Chemical safety assessment of toys: Guidance and inspiration for manufacturers, importers and distributors
A chemical safety assessment involves an assessment of the likelihood of toys containing chemicals that are prohibited or restricted. Since the legislation cannot take account of all substances that a toy or a new type of toy may contain, the manufacturer must also assess the likelihood of toys containing substances which are not prohibited or restricted, but which are nevertheless undesirable because they are known or suspected to be hazardous. The manufacturer must also assess whether substances in toys present a risk when children play with the toys. A toxicological risk assessment (TRA) may be included and, depending on scope, it may cover several stages in a chemical safety assessment.
The chemical safety assessment process includes three stages to be conducted by the manufacturer for each chemical substance:
Review the documentation available in order to identify materials and substances contained in the toy.
Examine each substance identified in order to clarify whether the substance is prohibited or subject to restrictions in use (total concentration or migration of the substance) or whether the substance is known or suspected to be hazardous.
Assessment of the likelihood that a material contains more than the permitted quantity of a restricted substance, or that it contains a non-regulated substance in quantities that will present a risk when children play with the toy.
If the assessment concludes that a material contains more than the permitted quantity of a restricted substance, or that a non-regulated substance will present a risk, the manufacturer must evaluate how to manage the risk. If the manufacturer decides to substitute the substance with another substance, this substance must be subject to the same assessment process.
Toy Testing Regulations apply to manufacturers, importers, retailers, hirers and other suppliers of new and second-hand toys – that is, anyone supplying toys in the course of any business. Toys distributed free of charge in the course of business are also covered.
Failure to comply with the Toy Standards Directive can result in compulsory measures ranging from withdrawal of products from the market and import rejections through to fines and even imprisonment.
IS YOUR PRODUCT FIT TO BE SOLD IN GCC MARKETS?
The GCC Technical Regulation BD-131704-01 has been in force since January 1, 2014 and implemented in two phases. The second implementation phase was the chemical requirements. Since July 15, 2015, all toys manufactured in, or imported into a Gulf State (Bahrain, Kuwait, Oman, Qatar, Saudi Arabia, United Arab Emirates (UAE) and Yemen) must comply. All compliant toys must display the GCC conformity quality marking, the G-Mark.
WHAT QUALIFIES AS A TOY IN GCC?
The GCC Technical Regulation defines toys as an item “designed or intended, whether or not exclusively, for use in play by children under 14 years of age”. This means that aside from the exempted products listed below and in Technical Regulation BD-131704-01, all toys designed for children under 14 to use in play must comply. Exempted products include:
GCC TECHNICAL REGULATION REQUIREMENTS
There are a number of essential safety parameters for toys falling within the scope of the Technical Regulation:
GULF CONFORMITY MARK (G-MARK)
The G-mark testifies compliance with GCC-wide safety regulations for toys. On successful completion of the assessment and certification processes, toys must display the G-Mark on the toy itself or its packaging. It must be at least 5 mm high and must be in a clear, legible, permanent and in-erasable format. Only toys demonstrating compliance to Technical Regulation BD-131704-01 qualify to display the G-Mark.
