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Toy Safety Standards in Europe

EN 71-standards – latest development Christian Wetterberg Chair CEN TC 52 ”Safety of toys” Update May, 2018. Toy Safety Standards in Europe. EN 71-1 Mechanical and physical properties EN 71-2 Flammability EN 71-3 Migration of certain elements

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Toy Safety Standards in Europe

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  1. EN 71-standards – latest developmentChristian WetterbergChair CEN TC 52 ”Safety of toys”Update May, 2018

  2. Toy Safety Standards in Europe • EN 71-1 Mechanical and physical properties • EN 71-2 Flammability • EN 71-3 Migration of certain elements • EN 71-4 Experimental sets for chemistry and related activities • EN 71-5 Chemical toys (sets) other than experimental sets • EN 71-7 Finger paints • EN 71-8 Activity toys for domestic use • EN 71-9 Organic chemical compounds – Requirements • EN 71-10 Organic chemical compounds – Sample preparation • EN 71-11 Organic chemical compounds - Methods of analysis • (!) EN 71-12 N-Nitrosamines and N-nitrosatable substances (!) • EN 71-13 Olfactory board games, cosmetic kits and gustative games • EN 71-14 Trampolines for domestic use • EN 62115 Electrical toys Blue = Reference not published in OJEU

  3. EN 71-1 MECHANICAL & PHYSICAL PROPERTIES EN 71-1:2014 provides a presumption of conformity to TSD Three amendments have been approved for publication prA1 regarding ”Cords and drawstrings in toys and packaging” prA2 regarding ”Projectiles, rotors, propellers and flying toys” prA3 ”Various” (covers changes/corrections e.g. for Inflatable toys, Aquatic toy warnings, Hinge lines, Bicycles/tricycles with push handle) • The amendments have been merged to one and will be published 13 June 2018. • Publication of a reference in OJEU is expected for Aug/Sept 2018

  4. EN 71-1 MECHANICAL & PHYSICAL PROPERTIES Topics under discussion: A formal objection has been received from Germany. It is based on an accident where a jammed wheel bearing caused a scooter/balance bike to come to a sudden stop, and the child to fall with injury as consequence. Background information has been supplied by Germany and has been discussed at the Toy Expert Group meeting in December 2017 and also at the CEN TC 52-meetings in April 2018 CEN TC 52 will send additional questions on the case to Germany as a result of the discussions and will also approach the Commission regarding classification of balance bikes.

  5. EN 71-2 FLAMMABILITY EN 71-2:2011+A1:2014 provides a presumption of conformity to TSD In connection with the 5 year systematic review, CEN/TC 52 decided to revise the standard Working group 13 (WG 13) has focused mainly on changes relating to toy disguise costumes but also discussing a new definition for “highly flammable solids” linked also to new elaborations in the rationale, and to include certain interpretations from TR 15371-1 WG 13 has been asked to approve activation of the preliminary work item by 1 June 2018 Provided that WG 13 agrees to the activation, the draft text will be sent to CCMC in June for launching of CEN Enquiry

  6. EN 71-3 MIGRATION OF CERTAIN ELEMENTS • EN 71-3:2013+A1:2014 provides a presumption of conformity to TSD. • A2 was published 9 August 2017 and addresses problems with false positive detection of organotin compounds in samples with high concentrations of inorganic tin. • prA3 supports the new TSD migration limits for lead and was approved without comments in CEN Enquiry and will be published 13 June 2018. • Publication of reference to EN 71-3:2013+A3:2018 in OJEU is expected Aug/Sept 2018 • EN 71-3 revision financed by the EC: CEN Enquiry was launched 24th May 2018 and closes 16th August 2018 • Publication expected 2019

  7. EN 71-4 CHEMICAL EXPERIMENTAL SETS EN 71-4:2013 provides a presumption of conformity to TSD Two requests for interpretation regarding use of food ingredients/food colorants and regarding closure test, resulted in proposals for amendment to EN 71-4. If these are approved by WG 5 per correspondence, a draft decision for a new work item for revision of EN 71-4:2013 will be circulated EN 71-5 CHEMICAL TOYS • EN 71-5:2015 provides a presumption of conformity to TSD

  8. EN 71-7 FINGER PAINTS EN 71-7:2014 provides a presumption of conformity to TSD A1 was published Sept 27, 2017 and regards changes to the positive list of preservatives (e.g. deletion of CMI/MI based on Appendix C restriction in force since 24 Nov 2017). After BT approved of a small modification it was re-published as A2 on 21 February 2018. Publication of reference in OJEU is expected Aug/Sept 2018 COM has indicated a note on Climbazole might be published EN 71-8 ACTIVITY TOYS FOR DOMESTIC USE • EN 71-8:2011 provides a presumption of conformity to TSD • EN 71-8:2018 was published 10 January 2018. Publication of reference in OJEU is expected Aug/Sept 2018 • Preliminary work item registered for “inflatable activity toys”

  9. EN 71-9, -10 and -11 ORGANIC CHEMICAL COMPOUNDS COM has indicated they might issue a mandate for revision of parts 9 to 11. CEN has therefore confirmed the standards while waiting for further information EN 71-12 N-NITROSAMINES AND N-NITROSATABLE SUBSTANCES • EN 71-12:2013 gives a presumption of conformity to TSD. Includes an “A-deviation” for Germany. Withdrawn 30 June 2017 • EN 71-12:2016 includes national German limit values (but 4 hour migration) for toys <3 years and intended to be mouthed. A-deviation remains. COM considers an Ordinary Legislative Procedure to amend TSD-limits. Referencing in OJEU not expected

  10. EN 71-13 OLFACTORY BOARD GAMES, GUSTATIVE BOARD GAMES, COSMETIC KITS AND GUSTATIVE GAMES • EN 71-13:2014provides a presumption of conformity to TSD. • Two recommendations for amendment from WG 12 will, if approved by WG 5, lead to a NWI for revision EN 71-14 TRAMPOLINES FOR DOMESTIC USE • EN 71-14:2014 provides a presumption of conformity • A1 changes safety factor from 2,5 to 5 for calculation of load in mat deflection test (for other trampolines than mini-trampolines). Published 23 August 2017. Publication of reference in OJEU expected Aug/Sept 2018 • Formal vote for revised version of 71-14 (including “buried trampolines”) expected Sept 2018

  11. EN 71-XX STANDARD(S) SUPPORTING APPENDIX C RESTRICTIONS • The following new preliminary work items have been registered for new standards: • Formamide • TCEP and alternative flame retardants • Isothiazolinones • Phenol • Bisphenol A A quotation for EC funding has been prepared.

  12. CEN TECHNICAL REPORTS • CEN Technical Report 15071 “National translations of warnings and instructions for use in EN 71-standards“. The revised 2015-version was made available in August, 2015 • CEN Technical report 15371-1:2017 “Replies to requests for interpretation of EN 71-1, EN 71-2, EN 71-8 and EN 71-14”, was published 31 May 2017. • CEN Technical report 15371-2:2017 “Replies to requests for interpretation of the EN 71 Chemical standards”, was published 31 May 2017. 15371-2:2018 is expected to be published in May 2018.

  13. CEN TECHNICAL REPORTS • CEN/ISO Technical report 8124-8 “Age determination guidelines”. Published 2016 as a fully aligned CEN/ISO TR 8124-8. A corrected version was published early June 2016 • CEN Technical report 16918 “Children´s mouthing behaviour in contact with toys”. Published December 23, 2015 • CEN Technical report CR 14379 “Classification of toys – Guidelines” has been withdrawn after decision by CEN BT. The European Commission has been encouraged to transfer relevant parts of the report to Guidance document 11. NOTE: Many guidance docs refer to CR 14379

  14. SUMMARY – Amendments/new standards • EN 71-1:2014:A1 to be published:2018 DAV 13/6-18 • EN 71-2:2011+A1:2014: CEN Enquiry text to CCMC June 2018 • EN 71-3:2013+A2:2017:Referencing of A2 pending Amd 3 to be published 13/6-18 Revision: CEN Enquiry closes 16/8-18 • EN 71-7:2014+A2:2017: Published (Referencing in OJEU pending) • EN 71-8:2018: Published (Referencing in OJEU pending) • EN 71-9/10/11: Confirmed while waiting for mandate • EN 71-12:2016: Referencing in OJEU not planned • EN 71-14:2014+A1:2017 Published. Referencing in OJEU pending Revision: FV expected Sept 2018 • EN 71-XX: New standards to support App C Quotation to be submitted

  15. SUMMARY – Amended restrictions TSD Restrictions in Appendix C • Implemented • TCEP, TCPP, TDCP: 5 mg/kg, content • BPA: 0,1 mg/L, migration • Implemented since 24 May 2017 • BIT: 5 mg/kg content • Formamide: 20 µg/m3 emission (or 200 mg/kg TC) • Implemented since 24 Nov 2017 • CMI/MI, CMI, MI 1 mg/kg, 0,75 mg/kg, 0,25 mg/kg • Decided (applies from 4 Nov 2018) • Phenol: 5 mg/kg content, 10 mg/kg migration • Decided (applies from 26 Nov 2018) • BPA: 0,04 mg/L migration Migration limits • Implemented (June 2013) • Barium, Cadmium • Decided (Pb applies 26 Nov 2018, CrVI 18 Nov 2019) • Lead • CrVI

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