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- Guest column: Safety by design and smart market surveillance - the recipe for safe toys in the EU
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Guest column: Safety by design and smart market surveillance - the recipe for safe toys in the EU
Would you be surprised to learn that a toy fork used by a child to feed its teddy bear has to meet stricter rules than the real fork the child eats with? What about if you were told that if oranges were toys, they would require a safety warning because of their fragrance?
As the tools of play, toys are an important part of growing up and have a central role in children’s development, learning and wellbeing. Toys are also one of the most well-regulated consumer goods in the EU. Because they are destined for children to play with, they must be of a higher standard than many of the other everyday products children come into contact with.
Catherine Van Reeth,
Reputable companies understand and respect importance of safety by design
The reputable companies who make up the vast majority of the sector understand the importance of designing safety into their toys from the start of the development process. They invest a lot of time and resources into testing to make sure they are safe for children to play with.
EU's comprehensive legal framework helps keep toys safe
The Toy Safety Directive (TSD) is the reference point for industry. Manufacturers also ensure they are compliant with other relevant legislation, including REACH, the Restriction of Hazardous Substances Directive (RoHS), the Radio Equipment Directive (RED) and, when toys are built for connected play, the appropriate security and privacy regulations.
In addition to this, manufacturers look to the myriad of standards that have been developed over time to handle specific aspects of toy safety. Reputable manufacturers know that by following these rules, the toys that they put on the market will be safe.
Adaptability of Toy Safety Directive makes sure it stays relevant
Furthermore, the safety of toys in the EU is reinforced by the wide margins included when limits are decided and the ‘living’ nature of the TSD, which means it can be revised if new scientific evidence comes to light.
This flexibility helps to make sure that the rules and standards are kept relevant and up to date. Examples of this in action include the changes to migration limits we have seen in recent years for lead, bisphenol A and chromium VI.
Science must be basis for decision making
Given the emotive nature of issues regarding children’s safety, it is essential that changes to legislation are made on the basis of science-based evidence and rational decision making. This is why the work of the Commission’s Expert Group on Toy Safety and its scientific committees are so important.
Rogue traders are a challenge, but represent only a small minority of market
However, there are a small group of rogue traders who don’t play by the rules. These are the operators who are responsible for 97 % of notifications for toys on the Rapid Alert System (RAPEX) and are the source of the toys featured in ECHA's recent report on compliance. By ignoring the rules, they gain a competitive advantage over reputable manufacturers and put children at risk.
Effective market surveillance key in catching operators who ignore rules
The only real way to tackle the challenge posed by rogue traders who ignore the rules is through smart and effective market surveillance. This includes strong cooperation and reputable economic operators. The Commission’s recent Goods Package Proposal provides a number of opportunities in this respect: the formation of a Union Product Compliance Network is a clear example of how to optimise coordination of enforcement activities within the EU.
Parents can be confident toys from reputable companies are safe for children to play with
The EU framework for toy safety is fit for purpose: it covers all aspects of toy safety and is designed to be responsive to new evidence – parents can rest assured that the toys that they buy from reputable manufacturers are safe for their children to play with. Effective market surveillance and enforcement is vital in keeping toys that don’t meet the EU’s high standards out of children’s hands.
Catherine Van Reeth is Director General of Toy Industries of Europe. She leads TIE in promoting a positive environment in which the toy sector can thrive and continue to bring safe and fun play experiences to children. Catherine has worked in EU public affairs for over 20 years and is an expert in consumer protection policy.TIE is the voice of reputable toy manufacturers in the EU. TIE was founded in 1991 and today represents 12 international toy companies, nine national toy associations and six affiliate members. TIE provides its expertise and knowledge about toys and the sector to members, stakeholders, and policymakers and provides a neutral platform for discussion and exchange. TIE’s main focus is ensuring that toys are safe for children. Other topics covered by TIE include responsible communications, ethical manufacturing, environmental sustainability, intellectual property rights and market access and promoting the value of play and the importance of toys in helping children develop and grow.
Published on: 17 May 2018
Top image: Toy Industries of Europe (TIE)
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