President’s Letter – September 6, 2011:  Tools to Help You Meet New EU Requirements

September 6, 2011 |   On July 20th, the revised European Union Toy Safety Directive (TSD) placed a new set of requirements on companies selling toys in the European market.  There were two significant changes:

  • First, the “risk assessment” that manufacturers must perform on every toy sold in the EU must not only evaluate compliance with safety standards but also assesses the safety of all chemicals contained in that product. 
  • Second, the number and scope of documents that a toy manufacturer must maintain for each SKU sold in the EU was expanded and the retention requirements extended until 10 years after the product is no longer available at retail. 

“But,” you say, “I already know there aren’t any prohibited chemicals like lead or phthalates in my toys because I specify that they must not be there and I test to be sure they are not.” 

No longer good enough. 

Your responsibility under the new TSD is to assess the safety of every chemical in the toy – be it a pigment, stabilizer, phthalate-alternative plasticizer or other – and to maintain the assessment results in a long-term dossier.  The tests can be a complicated and expensive undertaking requiring labs and toxicologists. And the record-keeping may be burdensome for many companies, especially small and mid-size manufacturers. 

Against this background, TIA and our colleagues at Toy Industries of Europe (TIE) set out to find a convenient tool that could assist toy companies in complying with the new chemical safety assessment requirements in the most efficient and least expensive way.  In addition to the services provided by independent testing laboratories, we found SciVera, a Charlottesville, VA-based company that has provided similar tools for other industries.  SciVera offers a web-based product that evaluates ingredient information provided by you and your suppliers against an extensive database of peer-reviewed toxicological data to assess the product for a comprehensive panel of potential safety hazards.  And because chemical formulations may be proprietary, this system securely preserves the privacy of proprietary formulas. The SciVera platform allows personnel without extensive scientific or toxicological background to manage a process which is compliant with the revised TSD requirement, without the need to utilize toxicologists or other more expensive options. 

Meanwhile, our colleagues at the Hong Kong Toys Council (HKTC) have worked with a software developer to create an online repository, the Chemical Management Database, or CMD, for all the documents that must be maintained by toy manufacturers.  Because we have worked together on these efforts, the information entered into the HKTC-led CMD can easily be uploaded into the SciVera chemical safety assessment tool. 

TIA and TIE have no ownership stake in either of these new tools.  We assisted in their development because it is the duty of your trade associations to provide collective solutions to industry challenges.  We believe these tools effectively address the existing EU requirements, and will likely have application to the emerging requirements in U.S. states such as California, Washington and Maine, and those that may soon appear in other jurisdictions.

Additionally, the consistency of chemical safety assessments that are provided through these systems will likely be a compelling argument against a proliferation of new laws and regulations. 

We will be providing additional information and details about these tools in the near future.  In the meantime, please know that we are working hard to provide you with useful and cost-effective tools that offer real value for your companies. 

Warm regards,

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Carter Keithley
TIA President