Toy Association Members Urged to Participate in Survey on EPA Ban of Flame-Retardant Plasticizer

April 1, 2021 | The Toy Association is urging members and the greater toy community to participate in a confidential survey from the National Association of Manufacturers (NAM) on the modification of a final Environmental Protection Agency (EPA) rule that bans the processing, importation, and distribution of products containing the flame-retardant plasticizer phenol, isopropylated phosphate (3:1) (PIP (3:1)).

While initial input from toy manufacturers indicated no known presence of the chemical in toys, it has since been determined that PIP (3:1) is commonly used in flexible electronic components, such as wire insulation, that may pertain to the toy industry. The NAM survey includes a list of products known to contain the substance, but it is not exhaustive. Members are encouraged to check their supply chains and complete the survey by April 12.

The rule is final, but as a direct result of joint advocacy by The Toy Association, NAM and others, the EPA issued a 180-day No Action Assurance on March 8 and immediately opened a new 60-day public comment period for reevaluation of the rule. This extension offers those in the toy industry, among others, a critical opportunity to further advise the agency on where this substance may exist; what alternatives are available; and what a timeline for substitution, if feasible, would be. The EPA also noted that this extension will help to avoid significant disruption to the supply chain for a wide variety of articles that may be impacted by the rule.

Questions on this topic may be directed to The Toy Association’s Alan Kaufman, senior vice president of technical affairs.