European Balloon and Party Council
EBPC
To create a positive and sustainable industry by providing a voice for our members at EU policy level.
ID: 831057748513-73
Lobbying Activity
Response to Revision of the 'New Legislative Framework'
2 Sept 2025
The European Balloon and Party Council (EBPC) represents manufacturers, importers, and distributors of balloons and celebration products across the EU. Our range of membership varies from Europes largest to multiple SMEs who supply lightweight, low-impact cultural goods that play an important role embedded in Europes traditions of celebration. We welcome the Commissions objective to simplify and modernise the New Legislative Framework (NLF). However, we are concerned that disproportionate obligations risk creating new burdens for businesses producing low-risk goods, without measurable safety or sustainability benefits. We urge the Commission to ensure that the NLF revision delivers proportionality, simplification, and fairness. Specifically: Recognise decorative products as low impact but culturally significant goods. Exempt or streamline Digital Product Passport (DPP) and traceability obligations for such products. Harmonise labelling and EPR compliance across Member States to remove market fragmentation. Use digitalisation as a simplification tool, not an added layer of complexity. Strengthen enforcement against non-EU online sellers who evade EU rules and undercut compliant SMEs. By safeguarding affordable decorative goods, the NLF will protect cultural traditions, social inclusivity, and SME competitiveness while keeping the regulatory focus where it achieves the greatest environmental and consumer protection impact. The EBPC urges the Commission to ensure that the revised NLF balances digitalisation, sustainability, and safety with proportionality and SME competitiveness. For our sector, this means: Exemptions or light regimes for DPP obligations. Harmonised digital labelling to reduce barriers and waste. Proportionate sustainability measures based on environmental materiality. Stronger enforcement against non-EU online sellers. By ensuring proportionate treatment of decorative goods, the Commission will not only safeguard SME competitiveness but also preserve the accessibility of culturally and socially significant celebrations for millions of Europeans.
Read full responseMeeting with András Tivadar Kulja (Member of the European Parliament, Shadow rapporteur for opinion)
19 Nov 2024 · Toy safety
Response to Revision of the Toy Safety Directive
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 align with EN 71-12:2016's lower limits for toys intended for use by children under 36 months or in other toys intended to be placed in the mouth, this doesn't account for differences in other categories as stipulated in the EN 71-12:2016, posing risks to other product categories as identified in EN 71-12:2016. Products for over 36 months, finger paints and balloons carry a significantly lower exposure risk. Based on detailed risk assessments, current limits of nitrosamines in products do not pose significant health risks. The European Commission rejected lower nitrosamine limits in balloons in 2012, and a 2021 independent risk assessment commissioned by EBPC concluded that the existing limits for balloons are safe, given their minimal exposure risks. We understand this was not the intention of the revision and call for clarification and alignment of the limits for N-nitrosamines and N-nitrosatable substances to the currently harmonised EN 71-12:2016 standard. We urge the European Commission to distinctly set nitrosamine limits for balloons and the other product categories as referenced in harmonised standard EN 71-12:2016, considering their specific intended use and exposure risks. Any such reduction would severely harm the balloon industry, especially since there are no viable alternative materials. 2. Prioritising Practicalities in Toy Safety: The proposed mental health impact assessments for toys are viewed as overly subjective, influenced by cultural and personal values. Chemical limits should be age-specific and scientifically backed based on accessibility and exposure. Overall, the TSR must balance genuine safety concerns with realistic, scientifically grounded standards for manufacturers. The current chemical limits designed for toys for young children and mouthed toys are being extended to all toys, a move that lacks scientific backing. The use case of interaction between 3- and 8-year-old children is distinctively different. 3. Digital Product Passport: Urgent Pitfalls Threatening EU Toy Safety & Innovation: We have concerns about the DPP system for which there is currently no visible framework and additional concerns that counterfeiters may bypass digital safeguards. The DPP, in addition to creating administrative challenges for reputable manufacturers and SMEs who dominate the sector, creates risk that regulatory checks might shift from product testing to database verification. Moreover, the DPP's call for full transparency threatens intellectual property protection. 4. Urgent Call to Strengthen Online Toy Safety Measures in the EU: The potential for toys and digital passports to be counterfeited is concerning, especially when a substantial number of online sales are selling imported toys. A pivotal recommendation is that online platforms should be held accountable as the toy's importer where an EU Economic Operator is not identified. Reputable EU manufacturers shoulder most of the costs for compliance and safety. Reputation of all toy manufacturers is rapidly tarnished due to the testing outcomes of toys from non-EU operators who sell directly to consumers online. 5. Challenging Deadlines: The Risk to EU Manufacturers and Sustainability: The proposed 30-month transition period for the new EU toy regulations is impractical for reputable manufacturers. The length of time potentially required for a development of the DPP and related IT systems, and the example of substance use derogations from ECHA such as Titanium dioxide can take between 36-48 months. Extending the transition to 60 months and scrapping the 12-month sell-through limit is essential. The European Balloon & Party Council 30 October 2023
Read full responseMeeting with Marion Walsmann (Member of the European Parliament, Rapporteur) and DEKRA e.V.
4 Oct 2023 · Toy Safety Regulation