Guidance on REACH for Toy Manufacturers, Importers and Retailers

Complex chemical testing is required of all toys manufactured, imported or sold within the EU, where consumer protection is of paramount concern. Manufacturers, importers and retailers are severally responsible for ensuring REACH compliance of the goods in their supply chains.

Registration, Evaluation, Authorization and Restriction of Chemicals is the full title of the highly apt acronym REACH – a European Union regulation that places the responsibility squarely on industry for managing the potential risks of chemicals to public health and the environment. Apt, because its reach extends far beyond the chemicals used in industrial processes to all chemicals, including those found in everyday products that we and our children use, and that includes toys. You are advised to set up a REACH compliance program and the following will guide you through the legislation.

Understanding the impact of REACH on toys
The regulations on chemicals in toys are specific to three types. Firstly, chemicals that directly form a part, such as in chemistry sets. Secondly, chemicals used as ingredients in a mixture, e.g. slime, toy cosmetics, bubble solutions and inks in felt-tip pens. Thirdly, the chemicals used to manufacture a product, such as teddy bears, toy bags, wooden blocks, bath toy sets, ride-on toys, inflatable toys and toy houses.

Understanding how REACH (http://echa.europa.eu/web/guest/regulations/reach/understanding-reach) may impact your products is vital. First you must know the chemicals included in a toy and the proportions of each present to work on gaining compliance. This enables you to limit the use of any dangerous substances (REACH Annex XVII), reduce the use of Substances of Very High Concern (SVHC) and to communicate SVHC information down the supply chain.

If the content of an SVHC is more than 0.1% of the product
EU companies are required to provide information within 45 days and free of charge about the contents of an SVHC in their products if this is requested by consumers. To obtain this information companies should first check their suppliers’ data. If no data on the chemical composition is available, you should obtain this information by having SVHC testing carried out. For any SVHC on the Candidate List that is identified and represents more than 0.1% of the product, you should also prepare a technical data sheet for consumer communications. This would include an identification of the manufacturer/importer, identification of the substance (name, trade name), type of manufacture and use of substance, its classification and labeling as well as exposure and safe use information.

If the content of a SVHC is more than 0.1% and exceeds 1 tonne per year
Companies in the EU must notify that there is an SVHC present that is on the Candidate List (http://echa.europa.eu/web/guest/addressing-chemicals-of-concern/authorisation/substances-of-very-high-concern-identification/candidate-list-of-substances-of-very-high-concern-for-authorisation) when the SVHC constitutes more than 0.1% of the article and the total amount of a SVHC in all the articles exceeds 1 tonne per year from any one importer or manufacturer. However, notification is not required when an SVHC has been registered for the specific purpose, or when is possible to exclude the risk of exposure to people and the environment. If you need to notify an SVHC you must prepare an SVHC Notification Dossier. This includes an identification of the producer/importer, if available the registration number(s), a substance identification and classification, a description of the use of the substance in the product, the scope of tonnage of the substance (e.g. 1-10 tonnes). An assessment of the effects of exposure to each substance on human health and the environment should also be prepared.

When is SVHC authorization needed?
EU producers are obliged to apply for permission to manufacture products containing an SVHC when it is on the Authorization List (REACH Annex XIV). This does not affect articles imported into the EU. Products containing an SVHC that is on the Authorization List can only be sold or used after the ‘Sunset Date’ defined for the chemical when its usage has been granted by authorization for a specific purpose or when the use is exempted.

IMPORTANT: If authorization is granted you must update the Safety Data Sheets (SDS) and include the authorization number on product labels before placing the substance or a mixture containing the substance on the market.

SVHC testing (http://www.sgs.com/en/Consumer-Goods-Retail/Toys-and-Juvenile-Products/Toys/REACH/SVHC-Testing.aspx) identifies the presence and proportion of an SVHC in a product. It is prudent to work out a substitution plan of safer alternatives to an SVHC and you should always check whether it is possible to use alternative substances that are not hazardous or are more environmentally friendly.

Assessing REACH Annex XVII (Restricted Substances) compliance
While testing for substances it is worth checking that the substances comply with REACH’s Annex XVII requirements for toys. Among others, the relevant tests for restricted substances include Phthalates, Azo dyes and Cadmium content.

Ongoing compliance success
It is essential to adopt a strategy that provides you with confidence you can achieve REACH (http://www.sgs.com/en/Consumer-Goods-Retail/Toys-and-Juvenile-Products/Toys/REACH.aspx) and SVHC compliance, whether you are a manufacturer, importer or retailer. SGS offers a comprehensive suite of specifically designed services to help customers comply with their REACH obligations. These range from initial registration to consulting, testing, auditing and verification services that support ongoing REACH compliance.

SGS is the world’s leading inspection, verification, testing and certification company. SGS is recognized as the global benchmark for quality and integrity. With more than 70,000 employees, SGS operates a network of over 1,350 offices and laboratories around the world.

SGS Consumer Testing Services
Hing Wo Tsang
Senior Technical Manager Chemical Laboratory
SGS Hong Kong Ltd.
5-8/F, 28/F, Metropole Square, 2 On Yiu Street, Siu Lek Yuen
Shatin, NT, Hong Kong, China

t: +852 277 474 20
Email: cts.media@sgs.com
Website: http://www.sgs.com/pages/consumer-testing/sgs-consumer-goods-and-retail.aspx

This release was published on openPR.