Analysis of the EUs New Toy Safety Regulation Proposal and Enterprises Response Strategies

With the European Union releasing a new toy safety regulation proposal, toy manufacturers around the world are facing a series of new challenges and opportunities. This article aims to deeply analyze the EUs new toy safety regulation proposal and provide effective countermeasures.

On October 4, 2023, the EU released a new toy safety regulation proposal through the WTO, which is expected to come into effect in 2024 - 2025 and be implemented in 2027 or 2028. This proposal intends to replace the existing Directive 2009/48/EC, aiming to strengthen the control of harmful chemicals in toys and introduce a product passport system to provide compliance information.

Requirements for Toys
Toys should meet general and special safety requirements, including aspects such as physical, mechanical, flammability, chemical, and electrical properties. Special emphasis is placed on comprehensive safety protection including childrens mental health and cognitive development.

Revision of Chemical Properties
The regulation has revised the general restrictions on harmful substances, including carcinogens, endocrine - disrupting substances, respiratory sensitizers, etc.

Obligations of Economic Operators
Manufacturers need to create a product passport for toys containing compliance information, replacing the traditional EU declaration of conformity.

Presumption of Toy Conformity
When manufacturers adopt harmonized standards or common specifications, the presumption of toy conformity remains valid.

Introduction of the Product Passport
The product passport will contain key information about the toy, including a unique product identifier, manufacturer information, a list of allergenic fragrances, etc.

Conformity Assessment
When manufacturers do not adopt harmonized standards or common specifications, third - party certification by a notified body is required.

Authorization Act
This proposal authorizes the European Commission to adjust the warning provisions and the permitted uses of specific substances in Annex III.

Pay Attention to and Adapt to the New Regulation
Manufacturers should keep informed of and adapt to the requirements of the new regulation in a timely manner, especially the revision of chemical properties and the introduction of the product passport.

Strengthen Product Quality and Safety Management
Manufacturers need to strengthen the quality and safety management of products to ensure that they meet the requirements of the new regulation.

Use International Trade Mechanisms to Put Forward Demands
Use the WTOs notification and comment system and the special trade concerns system to put forward reasonable demands and opinions, especially regarding discriminatory/unreasonable clauses in regulations or standards.

Explore New Markets
Actively respond to the Belt and Road Initiative, utilize free trade agreements such as RCEP and CAFTA to explore emerging markets and reduce the pressure of EU market supervision regulations.

The EUs new toy safety regulation proposal sets higher safety standards and regulatory requirements for global toy manufacturers. Manufacturers need to actively adapt to the new regulatory environment and strengthen product quality and safety management.

For more details, see the original regulation:Stepping up toy safety – European Parliament