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MEMO/11/448

Brussels, 23 June 2011

Toy safety is the European Commission’s priority

Brussels/Rotterdam 23 June 2011: Member States and economic operators will need to respect the substantially strengthened EU-rules on toy safety from 20 of July 2011. By this date all Member States will need to have incorporated all requirements set by the new Toy Safety Directive adopted in 2009.

This memo informs on:

  • The new improved market surveillance, CE marking and obligations for economic operators

  • The new safety requirements which Member States need to respect

  • Figures and facts on the European toy industry, an important industry sector.

1. Improved market surveillance, CE marking and obligations for economic operators

On 30 June 2009 the new Toy Safety Directive (2009/48/EC) was published, giving consumers assurance that toys sold in the EU fulfill the highest safety requirements world-wide, especially those relating to the use of chemical substances. The Directive only sets the essential safety requirements that toys placed on the market in the EU have to fulfill. The technical specifications of products are fixed by standardization organizations.

Standards are particularly appropriate for the toys sector, since they can be updated more rapidly to take account of new product and application developments. The Commission maintains a list of all harmonised standards applicable to toys under the Directive. The references of those (non-mandatory) standards are published in the Official Journal of the European Union.

Obligations for toy manufacturers, importers and distributors

  • All toys marketed in the EU must carry a CE conformity marking, which is the manufacturer's declaration that the toy satisfies all essential safety requirements (the CE marking now needs to be affixed also on its packaging if the mark is not visible from outside the packaging). Toys that are CE marked enjoy free circulation in the European Economic Area (EEA).

  • Before obtaining the CE mark a manufacturer has to carry out a safety and conformity assessment. The manufacturer has to establish more comprehensive technical documentation for all his/her products, including information on chemicals used and he has to ensure traceability.

  • Importers must check whether manufacturers have carried out conformity assessment of toys correctly and if necessary must carry out random tests themselves. If toy manufacturers/importers/ distributors do not fulfil the safety requirements of the Directive, Member States can impose penalties.

Manufacturers can chose between two modules for conformity assessment:

Self-verification: The manufacturer applies the harmonized standards published in the Official Journal covering all relevant safety requirements and puts in place an internal production control procedure. He draws up a technical documentation and the EC declaration of conformity. Then, he affixes the CE marking, his name and address and an identification element (traceability) before placing the toy on the market.

Third party verification or certification: The manufacturer submits the model of the toy to EC-type examination carried out by a notified body and puts in place the conformity to type procedure based on internal production control. The notified body issues an EC type examination certificate stating that the toy complies with the essential requirements of the Toy Safety Directive. The manufacturer draws up a technical documentation and the EC declaration of conformity. Then, he affixes the CE marking, his name and address and an identification element (traceability) before placing the toy on the market

More information can be found in Modules A, B and C of annex II to Decision N°768/2008/EC.

Market surveillance is a fundamental tool in creating confidence in the European market and its legislation

Strong national market surveillance systems

  • Member States will have to ensure that market surveillance authorities (list of these bodies in the Member States) perform adequate checks at the EU external borders and within the EU including visits to premises of all economic operators to make sure that dangerous toys are immediately prohibited or withdrawn.

  • Market surveillance authorities can destroy toys presenting a serious risk.

  • Member States have to investigate infringements and to take action to bring about their cessation, in order to ensure only safe toys are placed on the EU market.

  • Cooperation with foreign partners, in particular China, is also vital for toy safety. The Commission provided and will continue to provide training to manufacturers in China.

Toys that comply with Europe’s stringent toy safety requirements and other EU legislation are safe but market surveillance must be stepped up to ensure that rogue traders cannot put inferior products on the market. It is imperative to concentrate on the points of entry into the EU as it is difficult to detect non-compliant or unsafe toys once they are on the market. Increased market surveillance would also help to combat the problems of counterfeiting and parasitic copying, which are of particular concern to the toy sector and consumers alike, as counterfeit products can compromise the safety of children.

Despite a slight increase in the number of notifications of toys in the RAPEX 2010 Annual Report, there was a substantial decrease in the percentage of toys versus other categories – 25% in 2010 compared to 28% in 2009. The number of notifications is a reflection of the high level of scrutiny of toys due to the sensitive nature of child safety, and the very low tolerance of risk. The number of toys notified on RAPEX is by no means an indication that toys are unsafe.

2. New safety requirements which Member States need to respect

Chemical substances

Children, as a vulnerable group of consumers, need to be protected against risks caused by chemical substances in toys. In order to ensure a high level of protection, the rules related to their use have been strengthened.

  • Chemicals that could provoke cancer, change genetic information or harm reproduction, so-called CMR (Carcinogenic, Mutagenic or toxic for Reproduction) substances are no longer allowed in accessible parts of toys. E.g. Puzzle mats will be safer to play with.

  • For most substances (mainly heavy metals e.g. nickel, mercury) limits have been reduced in such a way that only traces that are compatible with good manufacturing practice will be allowed. These limits can be updated in order to take into account the development of scientific knowledge. E.g. Reactions due to contact dermatitis by hexavalent chromium will be reduced.

  • Allergenic fragrances are completely forbidden, if they have a strong allergenic potential, or have to be labelled on the toy if they are potentially allergenic for some consumers.

Enhanced safety requirements to prevent choking risks

Technological developments in the toy market raised new issues related to the safety of toys and raised consumer concerns. In order to take into account these developments, certain safety requirements have been enhanced.

  • Rules on toys and their parts to prevent children from choking or suffocating are strengthened, inter alia to deal with the new risk of toys such as those with suction cups or a toy trumpet can no longer have small parts at all.

  • Toys in or co-mingled with food always need to be in a separate packaging, in order to avoid the potential risk of choking due to the association of toys and food creating confusion for consumers between the food and the toy.

  • Toys which are firmly attached to a food product at the moment of consumption and which require the food to be consumed before getting access to the toy are prohibited.

Warnings on toys

The new directive promotes safe conditions for using toys, by enhancing the provisions on warnings which should accompany the toy.

  • In order to prevent accidents, warnings need to be marked on toys in a clearly visible, easily legible manner in a language easily understood by consumers.

  • In order to prevent the misuse of warnings and circumvent the applicable safety requirements, warnings that contradict the intended use of the toy are not allowed. For example, the warning “not suitable for children under 36 months” can not be affixed on toys clearly intended for this age group.

  • Toys contained in food or co-mingled with food shall bear the warning: “Toy inside; Adult supervision recommended”.

3. Figures and facts on the European toy industry, an important industry sector

The following figures were provided by Toy Industries of Europe (TIE), the trade association for the European toy industry:

The European toy industry comprises over 25% of the total world toy market. The toy industry is highly international and is one of the most dynamic business sectors in Europe. Around 80% of the sector is composed of small and medium sized enterprises (SMEs) which have less than 50 employees.

Total production of toys in the European Union (EU) in 2009 was approximately €5 billion (manufacturer’s price), of which 80% was generated by France, Ger-many, Italy, Ireland, Spain, the UK, the Czech Republic and Poland.

Almost 2,000 manufacturers work in the toy sector in the EU, approximately 80% of which is composed of SMEs.

The toy industry directly employs nearly 100,000 people across the EU in production, research and development, marketing, sales, distribution, and many other services.

Total exports of traditional toys1 from EU27 countries to non EU countries in 2010 were €1.05 billion (+10.2% compared to 2009).

Total imports of traditional toys from non EU countries to EU27 in 2010 were €6.96 billion (+20.3% compared to 2009).

The total retail market for traditional toys* in the EU totalled €14.485 billion in 2009.

In terms of revenue (turnover at retail including tax), the European toy market was the largest in the world in 2009.

The leading toy category in the EU in 2009 was infant/preschool toys with almost 20% market share.

The toy trade in figures

Destinations of exports to non EU countries

US

17.1%

Switzerland

15.9%

Russia

11.3%

Norway

7.8%

Australia

7.7%

Japan

6.1%

Turkey

2.5%

South-Korea

2.5%

Hong Kong

2.0%

Canada

1.8%

China was the leading importer: it accounted for 86.2% of total imports. Chinese manufacturing is part of the global supply chain of both European and international manufacturers who have to ensure that their toys meet all EU safety requirements regardless of where they are manufactured.

Sources of imports from non EU countries

China

86.2%

Hong Kong

4.1%

US

1.5%

Taiwan

1.4%

Indonesia

1.2%

Thailand

1.0%

Vietnam

0.9%

Mexico

0.4%

Israel

0.4%

Japan

0.4%

Christmas 2010 was one of the most difficult seasons ever experienced by the European toy industry due to severe weather conditions during the biggest trading weeks of the year. Despite the difficult economic conditions and the severe weather in December 2010, the toy sector did better than expected in the 27 EU Member States. Traditional toy sales in the EU27 amounted to €15.5 billion in 2010.

In terms of market share, the majority of EU toy sales (73%) took place in the industry’s five largest European countries, that is France, Germany, Italy, Spain and the UK. Traditional toy sales in the top five markets were up by 4% in value year on year in 2010 at €11.4 billion.

In terms of revenue (turnover at retail including tax), the European toy market was the second largest in the world in 2010 with the US as the largest market for traditional toys. Total world toy sales in 2010 were approximately €62 billion in 2010, which means that the European market constituted around one quarter of the global toy market.

The leading toy category in the industry’s five largest European markets was infant/preschool toys with almost 20% market share. This category was followed by games/puzzles (11.9%), dolls (11.1%) and outdoor and sports toys (10.9%). As in previous years, these categories combined comprised over half of all toy sales in the top five markets in 2010.

Leading toy categories

 Infant/preschool toys

19.4%

Games/puzzles

11.9%

Dolls

11.1%

Outdoor and sports toys

10.9%

Vehicles

9.7%

Building sets

8.4%

Arts and crafts

6.5%

Plush

6.0%

Action figures and accessories

5.9%

Youth electronics

2.6%

All other toys

7.5%

The success of the toy sector depends heavily on its capacity to innovate and introduce new products that meet changing consumer needs and wishes. The toy industry dedicates an important part of its investment to market analysis, research and development (R&D) and the protection of intellectual property. The toy sector is one of the most dynamic business sectors in Europe: approximately 60% of toys on the market each year are newly developed products. While some European companies moved production facilities to Asia, research facilities remain in Europe.

The economic footprint of the toy industry in the EU

Around 80% of the sector is composed of SMEs which have less than 50 employees. Even within the main EU economic operator countries, France, Germany, Italy and Spain, toy production is concentrated in some regions which are highly dependent upon the activity of these SMEs as the main source of economic activity and employment.

Main EU regions of toy production

Germany

Bavaria, Baden‑Württemberg

Italy

Lombardy, Piemonte, Marche, Veneto

France

Franche-Comté, Jura, Rhône-Alpes

Spain

Valencia, Cataluña, Alicante

Other regions where toys are economically important are Waterford in Ireland; Billund in Denmark; Malta; South Bohemia and Brno in the Czech Republic; Silesia in Poland; and the North West, East Midlands, Thames Valley/Heathrow Airport and Kent in the UK.

In the past, some toy production migrated to China to take advantage of the more cost-effective manufacturing that was available there. However, we have recently witnessed renewed investment in Europe which is presumably due to the increasing cost of wages and commodities in China. For example:

  • In May 2011, Smoby Toys, the largest French toymaker, opened a new production centre in Arinthod, in the Jura.

  • LEGO is increasing its production capacity at its factory in Kladno, Czech Republic, by 25% from May 2012. The company will hire 200 new employees and will open two new production lines where packaging for European market will be done. At the present time the factory employs just over 1,100 people. LEGO recently expanded its capacity at the facility in Kladno but the increased demand for LEGO products means the capacity will be expanded again. LEGO also expects to open a new factory in Hungary in 2013, creating another 1,000 jobs.

  • In Spain, toy maker Injusa recently announced that it will move its Chinese production back to its factories in Alicante after eight years manufacturing in the Chinese province of Dongguan. Injusa intends to invest €4 million in technology and create 30 more jobs.

While some European companies moved production facilities to Asia, product development, R&D, marketing, and sales facilities remain in Europe. This means that while some components may be manufactured outside Europe, it would be misguided to ignore the value added in Europe and the number of jobs the toy industry provides to Europeans.

More information

IP/11/779

1 :

All figures refer only to traditional toys and do not include video games.


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