The hearing took place on the 23 June 2008 and the final amendments will be made on 9 September 2008.
The European Child Safety Alliance is an initiative of EuroSafe that brings together experts in the field of child safety from across Europe to work cooperatively to address the leading cause of death to children in every Member State in Europe – injury. Most non fatal injuries to young children occur in the home, a location that should provide the greatest safety, security and enjoyment for children and their families. The rapid alert system of the European Commission, RAPEX, reported that the most frequently identified category of serious risk notifications in 2007 was toys.
The European Injury Data Base (IDB) from 2002-2006, estimated that 120,000 children 0-14 years old are treated in accident & emergency rooms each year for injuries caused by toys in the European Union 27 Member States. Therefore polices that will assist in advancing the safety of toys and reduce childhood injuries are an important undertaking.
The European Child Safety Alliance welcomes the aim of the Commission to better adapt the directive to the toys on the market, but the proposal falls short of what is needed to protect children from dangerous toys throughout Europe. In discussions with European consumer voice in standardisation (ANEC) and the European Consumers’ Organisation (BEUC), the European Child Safety Alliance has agreed the key gaps and have outlined in their position paper responding to the toy directive. They supported the need for the following actions to be included into the revision of the directive:
1. Introduction of the precautionary principle Given that injury data cannot reflect the risks of new products not yet on the market, and that children are part of the most vulnerable population, the only acceptable solution is to introduce the precautionary principle as a legal basis into the directive.
2. Introduction of a comitology procedure A comitology procedure is the only procedure which would allow the directive to be adapted quickly to new developments or risks, thereby avoiding a long co-decision process or a standardisation procedure. Such a procedure should be introduced and be applicable to all provisions in the directive that support the essential safety requirements.
3. More stringent and clear requirements on chemical properties They called for a total ban on carcinogenic, hormonal distruptors, mutagenic and reprotoxic substances and other chemicals of very high concern. They also call for a total ban of allergens and sensitizing chemicals.
4. An obligatory EC-type examination for certain types of toy Third-party conformity assessment should be made obligatory for certain types of toys. For example toys for children younger than three years, toys that present an element of risk which cannot be eliminated, or toys that have previously caused serious accidents (such as toys containing magnets) should all have obligatory third-party conformity assessment.
5. Specific requirements for warnings To be meaningful, warnings should catch the buyer’s attention, and be present on both the toy itself and its packaging. In particular, the most important warnings (e.g. this toy is not suitable for children under three) should be clearly visible before purchase. The Alliance consider that warnings should always give information on both the inherent hazard of the toy and the risks related to its use.
6. Requirements for toys in food They ask for the proposed requirements to be strengthened in order to cover all risks arising from the combination of toys and food products. The Child Safety Alliance asked, in particular, for the requirements for the packaging of these toys to cover all foreseeable hazards, including internal airway obstruction. They also strongly recommend that specific warnings should be affixed on such products.
Country representatives of the European Child Safety Alliance will be in contact with the MEPs after the hearing to discuss the position on the revision of the toy safety directive.
For more information
European Commission Enterprise and Industry website
EPHA related articles
Child Safety Good Practice Guide
