Hasbro International Holdings BV
Hasbro is a leading toy and game company whose mission is to entertain and connect generations of fans through the wonder of storytelling and exhilaration of play.
ID: 505204116982-84
Lobbying Activity
Response to Revision of the Toy Safety Directive
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 increased dramatically with the growth of e-commerce, and especially with online marketplaces where anyone can sell any product. There currently is little to no control on the quality and safety of products directly sold to EU consumers via online marketplaces. The draft revision of the EU Toy Safety legislation fails to properly address this issue. Instead, the text contains many new requirements which lack a scientific basis, are difficult to deal with and make things more complicated for reputable toy manufacturers. This adds to an unfair level playing field - while still not protecting EU consumers from unsafe toys sold by complacent marketplace sellers. The Digital Product Passport is a step into the right direction but will not shield the EU market and consumers from the vast number of unsafe toys. On the other hand, the DPP can easily become a burdensome bureaucratic monster. The information requested in the DPP shall focus on what is really needed for enforcement authorities. Also, online marketplaces should have the same responsibilities as other economic operators when selling toys for which there is no EU-based economic operator. When introducing new chemical requirements those should be based on sound science, and realistic thresholds need to be properly defined - for manufacturers to achieve valid and reproduceable test results, and for enforcement authorities to base their assessments on firm grounds. Chemical restrictions should capture actual risk scenarios for children. Extending the current requirements for children under 3 (which are based on the specific behaviour, i.e. mouthing) to all age groups goes well beyond the actual risk. This is also the case for CMR restrictions on inaccessible materials. No exposure means no risk. Environmental hazards shall be addressed by horizontal restrictions to achieve a satisfactory result these cannot be solved by regulating only toys. Toy Safety legislation shall focus on the physical safety of a toy which can be assessed by standardized testing methods. Requirements around psychological health are impossible to be assessed consistently without clear safeguards and criteria. Otherwise those aspects are subjective as they will always be based on individual cultural, ideological or religious values, which differ per individual, region and country. This has been seen also in recent ADCO minutes. Such requirements would therefore put toys at risk of individual judgement and do not provide a basis for consistent assessments. Toys compliant with the current rules should also not be limited in their sell-off period. What has been safe until now should not be required to be pulled off the market. A 12-months period after the entry into force of the new requirements will lead to millions of toys which cannot be sold further and in consequence would have to be destroyed. This goes against the principle of sustainability and causes huge costs and efforts, while not adding to consumer safety. Also, the foreseen 30 months transition period needs to be tied to the timeline of the duties of the Commission related to the Digital Product Passport and the publication/harmonization of the supporting EN71 standards. Manufacturers are totally reliant on the pre-work that has to be done first before they can start working on their systems. If there is delay in the prerequisites, this must be reflected in the timeline for manufacturers to be compliant. We therefore urge the Commission, Council and the Parliament to create workable and realistic requirements for reputable toy manufacturers without compromising on toy safety but creating a real level-playing field for reputable toy companies.
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