CEN and CENELEC support the objectives of the revision of the safety of toys Directive (2009/48/EC) and the proposal for a safety of toys Regulation (COM (2023)462) to increase children’s safety and improve protection from harmful chemicals.
We welcome that standards continue to play an important role in achieving these goals, as they specify technical details and thus help toy manufacturers to comply with the essential requirements set out in the Regulation. Since the European standardization organizations review each European standard at least every five years to ensure that it is up to date, the reference to harmonized European standards ensures that toys placed on the European internal market are state of the art.
A summary of the CEN and CENELEC key messages is presented below.
· Harmonized European standards should always take precedence over common specifications in the implementation of the Regulation.
· There needs to be a horizontal approach to common specifications across all European Union Single Market Legislation/ European Union Legislation under the New Legislative Framework
· Annex III of the proposed Toy Safety Regulation should refer to the general warning sign ISO 7010-W001.
· Analytical feasibility, e.g., for chromium (VI), should be taken into account when setting limit values.
· Organic tin limit values should be removed from the “element” migration limit table.
· The harmonization between several directives is key to enable an interoperable digital product passport.
In response, we would like to draw attention through our position paper to some of the passages of the proposed Regulation that could be further specified or improved in the legislative process.
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Ministry of Commerce of the people's Republic of China
State Administration for market Regulation
Standardization Administration of China
National Center of Standards Evaluation,SAMR
China National Institute of Standardization
China zhijian Publishing House