Chemicals in headphones: An emerging risk signal for insurers

Headphones are often treated as low-hazard consumer electronics, but recent testing by the EU-funded ToxFREE LIFE for All project suggests that such products may not be quite so.

In February 2026, The Guardian reported that hazardous substances were detected in every one of 81 in ear and over ear headphones tested, including products from major brands as well as items sourced via online marketplaces. 

For insurers, the most important contextual detail is how headphones are used. Unlike many electronics, headphones can sit on or in the ear for hours, and are often worn while commuting, working, or exercising. ToxFREE’s reporting emphasises the concern that chemicals can migrate from plastics to skin, and that heat and sweat may increase this migration, turning 'normal use' into and exposure pathway. This is a different claims profile from traditional electronics losses (electrical fault, battery overheating, accidental damage). This risk is closer to that posed by cosmetics, wearables, toys, and other products where claimants allege chronic, repeated exposure.

The same overall message appears in consumer-organisation reporting. Austria’s VKI (also working under the ToxFREE umbrella with partners in Slovenia, Czechia and Hungary) stated in October 2025 that no tested model was free of concerning substances and that it analysed 84 substances across headphone models for adults and children. VKI’s framing is particularly relevant for insurers: it indicates there may not be an “immediate danger” from any single product in isolation, but that cumulative exposure across daily life can drive concern and behaviour change. In liability terms, that can still generate loss via allegations of inadequate testing, failure to warn, misleading marketing, or defective design, even if medical causation is difficult to prove at scale.

How this converts into insured loss: regulation and enforcement

Chemical findings become insured events when regulators or enforcement bodies treat them as compliance failures, or when retailers act pre-emptively. Here, the wider enforcement environment matters. The European Chemicals Agency (ECHA) reported results from an EU-wide enforcement project (checks performed during 2022) in which electrical devices (including headphones) had particularly high non-compliance rates – often linked to substances such as lead and phthalates, and where enforcement measures “most” frequently resulted in withdrawal from the market. 

Insurers should also consider the direction of travel in EU rules for substances used in plastics. For example, the EU has amended the RoHS regime to restrict four phthalates (DEHP, BBP, DBP, DIBP) in electrical and electronic equipment, reflecting health/environment concerns and waste-management impacts. Separately, European public-health messaging on BPA has strengthened: the European Environment Agency has stated that population exposure to BPA in Europe is widely above health-based guidance values, citing human biomonitoring and EFSA’s updated risk work. Even if headphones are not the primary BPA exposure route, this official posture increases the likelihood of broader scrutiny of bisphenols and “regrettable substitution” (e.g. BPA replaced by BPS).

Implications for insurers: What to expect 

1. Product liability shifts from 'defect' to 'exposure'. Claims may focus on alleged endocrine disruption, fertility impacts, neurodevelopmental effects, allergic reactions, or 'medical monitoring'. Even when outcomes are uncertain, these cases can be defence-cost heavy due to expert evidence, causation disputes, and long timelines. 
2. Recall/withdrawal risk becomes central. Many insureds assume general liability will cover recall costs; in practice, recall often requires dedicated cover and tightly defined triggers. ECHA’s enforcement results show that market withdrawal is a common remedy when breaches are found. 
3. Supply chain traceability and subrogation are make-or-break. Chemical issues often originate in a specific component (soft-touch polymers, cable sheathing, adhesives, flame-retardant packages). Without robust traceability and change-control, a targeted issue can become a portfolio-wide accumulation event with limited subrogation recovery.
4. D&O and product governance risk rises. If products are marketed as 'safe', 'non-toxic', or 'BPA-free', adverse test results can create allegations about oversight, disclosure, or controls – especially where internal testing existed but was not escalated.

Underwriting takeaway: treat 'wearables + plastics + prolonged skin contact' as its own risk class. The ToxFREE headphone findings are not just a consumer headline; they are a credible signal that chemicals risk is migrating into everyday electronics, and insurers will be expected to have seen it coming.