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Revision of the Toy Safety Directive

Single market

Current legal provision on toy safety lay down the safety and other requirements that toys must meet before they can be marketed in the EU. The main objective of the initiative is to better protect children against risks in toys, in particular from chemicals. It builds on the work on chemicals (in particular Fitness Check on Chemicals and Chemicals Strategy for Sustainability) as well as an evaluation of the current rules completed in 2020.

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Public consultation

ID: 13164

Lobbying Activity

43 responses

Consultation response

Bureau Européen des Unions de Consommateurs, 17 Oct 2023

ANEC and BEUC welcome the draft Toy Safety Regulation (TSR) AIM 1 protecting children against harmful chemicals We strongly support banning known and suspected endocrine disruptors, respiratory sensitizers and STOTs. Combined with the limited derogation options, this will protect children against…

Consultation response

EuroCommerce, 31 Oct 2023

We welcome the new definitions relating to the introduction of the Digital Product Passport (DPP) as ensuring legal certainty. We see however the risk of not linking the definitions to the current proposal on the Eco-design for Sustainable Products Regulation (ESPR). Coherence among the two…

Consultation response

Wirtschaftskammer Österreich, 31 Oct 2023

In der Beilage finden Sie unsere Stellungnahme.

Consultation response

Verband der Chemischen Industrie e.V., 31 Oct 2023

The German chemical industry (VCI) would like to comment on the proposed Regulation regarding Article 3 (36) and Article 17 on topics overlapping with ESPR (Ecodesign for Sustainable Products Regulation): In principle, we welcome that there is or should be uniform definitions across different…

Consultation response

Independent Retail Europe (formerly UGAL - Union of Groups of Independent Retailers of Europe), 26 Oct 2023

Independent Retail Europe is the voice of groups of independent retailers, bringing together 23 groups of independent retailers and national associations representing them. Our members provide collectively more than 6.5 million jobs through their 403.900 independent retailers, who manage more than…

Consultation response

Independent Retail Europe (formerly UGAL - Union of Groups of Independent Retailers of Europe), 2 Nov 2021

Independent Retail Europe considers Directive 2009/48/EC on the safety of toys (Toy Safety Directive / TSD) generally useful and welcomes the clear obligations for distributors. This enables retailers – and especially SMEs – to apply the regulation more efficiently and with legal certainty. We do…

Consultation response

Toy Industries of Europe, 31 Oct 2023

Toy Industries of Europe welcomes the attempt to reinforce the EU's toy safety rules. However, we're worried that the proposal does not make it easier to place safe toys on the market and does not make it more difficult (impossible) to place unsafe toys on the market. Whereas toys compliant with…

Consultation response

Toy Industries of Europe, 2 Nov 2021

See feedback enclosed!

Consultation response

DIN Deutsches Institut für Normung e. V., 30 Oct 2023

DIN supports the objectives of the revision of the Toy Safety Directive 2009/48/EC and the proposal for a Toy Safety Regulation (COM(2023)462) to increase childrens safety and improve protection from harmful chemicals. We welcome that standards continue to play an important role in achieving these…

Consultation response

5Rights Foundation, 31 Oct 2023

5Rights Foundation welcomes the opportunity to comment on the draft European Commission proposal for a Toy Safety Regulation (TSR). This is a critical opportunity to fully implement the EUs Strategy on the Rights of the Child as well as reflect international guidance, best practice and technical…

Consultation response

The LEGO Group, 26 Oct 2023

The LEGO Group welcomes the Commissions proposal to review and modernize the EUs toy safety legislation framework with the new Toy Safety Regulation. As we note in our attached feedback document, we see various opportunities for more efficient enforcement and compliance, as well as various points…

Consultation response

Inter Ikea Systems BV, 27 Oct 2023

IKEA is a global home furnishing brand that brings well-designed, functional, affordable, and sustainable products to the many people. In IKEA we want the home to be a place where families with children love to play. We know play is learning for life, and we in IKEA have an important role to enable…

Consultation response

International Chemical Secretariat, 30 Oct 2023

Overall, we welcome the focus on increased protection from the most harmful substances for children from the use of toys, and the strengthening enforcement of this product group. We also support transforming the directive into a regulation. We particularly welcome the following elements of the…

Consultation response

DEKRA e.V., 31 Oct 2023

DEKRA, a global leader in testing, inspection, and certification, is committed to safety in every domain. Our vision focuses on a safer world, and toys, crucial in a child's formative years, are no exception to our mission of protecting human life. We support the European Commission's initiative to…

Consultation response

Rådet for Grøn Omstilling, 31 Oct 2023

Rådet for Grøn Omstilling bifalder, at EU-Kommissionen har fremlagt et gyldigt forslag til en ny forordning om legetøj, der har til formål at beskytte børn, som udgør en af de mest sårbare grupper i samfundet. Vi er meget enige i konklusionerne fra konsekvensanalysen, og anerkender, at mange af…

Consultation response

DEKRA e.V., 2 Nov 2021

DEKRA welcomes the European Commission’s initiative to review the Toy Safety Directive. We would like to support turning the Toy Safety Directive into a Regulation. We believe, that this will ensure consistent application of the toy safety requirements by all Member States. We also agree with…

Consultation response

European Committee for Standardization, 31 Oct 2023

CEN and CENELEC welcome the revision of the Toy Safety Directive and to continue the strong cooperation between the European Commission and European Standards. Understanding this, it is important to highlight: - Insist that standardization is the primary route for harmonized technical…

Consultation response

Swedish Society for Nature Conservation, 30 Oct 2023

Swedish Society for Nature Conservation (SSNC) welcomes the Toy Safe Regulation, with ambition to make toys safer for children. The draft includes some positive changes compared to the Toys Directive, while other changes are missing to protect children as much as possible. SSNC welcomes following…

Consultation response

Decathlon SE, 2 Nov 2021

We welcome the initiative of the European Commission and we agree with the overall aim of the initiative to enhance the protection of children through the revision of the Toy and Safety Directive. - We support "the extension of the general risk-assessment approach to be extended to other most…

Consultation response

The European Consumer Voice in Standardisation, 30 Oct 2023

ANEC and BEUC welcome the draft Toy Safety Regulation (TSR). AIM 1 protecting children against harmful chemicals We strongly support banning known and suspected endocrine disruptors, respiratory sensitizers and STOTs. Combined with the limited derogation options, this will protect children against…

Consultation response

The European Consumer Voice in Standardisation, 28 Oct 2021

ANEC welcomes the EC’s inception impact assessment, which contains many points we agree with. We agree the aim of this initiative should be to further strengthen the protection of children against possible risks in toys, in particular from chemicals & to further complete the Single Market for toys.…

Consultation response

Forbrugerrådet Tænk (the Danish Consumer Council), 27 Oct 2023

Congratulations to the Commission on presenting a valid proposal for a new regulation on toys aimed at protecting our children, the most vulnerable citizens. Forbrugerrådet Tænk agrees with the conclusions from the Impact Assessment and we are pleased to see that a lot of these have been…

Consultation response

Forbrugerrådet Tænk (the Danish Consumer Council), 1 Nov 2021

Forbrugerrådet Tænk welcomes the EC’s inception impact assessment, which contains many points we agree with. We welcome a revision of the TSD and we agree that the main aspects to be tackled are chemical risks, internet-connected toys, and compliance & enforcement. We suggest mandatory labelling…

Consultation response

TÜV-Verband e. V., 30 Oct 2023

The TÜV Association welcomes the EU Commission initiative to update the EU legislation on toys. The high number of non-compliant toys in the EU single market gives clear evidence that the current Toy Safety Directive has not achieved its aim to protect children adequately. The new Commission…

Consultation response

TÜV-Verband e. V., 29 Oct 2021

The TÜV Association welcomes the European Commission’s intention to revise the Toy Safety Directive 2009/48/EC. Given that children are the most vulnerable consumers in the EU Single Market, the future Toy Safety Directive/Regulation must set a blueprint for a modern and ambitious EU product safety…

Consultation response

International Fragrance Association, 31 Oct 2023

The International Fragrance Association (IFRA) thanks the European Commission for the possibility to comment on the revision of the Toy Safety Directive. In relation to the labelling of fragrance allergens, IFRA would recommend reviewing the provisions laid down in the proposed Toy Safety…

Consultation response

International Fragrance Association, 29 Oct 2021

The International Fragrance Association (IFRA) welcomes the opportunity to comment on the Inception Impact Assessment on the revision of the Toy Safety Directive. IFRA would like to raise the following comments: 1) The extension of the generic approach to risk management should be based on risk,…

Consultation response

ZERO - ASSOCIAÇÃO SISTEMA TERRESTRE SUSTENTÁVEL, 31 Oct 2023

ZERO welcomes the revision of the Toy Directive and agrees with the ban of the new hazard classes of chemicals in toys including endocrine-disrupting and suspected endocrine-disrupting substances, respiratory sensitizers and STOTs (Specific Target Organ Toxicity). Besides these substances, we…

Consultation response

Deutscher Verband der Spielwarenindustrie e.V., 30 Oct 2023

Ich möchte hier einige Anmerkungen zum Erwägungsgrund (21) machen: Grenzwerte für chemische Schadstoffe, die ein hohes Schutzniveau ermöglichen, sind wichtig für die Sicherheit von Kindern beim Spielen. Bei der Ableitung solcher Grenzwerte fließen aktuelle wissenschaftliche Erkenntnisse ein, sowie…

Consultation response

Child Rights International Network, 27 Oct 2023

We welcome the EU Commissions proposal for a Toy Safety Regulation, revising the existing directive on the safety of toys in force since 2009. We support this ambitious proposal, which is a great step toward a better protection of children and their rights against exposure to harmful chemicals. As…

Consultation response

Women Engage for a Common Future, 2 Nov 2021

Protecting children from unsafe toys and strengthening the Single Market – revision of the Toy Safety Directive Women Engage for a Common Future, WECF, welcomes the European Commission’s plan to revise the EU Toy Safety Directive (TSD), in relation to widening the scope of toxic chemicals to be…

Consultation response

Arnika, z.s., 27 Oct 2023

Arnika welcomes the revision of the Toy Directive while firstly agreeing with banning the new hazard classes of chemicals in toys including endocrine-disrupting and suspected endocrine-disrupting substances, respiratory sensitizers and STOTs (Specific Target Organ Toxicity). We propose to consider…

Consultation response

Sveriges Konsumenter, The Swedish Consumers' Association, 27 Oct 2023

The Swedish Consumers' Association supports the revision of the Toy Directive to safeguard children's health and to reduce exposure to hazardous chemicals in our homes, society, and the environment. As a member organization in both BEUC and ANEC, the Swedish Consumers' Association echoes the…

Consultation response

UL GmbH, 9 Oct 2023

UL Solutions welcomes the possibility to comment on the European Commissions legislative proposal regarding the Toy Safety Regulation. A global safety science leader, UL Solutions helps companies to demonstrate safety, enhance sustainability, strengthen security, deliver quality, manage risk and…

Consultation response

UL GmbH, 1 Nov 2021

UL welcomes the opportunity to submit feedback on the European Commission’s Inception Impact Assessment regarding the Revision of the Toy Safety Directive (TSD). UL has a solid experience with regards to toy safety and is representing one NB under Directive 2009/48/EC Safety of toys. Sharing the…

Consultation response

European Balloon and Party Council, 30 Oct 2023

Toy Safety Regulation: A Call for Thoughtful, Effective Regulation. 1. A request for nitrosamine limits in balloons to be maintained: The harmonised standard EN 71-12:2016 establishes two different limits, causing contention with the TSD. While there's intention for the Toy Safety Regulation to…

Consultation response

Ravensburger Verlag GmbH, 30 Oct 2023

Sehr geehrte Damen und Herren, die Firma Ravensburger Verlag GmbH produziert ca. 80% der Spielware in den drei eigenen Fabriken in Europa. Nur ca. 20% kommt von außerhalb Europas. Bei allen unseren Produkten beachten wir die bereits strengen Vorgaben der Spielzeugrichtlinie 2009/48/EG. Wir begrüßen…

Consultation response

Environment and Health Justice Support, 29 Oct 2021

The protection of children and the realization of the rights of the child and the right to live in a clean and healthy environmental should be one of the most important goals for the EU, as it has been laid down in the EU Strategy on the Rights of the Child . All products used by children should be…

Consultation response

FIPEC, 31 Oct 2023

The paints, varnishes, coatings, adhesives and sealants, printing inks and artists' colours industries that Fipec represents in France are paying particular attention to the proposal for a regulation on the safety of toys, both as toy manufacturers (mainly in the artists' colours industry) and as…

Consultation response

Hasbro International Holdings BV, 31 Oct 2023

The current EU Toy Safety rules are the strictest requirements for consumer products. Compliant toys are already safe, and reputable companies always strive to be compliant. The real issue are rogue traders who ignore the rules and simply place unsafe products on the market. This problem has…

Consultation response

European Writing Instrument Manufacturer's Association, 31 Oct 2023

With regard to the proposal for a Regulation on the safety of toys published on 28 July 2023 (2023/0290 COD), the European Writing Instrument Manufacturer's Association (EWIMA) would like to share the following initial comments from our members. Please find our feedback in the attached document.

Consultation response

Zveza potrošnikov Slovenije, 30 Oct 2023

Together with partner organizations, ZPS, Slovene Consumers Association is happy to see the draft Toy Safety Regulation (TSR) better protects children against harmful chemicals and reducing the risk of non-compliance. Especially, we would like to express our strong support banning known and…

Consultation response

Ecological and Toxicological Association of Dyes and Organic Pigments Manufacturers, 2 Nov 2021

Please find our detailed feedback regarding the proposed positive lists for certain substances, requirements for the labelling of chemical composition of toys and migration of substances as key parameter in the attached file.