Toy Association Submits Comments on Brazil Ordinance 503 and Brazil RoHS

November 27, 2018 | The Toy Association has submitted comments to Brazilian toy regulator, INMETRO, to address issues which have emerged under Ordinance 503, its proposed toy safety and certification regulation.

As anticipated, INMETRO has issued for public comment Ordinance 503, which is intended to be a companion regulation to revise some of the more problematic requirements of Ordinance 563, issued more than a year ago and requiring all toys sold in Brazil to be registered and certified based on testing to the MERCOSUR toy safety standard NM300.

The Toy Association has had concerns that Ordinance 563 could overly burden toy companies that sell product in Brazil and has been actively engaged with INMETRO to adapt language that would more closely align the regulations with international norms. One of the more onerous requirements of Ordinance 563 is the “family registration” system, which would be difficult for the toy industry to implement.

While not all issues have been addressed, INMETRO has granted a one-year delay in the effective date for Ordinance 563 to January 2020. However, there are some new issues in Ordinance 503, including deviations from NM300 and ISO 8124, this latter is the international safety standard with which The Toy Association would like the regulations to align.

In addition, the Association will shortly be submitting comments to the Brazilian Ministry of the Environment regarding their proposed RoHS (Restriction of Hazardous Substances) regulation, which will apply to electrical and electronic products, including electric and electronic toys, and any toy operated by batteries. We are advocating for full alignment with the current EU RoHS II requirements, including all exemptions.  

Members with questions can address them to Al Kaufman, senior vice president of technical affairs, or Rebecca Mond, vice president of federal government affairs.