President’s letter – March 8, 2011: A global
marketplace needs a global perspective
March 8, 2011 | The world has become a huge, unified
global marketplace and we are all better off for it. However,
legislators and regulators around the planet seem to have universally
ratcheted up the pace at which they are creating unique national or
regional safety requirements.
U.S.-based toy companies – even those who do not yet have
export markets – are already feeling the burdens of new and
emerging regulatory activities:
- Canada has adopted a new lead content limit for
toys that is just marginally lower than the U.S. and the EU, thus using
different standards to segregate North America into two toy markets.
- The European Union’s Toy Safety Directive
(TSD) has imposed new chemical testing requirements on toys that are now
being emulated in proposed legislation by several U.S. states.
- The United Nations Environmental Program (UNEP) is
also examining toy supply chain information systems to determine whether
to recommend new worldwide substance management control
regulations.
Absent the appropriate risk-based justification, any stricter limits
and related testing requirements being imposed by governments around the
world will simply make toys more expensive … not
safer. Each arbitrary limitation adds a burden that
makes it difficult for a toy company to develop new products, expand its
markets, run its business and keep its doors open. The
negative trickle-down effect impacts everyone in the supply chain, from
OEMs to retailers.
This is why TIA remains stalwart in its assertions that sound science
must prevail in rulemaking and steadfast in its active leadership of
both advocacy and technical efforts to align global toy safety
standards:
- At last month’s U.S.-hosted International Consumer Product
Health and Safety Organization’s annual Symposium, we partnered
with the Commerce Department, U.S. Trade Representative and CPSC to
organize a panel on the alignment of toy standards.
- In Washington, DC last week, we took the next steps to progress the
Asia Pacific Economic Cooperation (APEC) Toy Safety Initiative to align
toy safety standards within the countries bordering the
Pacific.
- Later this month, we are co-hosting with the Commerce
Department’s National Institute of Standards and Technology a
discussion of toy safety and certification initiatives with
representatives of the Gulf Cooperation Council (GCC) Standardization
Organization (GSO) which represents six member nations in the Middle
East.
- And of course, we continue our leadership in standards bodies such
as ASTM and ISO to push for the harmonization and alignment of technical
content.
We should sleep well knowing that we hold ourselves to an
appropriately higher standard than most other industries because our
consumers are vulnerable and precious. Data from the U.S. Consumer
Product Safety Commission and from the regulatory bodies of other
nations verify that the toy industry has a long history of doing the
right things to protect children. But the regulatory activities we
see emerging throughout the world may instead cause us a few bad dreams
in the nights ahead.
Warm regards to all,
Carter Keithley
ckeithley@toyassociation.org
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