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,

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Carter Keithley
ckeithley@toyassociation.org