Hazardous Substances In Electrical And Electronic Toys

April 25, 2014

Posted Under: RoHS Compliance Services RoHS Consulting Services

It is important that the significance of Children’s play toys are recognized as modern European societies face various economic, social and environmental challenges.

Children’s play toys have a vital role in this modern world. To improve the intellectual and physical growth in children toys are essential. We can even say that toys are the intimate friends of children. Many countries have implemented rigorous safety measures on toys as most of the children who play with these toys are under the age of 5. Compared to adults, children are more sensitive to chemicals and their bodies should never be exposed to hazardous chemicals or materials.

Chemicals are used in toys mainly to make them softer. There are certain chemicals that have been identified as hazardous and they are strictly prohibited from use during the manufacturing processes for toys. Therefore there are regulations created to control and forbid the use of hazardous chemical substances in toys.

In July 1989, the British government adopted the EEC toy safety directive ( 88/378/EEC) and this regulation came in to effect on the 1st of January 1990.This directive ensures that there is free circulation of toys and all these toys are required to have a CE marking along with the name and the address of the first supplier.

In 2012, a final report was prepared for the European Commission, which revealed that some of the member states had argued stating toys, irrespective of whether their primary function uses electrical energy, they are under the scope of RoHS as these toys are under the category 7 of the WEEE Directive. These Member States are known to have considered all toys that use electrical energy to fall under the scope of RoHS. For MS national legislation all EE toys, including the secondary function toys have been under the scope of RoHS and consequently the expectation is that the national requirement may be that all EE toys must be RoHS 2 compliant by January 2013.

The original toy directive that is 88/378/EEC was published in 1988. The EC (European Commission) reviews and updates this directive periodically to ensure that it achieves its objectives. Recent technological developments in the toy industry have raised new issues with regard to the safety of toys in areas such as noise, chemicals, and choking hazards. As a result, a newer EU Toy Safety Directive named 2009/48/EC was introduced to strengthen and update the rules on toy safety. This directive (2009/48/EC) was adopted on May 11 2009 by the European commission and this came into effect on the 20th of July 2011.

Benefits of RoHS EU Toy Safety Directive

RoHS, an environmental directive, is independent from the EU Toy Safety Directive (2009/48/EC) and may be it would apply to all Electrical and Electronic Equipment, but EE toys are definitely included. In its recast, which is known as RoHS 2, the scope extends from toys with a primary electrical function (RoHS, Category 7) to all EE toys, including those whose electrical function is only secondary to the overall play value. For example, a cuddly toy that talks – its primary function as a cuddly toy was exempt by a guidance document from RoHS 1, but now it will fall under the scope of RoHS 2 because it is electrically powered to fulfill this intended function.

Nitrosamines and nitrosatable substances shall be prohibited from use in toys that are intended to be used by children who are under the age of 36 months, or in other toys that are meant to be placed in the mouth if the migration of these substances are equal to or higher than 0.05 mg/kg and 1 mg/kg for nitrosamines and nitrosatable substances respectively.

Although the overall level of compliance to RoHS in the EU is high, some of the product categories are problematic. According to all enforcement reports, the biggest problem is the presence of lead in imported electrical toys. In proportion to the Commission’s knowledge, the member states will control those activities that are focused on sold equipment and not on components, as the RoHS restrictions apply to the finished product.

The Toy Industry Association supports and facilitates trade between the United States and the European Union. Mutual recognition could address most of the divergences in regulations that would burden companies who sell to both the markets while reinforcing consumer confidence that toys compliant with either standard can be trusted as safe for children. Moreover, establishing a strong regulatory cooperation agreement will ensure a joint U.S. – EU leadership in international regulations.This provides a basis for future trade agreements and also helps to provide a benchmark for the development of other standards pertaining to other countries.

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