In the latest outcome of last year’s two-month stocktaking review of the workings of the EU consumer product safety system, the European Commission has presented the findings of an expert report into toy safety. 

The report, Evaluating business safety measures in the toy supply chain, is based on a five-month analysis of measures that businesses throughout the toy supply chain are taking to ensure product safety, with the objective of identifying gaps and weaknesses in the existing practices and activities undertaken to ensure toy safety and to recommend improvement actions. Findings include the following.

  • 85 per cent of all toys on the EU market originate from China.
  • Different actors in the EU toy supply chain play distinct roles in ensuring product safety. Many original equipment manufacturers exert significant control over the manufacturing chain, including supplier auditing, and safety aspects are addressed from concept design onwards. Retailers generally make significant efforts on product safety, but typically employ a lower number of safety-dedicated personnel. Meanwhile, traders (namely those that import or buy toys but do not directly sell them to final consumers) often do not have the capacity to control product safety in any meaningful way, and rely almost entirely on the manufacturer and test reports provided to them to confirm that products are safe.
  • There is strong reliance on testing organisations to assure toy safety, but problems may arise as a result of differing interpretations of the EU harmonised safety standards and test methods between different testing houses.
  • Some member state surveillance authorities find it difficult to ensure effective toy safety controls, due to a lack of resources and expertise.
  • Issues identified across the whole supply chain include the poor quality or absence of technical files, problems with age grading of toys, insufficiently robust recall management practices and difficulties in interpreting harmonised toy safety standards.

The main conclusion of the report is that product safety cannot be guaranteed by final product testing alone, but has to be embedded in the entire product development and production process. The report goes on to make over 50 recommendations on the steps that should be taken by different market actors, in particular relating to education and training, quality management and traceability.