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Update Legislative Initiatives TIE Product Safety & Environment Committee Meeting 28 June 2017. Lars Vogt, Senior Policy Officer Toy Industries of Europe. TABLE OF CONTENTS. 01. Circular Economy. 02. Product Lifetime. Flying Toys / Drones. Timber Regulation.
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Update Legislative InitiativesTIE Product Safety & Environment Committee Meeting 28 June 2017 Lars Vogt, Senior Policy Officer Toy Industries of Europe
TABLE OF CONTENTS 01 Circular Economy 02 Product Lifetime Flying Toys / Drones Timber Regulation Ecodesign/Electronic displays 03 04 05
01 Circular Economy
Key Dosiers Revision of EU Waste legislation Plastics Strategy Analysis Interface Chemicals, Products and Waste Legislation
Waste Package • Negotiations EP-Council (& Commission) started • TIE outreach ongoing • Packaging & Packaging Waste Directive • Change of Legal Basis (Internal Market to Environment • Consequences: no need to notify national measures ahead of implementation, only possible to challenge them when already applied: risk for fragmented rules on packaging
Waste Package • Waste Framework Directive (WFD): • Costs EPR schemes • Communication to consumers + waste treatment operators on SVHCs • Provision of spare parts, instruction manuals, & technical information to re-use operators
Interface Chemicals, Products and Waste Legislation • Aims to address: • insufficient information about substances of concern in products and waste • presence of substances of concern in recycled materials and in articles made thereof incl. imported products. Ex: • Substances subject to REACH restrictions that are present in recovered materials (substances, mixtures and articles) • Authorisation obligations for recovered substances or mixtures • Application of authorisation requirements to the presence of substances of concern in EU-produced articles but not to their presence in imported articles
Interface Chemicals, Products and Waste Legislation • Aims to address: • Uncertainties about how materials can cease to be waste • Difficulties in the application of EU waste classification methodologies and impacts on the recyclability of materials • Draft TIE Submission to be finalised. Key points: • Presence of substances of concern in recycled materials; • TSD sets strict safety requirements with wide safety margins for materials used in toys • Use of recycled materials is only possible when the intake of materials can be fully controlled • Need for support to ensure the availability of suitable recycled materials
Interface Chemicals, Products and Waste Legislation • Empowering consumers: • Difficult to give clear-cut advise on sorting/recycling due to diverging national/local requirements • Insufficient information about substances of concern in products and waste: • Under TSD consumers and recyclers will know what toys do not contain • Need further clarity: what are substances of concern? Link with other initiatives like Chemicals REFIT, REACH REFIT….
02 Product Lifetime
European Parliament own initiative report on longer lifetime of products Vote in Plenary on 4 July on text adopted by Internal Market & Consumer Protection (IMCO) Committee Calls on the Commission, when promoting the circular economy, to stress the importance of product durability Targets ‘planned’ obsolescence Key issues – rejected by IMCO: Call for mandatory measures on spare part availability and minimum lifespans Call for expected product lifespan labelling
European Parliament own initiative report on longer lifetime of products Points out that issues such as product durability, extended warranties, the availability of spare parts, ease of repair and the interchangeability of components should be part of a manufacturer’s commercial offer in meeting the various needs, expectations and preferences of consumers, and are an important aspect of free market competition; Emphasises the difficulty of introducing compulsory labelling to provide information on the expected lifetimes of products; proposes that a labelling system of this kind should initially be the subject of a voluntary trial at EU level, on the basis of a common format and methodology
Flying toys – update EASA Expert group EASA released new draft regulation + impact assessment – Public consultation period until 15 September 2017 Entry into force expected 3 years after adoption (2021)
Flying toys – update EASA Expert group Kites & balloons not yet excluded (to be done through basic regulation currently under discussion) Proposal leaves little room for + 250 g toys (use + 14 year old or under supervision) Height: no technical limit for -250 g toys Registration: not needed for – 250 g toys (with or without camera) Needed for others + 250 g toys (e-identification if also with camera of at least 5MP or audio sensor)
Eco-design/Electronic displays Commission published Draft Regulation with Ecodesign requirements for electronic displays Displays with a surface greater than 1 dm² (10 cm x 10 cm) Several exemptions are provided, such as for game consoles Numerous complaints industry and WTO Members, e.g. Restrictions on fixings to enable recycling/disassembly (negative effect on durability, functionality…) Requirement not to use welding or gluing techniques other than the use of double-sided adhesive tape Information requirements proposed on flame retardants and metals ...
Eco-design/Electronic displays Impact toys: Some larger educational toys could be covered (for non-energy requirements) COM will revise proposal and might narrow the scope Meeting with stakeholders and members states: 6 July Joint-statement: TIE might sign a joint statement of concern with other sectors
05 Timber Regulation
Possible extension scope EU Timber Regulation (No 995/2010) • Currently: Toys outside scope • Impact Assessment ongoing • Public consultation to be launched , probably in September
Possible extension scope EU Timber Regulation (No 995/2010) Obligations under Timber Regulation: • No illegally harvested timber and products derived from such timber; • EU traders who place timber products on the EU market for the first time to exercise 'due diligence’ (show information, risk assessment, risk mitigation); • Keep records of suppliers and customers.