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Toy Industries of Europe

TIE

Toy Industries of Europe is the trade association for the European toy industry, representing national associations and manufacturers across Europe.

Lobbying Activity

Meeting with Christophe Grudler (Member of the European Parliament)

19 Nov 2025 · Politique industrielle européenne

Toy Industries of Europe calls for safety-first Circular Economy Act

6 Nov 2025
Topic — New EU Circular Economy Act to enhance economic security and promote sustainable production.
Message — The organization requests a comprehensive Act with product-specific requirements that prioritizes toy safety over circular targets. They want sectoral dialogues to develop incentives and harmonized EPR systems across Member States.1234
Why — This would allow them to meet circular economy goals without compromising toy safety standards.56
Impact — Environmental advocates lose stronger material recycling targets that could reduce waste and virgin material use.78
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Response to Revision of the 'New Legislative Framework'

2 Sept 2025

Toy Industries of Europe (TIE) fully agrees there is a need to update the New Legislative Framework (NLF) to ensure its continued relevance in light of digitalisation, sustainability goals, and evolving market practices. TIE members are committed to safe, compliant, and fun toys. However, regulatory fragmentation and excessive labelling requirements are increasingly difficult to manage especially for SMEs. Most critically, legal loopholes for non-EU sellers selling on online platforms allow for unsafe products to circulate freely (this was also identified during the evaluation of the NLF). This revision of the is a key opportunity to address these problems, with smart simplification and future-proof rules. We would like to highlight several areas that require attention during the review: 1) Online Marketplaces, Fulfilment Service Providers & Economic Operator Definitions 2) Conformity Marking / CE Marking 3) Digitalisation 4) Circular Economy Terminology 5) Common Specifications Thank you!
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Toy Industries of Europe seeks exemption for disguise costumes

11 Aug 2025
Topic — The EU is defining exceptions to the ban on destroying unsold clothing.
Message — TIE urges the Commission to grant a specific exemption for toy costumes from the destruction ban. They argue that safety requirements make reusing or refurbishing these products risky for children.12
Why — This exemption would spare toy manufacturers from costly administrative and regulatory burdens.34
Impact — Environmental objectives may suffer if unsold costumes are destroyed rather than repurposed.5
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Response to EU label on product durability and EU notice on consumers’ legal guarantee rights

28 Jul 2025

Toy Industries of Europe (TIE), the voice of the reputable toy actors operating in Europe, welcomes the opportunity to provide feedback to the draft Implementing Regulation on the design and content of the harmonised notice of the legal guarantee of conformity and of the harmonised label for the commercial guarantee of durability pursuant to Article 22a of Directive (EU) 2024/825. As previously commented during the dedicated stakeholder meetings, TIE would like to reiterate the importance of ensuring a design that is simple for traders to reproduce and easy for consumers to recognise, thereby enabling access to clear and accurate information. To this end, we invite the European Commission and national authorities to: - Preserve flexibility for the placement of the harmonised label - Avoid text and translation requirements - Clarify the responsibilities of economic operators - Assess compatibility with existing national requirements Finally, TIE would like to emphasise that beyond Article 22a, businesses still face considerable uncertainty regarding the broader implementation of Directive (EU) 2024/825, which is due to apply within one year. In this regard, we urge the European Commission to coordinate the development of supporting tools (such as targeted guidance documents or trainings) to ensure smooth and timely compliance. Please find the full position in the enclosed document.
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Response to Revision of the Standardisation Regulation

18 Jul 2025

Toy Industries of Europe (TIE) agrees with the Commissions assessment that there is a need to accelerate standard development while ensuring inclusiveness. We ask that the revision of the regulation concentrates on solving identified shortcomings in the standardisation process instead of turning to other mechanisms that may not offer the same level of inclusiveness, legal certainty, or stakeholder consensus. TIE is ready to support the next steps of this process and share our knowledge to help build a modern, efficient, and inclusive standardisation system. Recommendations for options to consider during the revision of the Standardisation Regulation: 1) Improve development of standardisation requests (SReqs) 2) Make the HAS assessment process more efficient and transparent 3) Enhance access to standards 4) Boost digitisation in standardisation processes 5) Speed-up citation in the Official Journal of the EU
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Toy industry urges flexible reporting for unsold consumer products

10 Jul 2025
Topic — Rules for companies to disclose information regarding their disposal of unsold consumer goods.
Message — TIE requests a 3-month disclosure deadline and guidance on reporting formats. They advocate for risk-based verification to avoid excessive administrative burdens.123
Why — This would lower compliance costs by preventing fragmented national rules and simplifying data verification.45
Impact — Environmental groups may face less precise data if companies use estimates to fill reporting gaps.6
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Meeting with Pablo Arias Echeverría (Member of the European Parliament)

8 Jul 2025 · Sector-specific legislation on toy safety and challenges faced by the industry

Toy industry urges flexible bioeconomy rules to protect safety

23 Jun 2025
Topic — The consultation seeks to update the EU strategy for a circular bioeconomy.
Message — TIE requests that biobased materials remain compatible with the strictest toy safety standards. They oppose generic biobased targets, favoring flexible criteria and harmonized mass-balance regulations. Finally, they advocate for funding to improve the affordability of high-quality biobased materials.123
Why — This approach prevents rigid mandates while securing financial support for material research.45
Impact — Proponents of uniform environmental standards lose if sector-specific exemptions and flexibility are granted.6
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Meeting with Daniela Bankier (Head of Unit Justice and Consumers)

3 Jun 2025 · Exchange of views and presentation of the Consumer Agenda 2025-2030

Meeting with Axel Voss (Member of the European Parliament, Rapporteur) and Google and

6 May 2025 · Copyright and generative AI

Meeting with Pascal Canfin (Member of the European Parliament)

25 Feb 2025 · Toy Safety Regulation

Meeting with András Tivadar Kulja (Member of the European Parliament, Shadow rapporteur for opinion)

20 Feb 2025 · Toy safety

Meeting with Oliver Schenk (Member of the European Parliament) and Deutscher Verband der Spielwarenindustrie e.V. and Ravensburger Verlag GmbH

13 Feb 2025 · Europe's safe toy market

Meeting with Jens Gieseke (Member of the European Parliament)

13 Feb 2025 · Austausch zu EU Politik

Meeting with Maria Guzenina (Member of the European Parliament, Shadow rapporteur) and Orgalim – Europe's Technology Industries

12 Feb 2025 · E-commerce

Meeting with Salvatore De Meo (Member of the European Parliament, Rapporteur)

3 Feb 2025 · E-commerce

Toy Industries of Europe urges harmonized labelling and enforcement

31 Jan 2025
Topic — The EU is consulting on a strategy to strengthen the single market.
Message — The organization calls for a unified EU regulatory framework to replace fragmented national labelling rules. They also demand that online platforms be held liable for illegal products and request harmonized producer responsibility schemes.123
Why — Standardized rules would reduce compliance costs and simplify operations across multiple member states.4
Impact — Rogue traders and non-compliant online sellers lose their current unfair competitive advantage.56
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Meeting with Victor Negrescu (Member of the European Parliament, Rapporteur)

11 Nov 2024 · Safety of Toys Directive

Meeting with Dirk Gotink (Member of the European Parliament)

6 Nov 2024 · EU customs legislation, consumer protection

Meeting with András Tivadar Kulja (Member of the European Parliament)

30 Oct 2024 · Toy safety

Meeting with Andrzej Buła (Member of the European Parliament)

15 Oct 2024 · EU toy safety regulation

Meeting with Anna Zalewska (Member of the European Parliament)

15 Oct 2024 · Sytuacja branży zabawek w Polsce

Meeting with Sunčana Glavak (Member of the European Parliament)

2 Oct 2024 · Meeting on toy safety standards in the EU

Meeting with Brando Benifei (Member of the European Parliament)

24 Sept 2024 · Unsafe toys on online marketplaces and what the EU can do about providing safety for children and protecting European businesses

Meeting with Christophe Grudler (Member of the European Parliament)

11 Mar 2024 · Sécurité des jouets

Meeting with Kathleen Van Brempt (Member of the European Parliament)

11 Mar 2024 · veilig speelgoed op Europese markt / import voorwaarden

Meeting with Brando Benifei (Member of the European Parliament, Shadow rapporteur)

4 Mar 2024 · Toy Safety Regulation

Meeting with Geoffroy Didier (Member of the European Parliament)

28 Nov 2023 · Toy Safety Directive

Meeting with Esther De Lange (Member of the European Parliament, Shadow rapporteur)

27 Nov 2023 · Toy Safety

Meeting with Brando Benifei (Member of the European Parliament, Shadow rapporteur)

24 Nov 2023 · Toy Safety Regulation

Meeting with Vlad-Marius Botoş (Member of the European Parliament, Shadow rapporteur)

15 Nov 2023 · Safety of Toys

Meeting with Arba Kokalari (Member of the European Parliament) and The LEGO Group

9 Nov 2023 · Safety of toys (staff level)

Meeting with Katrin Langensiepen (Member of the European Parliament, Shadow rapporteur)

8 Nov 2023 · Austausch zu Spielzeugsicherheit

Meeting with Andreas Schwab (Member of the European Parliament)

8 Nov 2023 · Spielzeug

Response to Revision of the Toy Safety Directive

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 the current rules are already safe, the real problem of rogue traders who ignore the rules and simply place unsafe toys on the market is largely ignored. We're worried by the absence of requirements on online marketplaces in that respect. Also, several of the proposed changes will have (unintended) consequences that have not been accounted for, such as 1) The inclusion of requirements for mental health lack objective criteria and rationale and was not included in the Impact Assessment 2) The extension of requirements for sound to all toys, also to unintended sound, will generate difficulties to implement and to enforce. This change was also not subject to an Impact Assessment. 3) Whereas we support the full ban on endocrine disruptors for human health, it will become increasingly complex, especially for SMEs, to demonstrate compliance with the full bans because important derogations (CLP threshold, inaccessible materials) have been removed without adequate justification. The fact that limit values can now be set for all substances in any toy made it unnecessary to remove the derogation based on the CLP threshold. As it becomes increasingly difficult to place safe toys on the market, rogue traders are expected to benefit, which will have a negative impact on human health. 4) The Digital Product Passport, although in theory a positive development, is not sufficiently clear and could lead to significant red-tape. This should be avoided and simplified. 5) The transition periods are too short and do not consider that standards will need to be updated, that ECHA needs to put in place procedures to assess potential derogations for classified substances subject to full bans and that all the required elements of the digital product passport need to be in place. On top of that, the limited sell-through period of 12 months will likely have a huge negative impact. It could lead to the destruction of millions of safe toys and retailers will not order toys before the end of the transition period. This can push many toy makers into bankruptcy and lead to empty shelves. That proposal was also made without an impact assessment. In the enclosed document is our position paper and an annex with detailed comments!
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Meeting with Mohammed Chahim (Member of the European Parliament)

27 Oct 2023 · Breakfast meeting on Toy Safety

Meeting with Tom Vandenkendelaere (Member of the European Parliament)

14 Sept 2023 · toy safety

Meeting with Catharina Rinzema (Member of the European Parliament, Shadow rapporteur) and EuroCommerce

27 Jun 2023 · Right to Repair

Response to Extension of the date of applicability of the RED delegated act on cybersecurity, privacy and protection from fraud

20 Jun 2023

Toy Industries of Europe (TIE) supports the need for toys to have the appropriate measures to ensure a safe and secure play experience. We welcome the Radio Equipment Directive Delegated Act and the proposed cybersecurity safeguards. To make it possible for reputable toy manufacturers to be able to conform with the new rules, we rely on the availability of consensus-based and stakeholder-developed harmonized European standards. TIE understands that CEN-CENELEC requires more time to develop these necessary standards. TIE therefore strongly agrees with the Commission 's proposal to extend the application timeline, for CEN-CENELEC to develop and publish the harmonized European standards as well as for toy manufacturers to then have the opportunity to assess and implement these standards, and to be compliant with the new requirements under the RED Delegated Act. Kind regards.
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Response to Virtual worlds, such as metaverse

3 May 2023

Toy Industries of Europe (TIE) welcomes the European Commissions ambition to foster the development of virtual worlds in accordance with European values. Children should be able to play and move between physical and digital worlds, and be able to do so without seeing their safety and well-being compromised. 1) To realise childrens right to participate online (e. g. to play online) and ensure a safe, nurturing and fun online environment for children, we believe children should be specifically recognised as a distinct group of users and content creators of the virtual worlds. This notably means the forthcoming initiative must: a)require compliance with safe-by-design frameworks and offering children access to age-appropriate content and experiences within virtual worlds. b)embed necessary safeguards to protect children from online risks regarding harmful content, contact, conduct and contract, and continuously mitigate such identified risks. c)incentivise and stimulate investment in the design of inclusive, enabling and child-centric virtual worlds by explicitly recognising the importance of embedding childrens rights and promotion of their well-being from the outset. Only by recognising childrens unique capabilities and incentivising a child-centric design of the virtual worlds, children will be able to actively and safely play within the virtual worlds, seizing the benefits and opportunities these will offer to their growth and development. 2) There will be a need to strengthening consumer protection against unsafe and counterfeit products within virtual worlds. Virtual worlds will create numerous instances offer a great deal of opportunities for in which consumers can fall victim to online fraud and scams and non-compliant products. At this stage, we consider that existing IPRs rules will continue to be relevant and applicable in a virtual worlds environment. However, we also expect that such a new digital environment may lead to new challenges in particular for how to effectively protect and enforce IP rights. Virtual worlds could lead to new avenues for infringement of trademarks, copyrights and designs on a fast and large scale. The use of new technologies such as NFTs, as well as increased co-creation between different users of new assets based on existing IP, add an additional layer of complexity. This relates as well to consumer safety. Malicious, unauthorized and infringing use of brands and trademarks could lead to consumers falling victim to scams. 3D and immersive virtual worlds may make it even more difficult to distinguish between legitimate and illegitimate use of IP and the identity of the online trader or advertiser. Such scams could include identity theft, financial fraud or the marketing and sale of counterfeit or copycat non-compliant and unsafe products. We recommend the Commission to study and follow this area closely, as technologies develop, to ensure that what is illegal offline is also illegal online, and enforced accordingly. Kind regards.
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Meeting with Billy Kelleher (Member of the European Parliament)

26 Apr 2023 · Waste Regulation & Toy Safety

Meeting with Joan Canton (Cabinet of Commissioner Thierry Breton)

28 Mar 2023 · Preparation revision of the Toys Safety Directive

Meeting with Luisa Regimenti (Member of the European Parliament, Shadow rapporteur) and Dow Europe GmbH and

10 Mar 2023 · PPWR

Meeting with Biljana Borzan (Member of the European Parliament, Rapporteur)

22 Nov 2022 · Empowering consumers for the green transition

Meeting with Silvan Agius (Cabinet of Commissioner Helena Dalli)

4 Oct 2022 · Mr Agius attended on behalf of Commissioner Dalli this ceremony and presented an award.

Toy industry demands stricter e-commerce controls and simpler customs

19 Sept 2022
Topic — A legislative revision aiming to modernize EU customs for digital trade challenges.
Message — The organization advocates for removing the €150 customs duty exemption for e-commerce sales. They also propose shifting counterfeit storage and destruction costs to commercial supply chain parties.12
Why — Streamlined processes for trusted traders would lower administrative burdens and operational costs.3
Impact — Online marketplaces and logistics providers would face increased financial liability for counterfeit goods.4
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Response to Safety requirements to be met by European standards for certain children products (excluding toys)

2 Sept 2022

The title of the initiative indicates “safety of children (excluding toys) – requirements to be met by European standards”, which clearly states that toys are excluded. Although the scope of the draft Decision is defined and does not address toys, it does not clearly exclude them. In addition, we believe Recital 5 of the draft Commission Decision could generate some confusion. It indicates: "(5) The rules on the safety of toys are laid down in Directive 2009/48/EC of the European Parliament and of the Council . However, Directive 2001/95/EC applies to the aspects and risks or categories of risks not covered by Directive 2009/48/EC. This Decision should therefore include requirements to be met by European standards for children's products and related products insofar as risks or categories of risks are not covered by Directive 2009/48/EC." The essential safety requirements and particular safety requirements included in the Toy Safety Directive 2009/48/EC (TSD) already cover all safety requirements set out in the Draft Decision. However, only in some very specific cases where a toy has a dual or multiple functions, the non-toy functions should be covered by the General Product Safety Directive - GPSD (for example, a tricycle can be a toy covered by the TSD, but when it is in addition designed to be also used as a mean of transportation it will be subject to additional requirements under the GPSD for this specific configuration). Another example: A toy seat which is only a toy is fully covered by the requirements of the TSD. Not clearly excluding toys will therefore result in conflicting requirements in standards. This will hamper efficiency and effectiveness of the legislation, result in unnecessary burden and hamper effective transposition and practical application. The way recital 5 is written suggests that CEN committees other than the safety of toy committees (CEN/TC52 and CLC/TC61) may decide that additional requirements could be needed on top of what the TSD and its harmonised standards require if products they are dealing with have a toy feature or may be classified as toys (such as toy disguise costumes being part of children’s clothing). CEN/TC 52 officers are already working with counterparts in CEN/TC207 and CEN/TC248 to try and ensure there is clarity of scope between toy safety standards and certain children’s furniture and children’s clothing product standards, respectively. We therefore strongly recommend that Article 1 (scope) is modified to indicate clearly that: - toys (with no other non-toy function) are out of scope and - when a product has a toy function and one or more additional functions in the scope of article 1, only the non-toy functions are covered by the GPSD. We also recommend Recital 5 is amended: 5) The rules on the safety of toys are laid down in Directive 2009/48/EC of the European Parliament and of the Council . However, Directive 2001/95/EC applies to the aspects and risks or categories of risks not covered by Directive 2009/48/EC. This Decision should therefore include requirements to be met by European standards for children's products and related products for the part of the product that does not have a play function. Without these important clarifications, it could lead to requirements for toys being included in standards outside of the EN 71 series (and potentially EN 62115). When such standards are referenced in the OJEU as supporting the GPSD, these references are likely to cause confusion for manufacturers completing conformity assessments
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Toy Industries of Europe urges EU focus on online fakes

14 Jun 2022
Topic — Evaluation of whether consumer law s ensure digital fairness for European Union citizens.
Message — TIE recommends adding counterfeit sales and online scam s to the consumer law fitness check. They also advocate for better traceability of products sold via online marketplaces.12
Why — This would help legitimate companies defend their trade marks agains t illegal online competition.34
Impact — Online platform s could be force d to increase oversigh t of suspicio us adverti s ing and trade rs.56
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Response to Waste Framework review to reduce waste and the environmental impact of waste management

22 Feb 2022

TIE – Toy Industries of Europe wishes to highlight that the revision of the Waste Framework Directive (WFD) is an opportunity to address problems resulting from non-harmonised sorting rules and labelling requirements. At the moment, we experience an uncontrolled growth of national labelling and information requirements, often to be placed on the packaging itself. These include diverging - and sometimes even contradicting - sorting instructions and symbols/logos. This has several unintended consequences, for example: - a negative environmental impact caused by for example larger packaging, stickering, re-packaging, more difficult to send unsold stock to other member states - potential to confuse consumers due to a plethora of logo’s and instructions present (leading to less efficient sorting of waste and distracting from important safety warnings) - obstructs the free movement of goods. There is thus a practical, and urgent, need for EU action in this area with a likely positive impact in terms of waste prevention, recycling and free movement of goods. EU action is urgent as adaptation of packaging takes time and companies are already envisaging changes and confronted with big dilemmas regarding meeting sustainability goals vs meeting diverging national requirements. We therefore support that a harmonised approach to sorting of packaging should be included in the revision of the Packaging and Packaging Waste Directive (PPWD). We recommend that the revised WFD builds on and complements the proposal of the PPWD, beyond packaging waste. We are concerned however, that we would need to wait for the adoption and implementation of the legislation before a solution will be available. We sincerely hope that the European Commission will prioritise EU harmonisation on this aspect and – while the EU legislative tools are being developed – urge Member States to refrain from adopting national approached to sorting labelling that harm the free movement of goods and also have a negative environmental impact.
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Response to Revision of the Toy Safety Directive

2 Nov 2021

See feedback enclosed!
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Response to Smartwatches and connected toys

26 Aug 2021

As the voice of the reputable EU toy sector, Toy Industries of Europe (TIE), supports the Commission’s work to address increased vulnerability of children in the digital space and strengthen legal requirements on the security of internet-connected devices. Reputable toy manufacturers make sure that connected toys are safe, secure, respect children’s privacy and are fun to play with. TIE’s members are fully committed to ensuring that children’s privacy is respected and data is protected in the products and services they develop. The proposed requirements under the Radio Equipment Directive (RED) can be useful in creating a baseline for all connected consumer products. This approach would protect consumers, including children’s privacy, prevent sub-standard products being placed on the market and ensure a level playing field for business. We do however have a number of recommendations: 1. Scope: To apply Article 3.3e of the RED to all radio equipment capable of processing personal data, or traffic data and location data and that are for use by children under the age of 14 – also when these devices are non-internet-connected. 2. Definitions: To include an unambiguous definition of ‘internet connected radio equipment’ and further clarify the scope of ‘radio equipment designed exclusively for childcare’. 3. Date of application: 60 months after the date of entry into force to enable manufacturers to fully implement the requirements in product planning, design and production and to anticipate delays in the standardisation and citation processes. 4. Explanatory memorandum: Introduce a number of corrections and clarifications to the current text.
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Response to Standardisation Strategy

9 Aug 2021

TIE agrees there is a need for a new EU standardization strategy. An effective European standardization System (ESS) is key for the single market and competitiveness of EU industry. Harmonised Standards serve as compliance demonstration tool as they grant their users presumption of conformity. They also enable market surveillance authorities to verify the conformity of products vis-à-vis the law. We agree that one of the objectives of the Strategy, as outlined in the Roadmap, should be to address bottlenecks within the ESS. It should be made sure that harmonised standards can continue to effectively support compliance with EU legislation, including the EU’s toys safety rules. While we remain convinced that the European Commission’s interpretation of Regulation (EU) 1025/2012 following the court rulings should be reassessed, we believe several solutions we brought forward together with industry partners should be taken into account when drafting up the strategy. This includes a need to ensure flexibility in Standardisation Requests, which we believe is essential. See https://www.toyindustries.eu/wp-content/uploads/2021/07/Joint-Industry-Recommendations-for-effective-Harmonised-Standardisation_.pdf. Not mentioned in the Roadmap is a recent trend to include possibilities to develop alternatives to standardisation solutions, such as the adoption of Commons Specifications, in proposals for EU legislation. Examples are the Commission’s proposal for a new Batteries Regulation and a Regulation on Artificial Intelligence. Whereas the option of resorting to Common Specifications might be an appropriate solution in some cases, there is a possibility that it undermines work in the field of standardisation. The new standardisation strategy should reflect on this and provide further clarity on the possible development of Common Specifications.
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Response to Environmental impact of mobile phones and tablets - Energy Labelling

27 Jan 2021

Toy Industries of Europe (TIE) wishes to thank the European Commission for the opportunity to provide feedback on roadmap for the initiative “Environmental Impact of mobile phones and tablets” TIE’s members are reputable toy manufacturers who prioritise toy safety. The toy sector is one of the most diverse sectors in Europe in terms of products on offer. If the initiative will also cover certain products that fall under the EU Toy Safety Directive 2009/48/EC (TSD), such as some toy tablets, we recommend that efforts are made to ensure that the eco-design requirements do not conflict, in any way, with the safety requirements set out in the TSD (e.g. chemical requirements) and in the relevant harmonised standards (e.g. mechanical and physical requirements from EN 71-1 and electrical requirements from EN 62115, etc.), nor should they hamper the possibility for manufacturers to comply with these safety requirements. If this cannot be ensured, we recommend excluding products that fall under the TSD from the scope of this initiative.
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Response to Review of the Community Designs Regulation

11 Jan 2021

Toy Industries of Europe (TIE), the voice of the reputable toy sector in Europe, wishes to thank the European Commission for the opportunity to provide feedback on the roadmap for the “Review of EU rules on industrial design”. The toy sector invests extensive resources in the development of new toys that are up to children’s expectations and ensure a safe play experience. A sound protection of designs is therefore key for our industry to ensure that innovation is not undermined by rogue traders. We welcome the modernization of the EU rules on design protection to address some of the shortcomings identified in the evaluation of the design system such as 3D printing issues or the application of rules to spare parts. In addition, our industry supports the efforts to better fight against counterfeits, including those transiting through the EU. On the identified shortcomings, we would like to highlight the following: 3D printing The increased access to 3D printers and scans has resulted in a growing number of digital versions of 3D physical products, including toys, being available to the general public. The current definition of “identical design” in the Regulation on Community Designs excludes features that are not visible to consumers. In this regard, users of 3D printing can slightly modify blueprints to create a design that appears visibly different to consumers. The unclear scope in relation to 3D printing can reduce the protection level of the original design. In addition, we believe that the rules applicable to 3D printing of spare parts should also be clarified. Spare parts Spare parts can play a key role in the transition to a more circular economy. That is why, we would welcome any efforts to clarify the and harmonize the application of design protection rules to them. We would also appreciate further clarification on the so-called repair clause in Article 110.1 of the Regulation on Community Designs, in particular on which type of products fall under the term “component part” and are, therefore, excluded from protection.
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Response to Evaluation of the 'New Legislative Framework' for EU legislation on industrial products

2 Dec 2020

TIE, Toy Industries of Europe, wishes to comment on the Roadmap for the Evaluation of certain aspects of the New Legislative Framework. We recommend the following elements should be assessed as part of the evaluation: 1) Affixing CE marking and other product information: Whether more flexibility, such as where to place it or if labelling through digital solutions, can be beneficial. The CE mark is aimed at market surveillance authorities. Manufacturers might be able to attest compliance to these authorities in more effective ways than the mark on the product (or packaging or accompanying document). The ‘international’ dimension is also relevant in this respect. Other jurisdictions around the world are requesting similar marking. If companies produce their products for the global market, labelling on the product can be problematic if numerous conformity marks have to be present. 2) Online sales: Whether the NLF adequately addresses different means of online sale. The current framework does not include clear requirements nor does it specify the role of online marketplaces, unless they fall under one of the established types of economic operator (manufacturer, importer, distributor, authorised representative). It also does not assure there is a natural or legal person established in the EU liable for a product placed on the EU market. This is the case for ‘traditional’ sales channels, but not clearly specified in case of, for example, direct sales by 3rd-party sellers based outside the EU through an online marketplace targeting EU consumers. Regulation (EU) 2019/1020 on market surveillance and compliance of products includes rules on cooperation with market surveillance authorities for fulfillment service providers’, but this does not cover most means of online sale through marketplaces, nor does it address the issue of liability. Many reports, including our recent assessment of almost 200 products bought on online marketplaces, have highlighted shortcomings in the current system (see https://www.toyindustries.eu/ties-eu-toy-safety-the-problem-of-unreputable-sellers-on-online-marketplaces/). 3) Standardisation: The current system for development and application of harmonised standards in the NLF should be evaluated. There have been several rulings in recent years, such as the James Elliott case (C-613/14), that have had an impact on standardization work under legislation falling under the NLF. Since the success of the NLF depends for a large part on an effective system of standardisation we believe this is a crucial elements to include in the evaluation. The practice to treat harmonized standards as part of EU law should be revisited. 4) Green transition/spare parts: In the ‘context’ section, the Roadmap rightly points out that industry and products have undergone a green transformation. We recommend that the scope of the evaluation also addresses this. Most notably how the NLF applies to spare parts and whether this is effective. 5) 3D printing (additive manufacturing): Whether the NLF is fit to address challenges with 3D printing/additive manufacturing. For example, responsibilities for safety and compliance of a 3D-printed product or spare-part when different economic operators/physical persons own the digital file, the printer and the raw material. We look forward to contribute to the range of consultations that are foreseen.
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Response to Sustainable Products Initiative

16 Nov 2020

TIE, Toy Industries of Europe, welcomes the opportunity to comment on the European Commission’s Inception Impact Assessment for the Sustainable Products Initiative. TIE’s members are reputable toy manufacturers who prioritise toy safety. The toy sector is one of the most diverse European sectors in terms of the materials used in its products as well as the range of end products on offer – which include everything from simple cardboard jigsaws, through to plush teddy bears containing electronic components that allow children to sing-a-long to nursery rhymes. Across the sector, companies are looking to innovate in the sustainability of their processes, products and packaging, whilst making sure that toys remain safe for children to play with. With the regards to the Sustainable Products Initiative, we would like to share the following considerations: 1. No one-size-fits-all: It is important to recognize that there is no one-size-fits all solution for circular product development. Solutions depend on a wide range of parameters. For example, product type, legal requirements, product safety, product functionality and lifetime of the product. Solutions that work for a specific product might not be feasible or are not effective for others. Solutions focusing on durability, reusability, reparability, recyclability and resource efficiency must consider the overall lifecycle of a product and potential trade-offs between these solutions. 2. Coherence with other EU policies: It is important that coherence with other EU policies and legilsation is upheld. This includes the needs to ensure that for toys, product safety rules should not be compromised. 3. Protecting the EU single market: We agree that is crucial for the effectives of the initiative that it should be based on article 114 (internal market) of the Treaty of the Functioning of the European Union (TFEU) 4. Impact on toys should be specifically assessed when measures mentioned in Section B are considered for toys: This includes: a) The potential extension of scope of the Ecodesign directive, as mentioned in Section B. Some toys could be included in the product groups that are mentioned (such as electronics and textiles). It is essential that the potential impact on these specific toy products is assessed, amongst others to ensure coherence with the wider EU policy framework such as the EU Toy Safety Directive. b) The list of additional measures that could be of a horizontal nature or target specific sectors in particular. For these cases, we also strongly recommend that in case toys could be included, the potential impact of the measures for specific toy products would be specifically assessed. 5. Further consultation with relevant sectors is essential to ensure a comprehensive and accurate evidence base: For example, to provide valuable contextual information on the information provided in the support study to the Commission Staff Working document on ‘Sustainable Products in a Circular Economy’ if information from that report is used. 6. Mandatory requirements need to be enforceable: For any possible new mandatory requirement for products, an assessment of the enforceability is essential. This should include the possibility to effectively enforce requirements for products sold on online marketplaces.
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Response to Amendment of the Toy Safety Directive to adapt the limit values for aniline

22 Oct 2020

TIE does not support the restriction limiting values for aniline resulting from the dyes degradation in textile and leather toy materials through an amendment of Appendix C of the Toy Safety Directive. If aniline is indeed a concern for consumer safety, a proposal targeting the uses with actual relevant exposure would be appropriate: - The restriction as part of the Toy Safety Directive is not limited to textile and leather materials that come in direct and prolonged contact with the skin or oral cavity, whereas these routes of exposure are the ones that generate dyes degradation. - Consumers including children could be exposed to aniline resulting from the dyes degradation through many products made of textile and leather materials that come in direct and prolonged contact with the skin or oral cavity. Therefore, if aniline is indeed a concern for consumer safety then a revision of the current REACH Annex XVII restriction on azocolourants and azodyes (Entry 43) should have been the appropriate route in order to ensure convergence of all products. Details: Recital 5 of the Draft Commission Directive states: “aniline could be found in coloured toy material such as textiles or leather when that material is subjected to the reductive cleavage test provided for in Appendix 10 to Regulation 1907/2006 of the European Parliament and of the Council” Recital 9: “it is necessary to set a limit for aniline in textile toy material and leather toy material of 30 mg/kg after reductive cleavage and a limit for aniline in finger paints of 10 mg/kg as free aniline and 30 mg/kg after reductive cleavage.” Appendix 10 of the REACH Regulation contains relevant test methods to be used for assessing compliance with the Annex XVII restriction on azocolourants and azodyes (Entry 43). The conditions of the restriction from entry 43 are the following: “Azodyes which, by reductive cleavage of one or more azo groups, may release one or more of the aromatic amines listed in Appendix 8, in detectable concentrations, i.e. above 30 mg/kg (0,003 % by weight) in the articles or in the dyed parts thereof, according to the testing methods listed in Appendix 10, shall not be used, in textile and leather articles which may come into direct and prolonged contact with the human skin or oral cavity” The associated test methods to entry 43 intend to mimic the physiological reaction on the skin or in the oral cavity that lead to the breakdown of azodyes into primary aromatic amines. Since the Draft Commission Directive appears to be an extension of entry 43 to aniline with a scope that covers textile and leather materials in toys, it should have been limited to situations where direct and prolonged contact with the human skin or oral cavity occurs, in order to align with the similar REACH Annex XVII approach. As a consequence, the omission of the direct and prolonged contact with the skin or oral cavity in the toy restriction for aniline generates deep inconsistencies. Additionally, Appendix 8 of the REACH Regulation does not mention aniline as a banned amine. It is worrying that an extension of the current REACH restriction to aniline is placed into Appendix C of the Toy Safety Directive. It appears to be inconsistent that textiles and leather toy materials are subjected to an aniline restriction whereas normal children's clothing are not. If aniline is indeed a concern for consumer safety then a revision of the current REACH Annex XVII restriction should have been the most appropriate route in order to ensure convergence of all relevant products.
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Response to Intellectual Property Action Plan

14 Aug 2020

Toy Industries of Europe (TIE), the voice of the reputable toy sector in Europe, thanks the European Commission for the opportunity to provide feedback on the “Intellectual Property Action Plan” roadmap. The toy sector, which exists for 99% of SMEs, invests extensive resources in the development of toys that are up to children’s expectations and ensure a safe play experience. A strong IP framework is key for our industry to ensure that these efforts are not undermined by rogue traders. A recent EUIPO report on IPR infringement shows that our sector is heavily affected by counterfeiting. Between 2013 and 2017, 1.7 billion of total sales and more than 7000 jobs have been lost (https://euipo.europa.eu/tunnel-web/secure/webdav/guest/document_library/observatory/documents/reports/2020_Status_Report_on_IPR_infringement/2020_Status_Report_on_IPR_infringement_en.pdf). Dishonest operators damage the reputation of responsible companies and put children at risk. If counterfeiters seek to cut corners by infringing on intellectual property rights, it is likely they will cut corners on safety. TIE therefore welcomes the intentions from the European Commission to strengthen the EU IP framework. There are a couple of points we would like to highlight for the Roadmap and the Action Plan: 1) We support the aims to tackle the high level of counterfeiting and piracy and the lack of global fair play. We believe specific priority should be given to the online world in this respect. This includes, but is not limited to, the sale of counterfeits on online marketplaces and use of brand names for online scams. 2) Alignment with green and digital transformation is important. For example, the implications of 3D printing on IP protection and product safety rules should be assessed and addressed. 3) Parasitic copies, also often referred to as look-alikes or knock-offs, are not mentioned in the Roadmap. They are an import problem for our sector and the legal framework in Europe on this remains too fragmented (see for example the 2012 Study on trade secrets and parasitic copying (look-alikes) for the European Commission, by Hogan & Lovells - https://op.europa.eu/en/publication-detail/-/publication/068c999d-06d2-4c8e-a681-a4ee2eb0e116 ). We recommend that the IP Action Plan addresses this matter.
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Meeting with Werner Stengg (Cabinet of Executive Vice-President Margrethe Vestager)

7 Jul 2020 · To discuss Digital Services Act

Response to Digital Services Act: deepening the Internal Market and clarifying responsibilities for digital services

30 Jun 2020

Toy Industries of Europe (TIE), the voice of reputable toy makers in the EU, welcomes the opportunity to comment on the combined evaluation roadmap/Inception Impact Assessment on the ‘Digital Services Act package: deepening the Internal Market and clarifying responsibilities for digital services’. Our comments relate to the need to prevent illegal content on online marketplaces. Specifically to prevent illegal and unsafe toys, to be placed on the EU market and made available to European children. Children’s safety is the number one priority for TIE. We agree with the Commission’s assessment that online sale of counterfeit, dangerous products or other illegal goods puts citizens at risk and harms legitimate businesses. We are worried as a recent investigation we conducted shows that an alarming amount of dangerous and illegal toys are available in the EU through online marketplaces. Moreover, it seems that once unsafe goods are discovered, because of a lack of knowledge on the products for sale on their platforms, online marketplaces face difficulties in removing and acting against listings with seemingly identical products that have the same safety issue. We believe the Commission should assess binding obligations for online marketplaces to address the sale of dangerous toys. Only through clear requirements for online marketplaces (inclduing proactive and preventice meassures), it can be assured that what is illegal offline, is also illegal online and the sale of unsafe toys to European consumers can be prevented. Specifically, we believe the following obligations for online marketplaces should be assessed. These obligations are in line with existing requirements that apply offline: 1) preventing dangerous toys to be offered for sale on their platforms (proactive measures) through due care requirements. 2) reacting effectively when unsafe toys are discovered (reactive actions), specifically through obligations to: a) Operate a ‘notice, take-down & stay-down' policy’. There should be a short timeframe (for example two days) specified by law for the removal of any unsafe toys notified by public authorities. This should also apply to identical listings, b) Recall unsafe products and inform consumers & c) collaborate with market surveillance authorities and inform them as soon as they are aware of dangerous products being sold on their platform. 3) screening toy sellers and collecting verified contact information (traceability requirements). In the context of the DSA, we believe it is important that the following is addressed: 1) due-diligence requirements and enforcement of ‘know your service provider requirements’ on online marketplaces; 2) the liability rules for online platforms. The DSA offers an opportunity to provide clear rules for online marketplaces, for example through specific liability rules for online marketplaces or to make it clear that online marketplaces are not exempt from obligations under EU-product safety rules; 3) The exemption from general monitoring obligations for intermediary service providers. This should not shield online marketplaces from obligations in the field of product safety. We agree that it is important that the Commission’s work on the DSA and the REFIT of the General Product Safety Directive (GPSD) will be closely associated to ensure coherence of the legal framework. Further details are available in our position paper – enclosed
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Response to Amendment of the Toy Safety Directive to adapt the list of prohibited allergenic fragrances

3 Apr 2020

TIE - Toy Industries of Europe - supports the adaptation, which follows opinions from European scientific committees.
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Response to Amendment of the Toy Safety Directive to adapt the list of allergenic fragrances to be labelled

3 Apr 2020

TIE - Toy Industries of Europe - supports the amendment, following opinions from European scientific committees, but, to ensure consistency between product groups, strongly recommends to align the application date with the application of the same labelling requirements under the Cosmetics Regulation (EC/1223/2009).
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Response to Smartwatches and connected toys

4 Mar 2019

As the voice of the reputable EU toy sector, Toy Industries of Europe (TIE), welcomes the Commission’s decision to explore whether a delegated act under the Radio Equipment Directive can be a useful and effective part of the EU legal framework, particularly with relation to increasing the security of connected products placed on the EU market, whilst ensuring a level playing field for businesses. Nevertheless, we have several concerns about the content of the IIA that we would like to raise, that we have outlined here and provide more detail about in the document we have attached to this response. - Given the stated intention of the IIA to consider all internet-connected radio equipment and wearable radio equipment, and the very small proportion of connected toys relative to other connected devices, we are concerned that the content of the ‘context’ section of the IIA is too narrow in its focus. - It would be useful to have a clearer overview of the concrete security and privacy threats the initiative is aimed at addressing, as well as references to the challenges that reputable businesses face in the connected environment. - We would ask for the references related to connected toys to be reviewed and revised to correct inaccuracies. We thank the Commission for the opportunity to provide feedback on the Inception Impact Assessment. We look forward to providing further input into the initiative and are available in case the Commission has any further questions.
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Response to Commission Regulation amending the CLP Regulation (EC) 1272/2008 and correcting Commission Regulation (EU) 2018/669

7 Feb 2019

Regarding Titanium Dioxide, the notified draft contains a warning for the packaging of all liquid and solid mixtures (Annex II to CLP Regulation). For liquid mixtures, like toy finger-paints, a warning would need to be included that dangerous droplets may be formed when sprayed. For solid mixtures, like toy chalks, a warning would need to be included that dangerous dust may be formed when used. Instructions for safe use should also be included. Thus, the warning and safe-use instructions would be required also on a toy finger-paint that is not intended to be sprayed, and on solid-mixture toys where no significant amount of dust is formed, even though the mentioned risk is not present in these cases. Toys need to be accompanied by relevant warnings, as stipulated by the EU Toy Safety Directive. We believe it is important that additional warnings should only be included if relevant and will not confuse consumers and divert attention from important warnings and instructions. Requiring warnings on all liquid and solid mixtures will dilute the impact of necessary safety warnings. We therefore believe the warning, applying to all liquid and solid mixtures would be disproportionate and will negatively affect consumer trust in perfectly safe toys
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Response to Amendment of the Toy Safety Directive to adapt the migration limits for aluminium

5 Feb 2019

TIE - Toy Industries of Europe - agrees with adapting the migration limit for aluminium in line with the evidence based scientific opinion from SCHEER that has resulted in a proposal for a lowered TDI.
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Response to Detailed rules on unmanned aircrafts

5 Nov 2018

TIE - Toy Industries of Europe - welcomes the intention to create uniform EU-wide rules to enable the safe use of Unmanned Aircrafts (UAs). Toy safety is the toy industry’s number one priority. TIE supports the risk-based approach and requirements should be proportionate to the nature and risk posed by the specific UAs. The proposed Delegated Act (DA) and Implementing Act (IA) would impact a range of flying toys. TIE believes several improvements are required to adequately reflect the risks and hazards associated with flying toys, to avoid legislative requirements on issues already addressed through the EU Toy Safety Directive (2009/48/EC) and to ensure that children will continue to have access to affordable flying toys for outdoor use, which can bring clear benefits and fun. Playing with flying toys is associated with a wide range of benefits for children. Apart from being a fun activity, it leads to improved coordination of eyes, hands and brain, the development of spatial imagination, curiosity, and intellectual capabilities. Flying a drone also requires basic skills, which will need time to develop. Practice from a young age due to the availability of toy drones will contribute to this. It is therefore important that the new rules would continue to enable our sector to develop safe and affordable flying toys for European children to play with. C0: We welcome the specific provisions under the DA and IA allowing the marketing of toy drones below 250 g in compliance with the Toy Safety Directive. However, we believe that the risks and hazards associated with points (2) maximum speed and (3) attainable range as specified in Part 1 of the Annex to the DA are already addressed through the Toy Safety Directive. Applying these particular requirements also for toys could result in unnecessary additional requirements and compliance costs. For example, it would be difficult to demonstrate compliance with a particular range or speed limit as elements like atmosphere effects, metal structures, proximity to the ground, interfering 2.4Ghz sources and production tolerances will cause inconsistencies. Following the requirements of the Toy Safety Directive, a wide range of risks need to be addressed before a flying toy can be placed on the market. This includes ensuring that the toy does not jeopardise the safety or health of users or third parties when they are used as intended or in a foreseeable way, bearing in mind the behaviour of children. An assessment of hazards that the toy may present as well as an assessment of the potential exposure to them is required. If in such case the speed (or Kinetic Energy Density) or range is considered to form a non-reasonable hazard for users or third parties, the toy does not comply with the Toy Safety Directive and is not allowed to be placed on the market. C1: Article 9 of the Draft IA would exclude toys which have been proven to be suitable for children under 14 years old from any other category than C0. This would either ban flying toys above 250 g, which are compliant with the Toy Safety Directive and therefore suitable for children under 14 years old, from the market or would avoid these products to be classified as toys (which as a result would deprive children from playing with those products and manufacturers will no longer ensure compliance with the Toy Safety Directive for those products). We therefore recommend that UAs compliant with the Toy Safety Directive should also be exempted from the age limit for Class C1. Manufacturers will still need to ensure that the toy is compliant with the requirements for Class C1 UA, but we would recommend to include the same exemptions as for class C0.
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Meeting with Szabolcs Horvath (Cabinet of Commissioner Tibor Navracsics)

20 Sept 2018 · an article and a short bio and picture of the Commissioner

Response to Evaluation of the Toy Safety Directive

8 Aug 2018

TIE - Toy Industries of Europe - acknowledge the roadmap on the Evaluation of the Toy Safety Directive 2009/48/EC. At this stage, we would say that we would like to be fully informed about the whole process and further steps proposed by the European Commission. We also would like to be consulted at all stages throughout the evaluation and are ready to deliver our input to consultations, questionnaires and interviews that are foreseen. We’d recommend that the external evaluation of the Toy Safety Directive, which has been conducted at an earlier stage in the evaluation process, is duly considered for the evaluation.
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Response to Reducing marine litter: action on single use plastics and fishing gear

20 Jul 2018

TIE - Toy Industries of Europe – welcomes the efforts made by the European Commission to reduce marine litter on European beaches. However, we regret that the Commission has included balloons and balloon sticks in their proposal without conducting a proper Impact Assessment and that alternative options like voluntary measures were not considered. Measures for balloons, like EPR schemes, and banning of balloon sticks are likely to be disproportionate in relation to their actual impact on the marine environment. We therefore recommend removal of these product categories from the current proposal. In fact: 1) No evidence on the harmful impact of balloons and sticks was provided by the European Commission’s Impact Assessment (as confirmed by the European Commission’s own Regulatory Scrutiny Board). Moreover, the data justifying inclusion in the top 10 product category seems flawed and is still not publicly available. The Commission's Impact Assessment puts balloon and balloon sticks together in one category. It is unclear whether they would be in the top 10 categories if counted separately. The European Balloon and Party Council (EBPC) has also voiced concerns that the inclusion of balloons & sticks in the top-10 items is at odds with all other available data sets, most notably from the OSPAR (Convention for the Protection of the Marine Environment of the North-East Atlantic) Commission. 2)The European Commission’s Impact Assessment did not assess the impact on the balloon and balloon-stick sectors and did not include a proper SME-check. As most balloons are made from natural rubber and no alternatives exist, the impact cannot be compared to the impact on the plastics sector in general. Moreover, up to 75% of the EU market of approximately €540m is produced in the EU, mainly by SMEs. Balloon manufacturing alone accounts for around 21,000 direct jobs throughout Europe. The European Parliament’s ‘Initial Appraisal of the Impact Assessment’ also highlighted that no proper SME-check was conducted. 3) Existing voluntary industry measures have not been considered. The industry is already undertaking voluntary commitments to achieve the same objectives as the proposed Directive. For example, the sector has taken a public stance against balloon releases and is already working on a labelling symbol against releasing balloons, both for safety and environmental reasons. The Commission’s Impact Assessment has not shown how the legislative EU-wide measures for balloons and sticks would be more effective and efficient than such voluntary measures.
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Meeting with Eduard Hulicius (Cabinet of Commissioner Věra Jourová)

27 Apr 2018 · Safety of toys and online marketplaces

Response to Restriction of CMR substances in textile articles and clothing for consumer use under REACH

8 Mar 2018

The proposed restriction targets clothing and textiles other than clothing which, under normal or reasonably foreseeable conditions of use, come into contact with human skin to an extent similar to clothing. Although we acknowledge that the proposed restriction intends to restrict chemicals in clothing and to protect consumers, this approach will add complexity for toy disguise costumes, which can be considered to be in scope and which are already regulated through the EU Toy Safety Directive (2009/48/EC) and other connected pieces of legislation (e.g. REACH) The effect of the proposed restriction would therefore mean that these toys would be further regulated by multiple legislations for the same substances with different limits and test methods. For cadmium, chromium VI, arsenic and lead, the proposal is unclear on what is meant by “which can be extracted from the material” since it could be understood as total content or an extractable content (migration). The proposal also lacks references to validated test methods and generates uncertainties with regards to the available means to demonstrate compliance. Given the lack of clarity, possible conflict and potential confusion, particularly for SMEs, TIE would question whether we can consider this is a suitable use of article 68 (2) of REACH.
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Meeting with Marika Lautso-Mousnier (Cabinet of Vice-President Jyrki Katainen) and LVMH Publica and

3 Oct 2017 · EU measures against counterfeiting

Meeting with Eduard Hulicius (Cabinet of Commissioner Věra Jourová)

23 Feb 2017 · Connected toys

Meeting with Hanna Hinrikus (Cabinet of Vice-President Andrus Ansip)

14 Feb 2017 · AVMSD

Response to Limit value for bisphenol A in toys

22 Aug 2016

Toy Industries of Europe (TIE) agrees with adapting the BPA migration limit for toys in line with the evidence based scientific opinion from EFSA that has resulted in a proposal for a lowered Tolerable Daily Intake (TDI).
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Meeting with Robert Madelin (Director-General Communications Networks, Content and Technology) and American Chamber of Commerce to the European Union and

3 Jun 2015 · New College and Better Regulation

Meeting with Agnieszka Drzewoska (Cabinet of Commissioner Elżbieta Bieńkowska), Rolf Carsten Bermig (Cabinet of Commissioner Elżbieta Bieńkowska)

24 Apr 2015 · Toy Safety Directive

Meeting with Eduard Hulicius (Cabinet of Commissioner Věra Jourová) and LEGO System A/S

23 Apr 2015 · Ban on Bisphenol A in France

Meeting with Kaius Kristian Hedberg (Cabinet of Commissioner Elżbieta Bieńkowska), Rolf Carsten Bermig (Cabinet of Commissioner Elżbieta Bieńkowska)

19 Dec 2014 · Toy Safety

Meeting with Kaius Kristian Hedberg (Cabinet of Commissioner Elżbieta Bieńkowska), Rolf Carsten Bermig (Cabinet of Commissioner Elżbieta Bieńkowska)

12 Dec 2014 · Toy safety

Meeting with Eduard Hulicius (Cabinet of Commissioner Věra Jourová)

5 Dec 2014 · Consumer protection