ANEC is in favour of evaluating the Toy Safety Directive. Although the Directive certainly brought improvements to toy safety in Europe, the following issues need to be addressed in our opinion:
• the chemical requirements for toys need to be strengthened significantly. This position is shared by several Member States. The lack of adequate provisions to exclude exposure to dangerous substances such as CMRs requires a fundamental revision of the chemical requirements of the Directive. A key point in this context is the broadening of the Comitology to set limits also for toys for children above 36 months of age (other than those intended to be placed in the mouth).
• while the comitology procedure only applies for chemicals, it should also work for mechanical and physical requirements for toys for children under 3 years of age.
• The Directive must be updated to ensure that it is in line with the new ‘security for safety’ concept of the general legal framework. See ANEC and BEUC position on the ‘Cybersecurity of connected products’, http://www.anec.eu/images/Publications/position-papers/Digital/ANEC-DIGI....
• the Directive needs to be amended to regulate impulse noise levels in toys, and to set the limit to what is allowed for adults in industry according to Directive 2003/10 /EEC. We see no safety-based reason to expose children to higher levels than is allowed for adults.
• in the interest of legal certainty, specific requirements for visibility and legibility of warnings on toys (e.g. a minimum letter size) need to be introduced, in order to enable Member States to enforce these requirements in a uniform way.
• When buying toys online, consumers often don’t get the required information and warnings they would find when buying toys in a physical shop.
• The Regulation on Enforcement and Compliance, proposed by the Commission in November 2017, covers toys. In this context, we reiterate the need to increase controls and market surveillance of toys; to set up a Pan-European Accident and Injury Database in order to systematically collect information about accidents and injuries that occur because of dangerous toys; to improve traceability along the supply chain, also for toys that are sold online.
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