a cadmium encapsulated in non-toxic crystals so the cadmium doesn’t leach out of the crystals.

The same principle should be applied to coating children’s toys.

The TL stain is a dye dispersed in a water-base without any of these mechanisms to make it safe.

It has to be sealed and finished correctly to make the toy safe, and this has everything to do with the sealer and nothing to do with the dye itself. So, this dye cannot claim to be ‘toy safe’ on its own merit.

Tung Oil has been recommended as a sealer for the TL dyes for toy making. We’ll still recommend this if a customer wants to use the TL dye. However, there are a few fine points to note:

Tung Oil and many natural oils or beeswax are safe on their own. But most natural oils do not sufficiently lock in the small dye particles compared to polymer encapsulated pigments.

If you apply one coat of Tung Oil on top of TL dye, although the surface will be water-resistant for light use, the dye will still leach out when you soak the piece in water. This is fine for decorative items but not for toys for young children.

It probably requires a minimum of 5 coatings of Tung Oil to stop the dye leaching out when soaked. We’re not able to tell you exactly what the deal is when you finish with Tung Oil, because there’s no existing testing or study to show you how it stops the dye particles from migrating. You need to conduct your own tests and determine what is sufficient for your safety goal.

We’re about to launch a range of professional colour systems for toy makers in March. We do not use food grade colour dyes for them as ‘food grade’ is completely irrelevant for this particular safety goal.

Our water-based formula is made with lightfast pigments that are encapsulated with a purpose-built binder to stop the migration of elements in contact with skin and saliva, lab tested for EN71, PAH migration (for toys under 3) and phthalates.

This is what we consider as a safe option for making toys.

On top of that, you don’t have to seal it additionally and can use water-based sealants on top (unlike TL dye) so you can finish your toys in more bright colours without darkening it with an oil.

Of course, we love using natural dyes like beetroot and finishing with Tung oil. However, natural dyes have weak colours that fade fast, so this is only suitable for some occasions. We think this is still the best choice for teething toys, but older children should enjoy more vibrant colours – it gives rich, creative experiences for them and is beneficial for their development.

If you want to be notified for the launch, feel free to sign up on our newsletter or follow us on social media.

Back to a few more notes on TL dyes…

Environmental Claim

The TL brand is touted as ‘plastic free’ and ‘environmentally friendly’.

It’s worth noting that synthetic food colourings are made from petroleum or coal tar.

Manufacturing of these can have a significant environmental impact due to the chemicals used and waste produced.

Synthetic food colourings are not biodegradable, harm aquatic life, affect soil quality and pollute water resources with carcinogenic chemicals and require advanced technology to filter them. [14,15]

So, it is not specially environmentally friendly in comparison to, for example, acrylic paint.

Glass jars are also arguably worse for the environment as they have a higher environmental impact than plastic bottles. [16,17]

As far as the commercial convention goes, these products can still make claims of ‘environmentally friendly’ – as it’s water-based and doesn’t use plastic packaging, just as some acrylic paint can claim to be ‘environmentally friendly’, which customers need to take with a pinch of salt and apply their own standard when choosing products.

The claims of ‘plastic free’ gives the impression that this is an eco-friendly alternative to petrochemical products and causes no harm to the environment. We find this as not true, so will be retracting any description of ‘plastic free’ for these products.

Homemade

One of the marketing lines by TL is ‘made in a kitchen, not a factory’.

Together with ‘food grade’, ‘safe to eat’ and the fact it’s made by a fellow mum, all conjure up an image of a wholesome homemade meal, with no safety warnings to throw cold water on your warm feelings towards it.

The problem with this is that it creates a false sense of security where parents and toy makers drop their usual guard down, and use them with much less caution than they should, which can cause more harm.

They’re less likely to protect their hands from stains, less likely to be vigilant of children ingesting the material, or disposing of it down the drain without concern.

All together, I must say, it seems that there are more marketing buzzwords than thoughtful research and assessment for the safety of children and environment.

You should always have some scepticism about any brand’s claims. Please do your own research and use the product responsibly.

Clearance of Tiny Land products

To summarise:

Here’s what we agree with for Tiny Land stains and will continue marketing as such:

They’re super easy to apply
Bright colours for creative projects
Overall, they’re good, easy to use water-based stains for home DIY, furniture and decorative projects and are better options than some other solvent-based stains with high VOC and higher toxicity.
It meets EN71-3
Non-toxic and eco friendly: they’re non-toxic as in they’re water-based without aggressive solvents, (ie. not classified as ‘hazardous’) and meet EN71-3 standard for heavy metals.

They come in plastic free packaging, which conventionally qualifies as ‘environmentally friendly’ (although debatable). These are conventionally used & acceptable claims although not as high a standard as we’d like.

Here are the claims that we Do Not agree with any more:

Food-grade (they’re made of UK food grade dyes for over 3 years, but for the reasons given above, we’ll not use it as a selling point to avoid causing harm)
Toy-safe (they meet EN71, but we cannot claim toy-safety knowing what we know about other substances in it)
Plastic Free (as they’re made from petroleum and not biodegradable)

Additionally, we’d recommend these safety protocols when using:

Wear gloves when handling dye – protect your skin
Keep away from children
Use in well-ventilated areas. (If you’ve been using TL dyes, you’ll know it’s based on a strong vinegar solution as you can smell it. Acetic acid in vinegar can cause irritation to your mucous membranes and lungs.)

Fortunately, most of our own customers have bought them for DIY/decorative projects. We never sold the finger paints and playdough we purchased, so thanks for that. We’ll be discarding them all. We’ll continue developing our own stain formula and new colours for home DIY purposes only.

They can be used for toys if you know what you’re doing. But not without personal responsibility.

All of our Tiny Land stock is now in the clearance sale. We’ve got probably a few years’ worth of stock in many colours.

Feel free to browse if you have DIY projects and use them safely and responsibly!

Certification & Liability

We’ve been asked about EN71, CE certification and other regulatory requirements by some of the former TL toy maker customers. We promised to answer them at some point, so here’s some info on that.

We’ve already discussed EN71-3, a regulatory necessity, but not a very high standard even for heavy metals. (We sell our toys worldwide and some retailers want a much better testing result than the mere ‘PASS’.)

In the UK, all liability for due diligence and the safety claims for Tiny Land products lies with the manufacturer Tiny Land Play Ltd. Resellers are not liable for any of the manufacturer’s claims in the UK. As you can imagine, a shop can’t verify the safety claims of each product manufactured by others. This is solely the manufacturer/brands’ responsibility.

We’ve been asked to provide CE certification before. This should be provided by the manufacturer, however, CE is not required for stains (not being in the category for CE). Chemicals on their own or in mixes, for example, paints and inks, fall under UK REACH and EU REACH legislation.

Please note – toy makers should create their own UKCA & CE certifications for the finished toy based on their due diligence.

Your due diligence includes requesting 3rd party testing documents, MSDS or other risk & safety assessment documents from the manufacturer (Tiny Land). You’ll need to draft UKCA & CE Certificates of Conformity (COC) with your own self-assessment.

Compile Technical Documents that include a risk assessment, manufacturing processes, lists of materials used including adhesives, inks and finishes and the methods you used internally to ascertain Mechanical and Physical test compliance with the regulations (if you test internally).

The best thing to do, if you can, is to test your final toy for EN71 with a third party lab.

Ultimately, it is your sole responsibility to guarantee the safety of your toy. If you haven’t tested it and it turns out that the manufacturer’s claim was not correct, the liability will be on you. So, it is important to work with a trustworthy manufacturer.

Compliance in the US governed by the CPSC is the same. You’ll need to test it according to ASTM standards for heavy metals and the CPSIA (Consumer Product Safety Improvement Act 2008) or register for exemptions with the CPSC and do your due diligence.

As mentioned, for EN71-3 / CE, CPSC, the standards will not ask for any compliance for these harmful chemicals contained in food colourings or any other chemical products. There’s currently no regulation for these outside food applications. It’s up to you to determine what you want to do and how to gain trust from your customers.

Regarding reselling these dyes as products

In the past, Tiny Land had distributors abroad, who were resellers of these products in their own countries.

If you’re ever reselling these stains outside of the UK, please note all importers/distributors in each country are solely responsible and liable for the safety claims and compliance in their country for any products they import or distribute as a manufacturer.

Knowing what the authorities are like, any emphasis on ‘food grade’ for non-food products for marketing purposes is likely to be a problem. Claiming ‘food grade’ ingredients when some of them are banned in your country is going to be a problem. Any claim that a non-food product is ‘safe to eat’ is going to be very problematic. Any refusal to disclose known allergic ingredients is going to be a problem. Any claims for ‘toy safe’ without 3rd party testing for your country’s compliance standards is going to be a problem.

Please be careful. We’re saying this because we’ve seen it done before without any concerns for these matters.

Please do your own research. You’re responsible for all your product claims and liability in your country if you import or manufacture them in your country.

Additionally, we can now see that the company Tiny Land Play Ltd was dissolved last September in the UK. We don’t know why and are not sure what happens to the liability. This company was only incorporated in 2020 and we understand that the product was sold for many years prior to this as a sole trader business, so I would think all original product claims and liability will still lie with the director/sole trader personally.

Final thoughts

Back in March 2022, we started looking into using food grade colouring as wood dye for children’s toys as we assumed this to be a good, safe place to start.

Normally I’m pretty good at looking into the safety aspects of all the products I use – shampoo, moisturiser, cleaning products etc. I always stay sceptical of most company’s claims, especially the large ones and never believe the ‘safety’ claims until I look into it myself.

However, because in our household, we hardly ever eat processed foods – we buy from farms and organic suppliers when we can and cook all our meals, especially never eating brightly coloured processed ones, I have never paid special attention to food colourings. It was never relevant to me and I hadn’t had a chance to learn about it.

When we came across Tiny Land and saw the ‘food grade’, ‘toy safe’ ‘eco friendly’ stain, we didn’t apply much scepticism to these claims. I think the fact that it was owned by a mum, a tiny home business and was getting a lot of community support – so a lot of good things – alongside the fact that I was not personally familiar with food colourings gave me a blind spot. The safety for kids and the environment seemed to be a paramount passion for the company.

‘Made in the kitchen’ claims and all the good vibe just disarmed me of my usual scepticism, as it does for many customers. Knowing that the products have been sold for a decade or so and have a strong community endorsement, I assumed all due diligence was done. After all, it wasn’t from a big corporation that usually keeps me on my toes.

As some of you may know, we tried to acquire this brand for all these reasons, but eventually withdrew for other concerns.

Then we just got busy with other projects and let the sales dribble in for the stock we purchased (that we couldn’t’ return) without any marketing effort. We sold them under the claims of TL. To my shame, I haven’t doubted these claims ever since.

Recently, we made some progress with our other projects and went back to where we left for further product research and development. Alongside other product ideas, I intended to go back to the initial food grade dye idea with a different formula. The first thing I started doing was compiling the technical data and doing the safety assessment of each material.

Immediately, on day one of starting my due diligence, I found out they’re banned in multiple countries for food and there is plenty of, and ongoing, research about their toxicity to human health and harm to the environment. The legislation has been continually tightening, the permitted exposure limits lowered and the trajectory is undeniably toward banning. These are highly controversial, harmful substances that are simply not suitable for the application the brand was promoting for.

As soon as I conducted my research, we decided to discontinue the brand’s main claims and inform the customers straight away.

So here we are.

To be frank, I’m astounded that none of these were looked into and mentioned for over a decade(?) of selling and marketing these products. Although I’m sure this is an honest oversight, rather than dishonest marketing, such a lack of basic due diligence over this many years is truly appalling.

A small business by a fellow mum should be supported and encouraged as much as possible, however, it shouldn’t put blinders on in assessing the product’s claims.

For example, I love finding natural skincare products made at home on Etsy and would buy them over big company products. However, I don’t buy homemade sunscreens. Dispersing the zinc particles for even coverage and ensuring correct SPF requires larger resources than a home kitchen. When they’re not done properly, you’re not going to protect your skin as intended. So, I look for those made by companies who know what they’re doing. I look at each ingredient and research, regardless of the safety claims approved by the current industry standards.

We’ll probably lose business in selling our remaining stock of TL, because ‘food grade’& ‘toy safe’ have been major selling points for marketing.

Obviously, we’ll definitely take less sales any time over misleading claims that can cause harm.

As for Tiny Land, I think the brand should inform customers of these health risks and ask parents to stop using them for children immediately.

Thank you for reading this far, our goal is to inform customers as best we can about the industry’s ingredients, develop the safest products we can and create a safer environment for all of our families!

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