EU Toy Safety Standard Updates

December 17, 2013 | U.S. toy manufacturers and distributors that export product into Europe are being notified of two toy safety standard updates recently published by the European Commission (EC).

On December 2nd, the EC published a revised “Guidance Document on Technical Documentation,” to help manufacturers and importers of toys in the EU file comprehensive technical documentation demonstrating compliance of each toy with the requirements of the EU Toy Safety Directive (TSD). (Note: a technical file must be compiled before a toy is marketed and maintained for 10 years following the discontinuation of an item.)

Revisions to the Guidance Document include a model letter which toy companies can use to remind suppliers about the need to provide a list of materials, chemicals, and components used in the toy, as well as a model sub-declaration for suppliers to obtain a guarantee that the supplied parts and components have been correctly assessed and comply with the appropriate toy safety requirements for their expected use. The updated guidance document can be viewed here.

In the same week, the EC amended current restrictions of Polycyclic Aromatic Hydrocarbons (PAHs) in the REACH Regulation EC 1907/2006 (PAHs are not intentionally added to consumer products but are impurities of various manufacturing processes). The amendments in the new regulation – EU 1272/2013 – include limits for the allowable PAHs in rubber and plastic articles with prolonged skin or mouth contact, with special limits for toys in direct and prolonged or short-term repetitive contact with the skin or oral cavity. The limits are 1 mg/kg for all articles and 0.5 mg/kg for toys. The new regulation goes into effect in two years, on December 27, 2015; the amended rule can be viewed here.

Toy Industry Association (TIA) members with any questions on the above matters may contact TIA’s Al Kaufman, senior vice president of technical affairs.