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«Authors: Uwe Dannwolf, Dialogik Frank Ulmer, Dialogik Jennifer Cooper, DEKRA Industrial Susanne Hartlieb, DEKRA Industrial Chemicals in Products ...»

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Chemicals in Products

Toys Sector Case Study for UNEP


Uwe Dannwolf, Dialogik

Frank Ulmer, Dialogik

Jennifer Cooper, DEKRA Industrial

Susanne Hartlieb, DEKRA Industrial

Chemicals in Products -Toys Sector Case Study for UNEP

1. Executive Summary

The toy sector case study was conducted via desk research and expert consultations, from

July to January 2011.

Toys were selected as a product group for study in an earlier phase of the Chemicals in Products Project where 77% of participants chose toys as a sector to study and learn from.

An extremely wide variety of materials are used in toys, from textiles to wood to plastic and like many products they have the potential to contain regulated chemicals and other substances of concern such as possible hormone-disrupters. In the EU toys are the product with the most notifications for regulatory non-compliance and while the most frequent notifications are related to small parts (a choking hazard) the second most frequent are related to chemicals in toys in excess of regulated thresholds.

Information on chemicals needed for regulatory compliance is available to the firms that participated in this study. While there is not an uninterrupted flow of information on chemicals along the supply chain – a flow that begins with material producers and continues through each supplier to the toy manufacturer, retailer and consumers – firms did state the information they need for compliance documentation is either generated by their suppliers or obtained with laboratory testing. The obstacles they identified were related to efficiency – access to information could become more efficient among supply chain actors if queries and formats were better understood. Authorities reported a need for information to control imports and exports. Producers reported a need for information on specific end-uses of the substances they supply, in order to inform their risk assessments.

Less information is exchanged on non-regulated chemicals and on regulated chemicals beyond minimum thresholds. NGOs stated consumers do not have access to the information they need to make decisions on toy purchases. Small toy manufacturers stated they do not have information, nor expertise, to know what chemicals to manage beyond what is required by law (and across the board toy safety regulations in Japan, the EU and the US were referred to as the most stringent, with a scope that is expanding to include chemicals). And large companies stated they use product testing to respond to requests for non-regulatory information. Retailers – especially specialised retailers serving an informed consumer group – report such requests do occur, though still infrequently. The study found no common system for chemicals information exchange in the sector.

The potential to enhance the access to information in the sector can be understood in terms of two sector characteristics: the nature of relationships and the market structure. While some supply chain relationships are long term and collaborative (e.g. manufacturer and supplier developing a new material) there are also very many short term relationships.

Participants with successful information exchange stated it took time to establish the flow of regulatory information. Their suppliers needed a lot of support to understand the information requests and what to provide in response (format, level of detail). In short term relationships there is less time for this learning. Second, the market is structured around very many small firms each with a low buying power. They have less pull with larger suppliers and lower possibility to have their requests for information fulfilled (beyond regulation).

2 (50) DEKRA Industrial GmbH • Handwerkstraße 15 • D–70565 Stuttgart • +49.711.7861–3561 • www.dekra.com Chemicals in Products -Toys Sector Case Study for UNEP Two types of approaches can be considered to further the access to information on chemicals in toys. The first is a technical approach focused on the type of information and the means of accessing it. The second is a broader approach to build on the “enablers” for overcoming current obstacles to access to information, such as lack of chemicals expertise within many small or medium sized firms.

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2. Table of contents

1. Executive Summary

2. Table of contents

3. Introduction

3.1. Context of the Study

3.2. Why toys?

3.3. Scope and methodology

4. Overview of the sector

4.1. Volumes and geography

4.2. Stakeholders concerned with chemicals throughout the lifecycle of a toy

4.3. Stakeholders’ Level of Influence or Control

4.4. Nature of Relationships Among Stakeholders

4.5. Characteristics of the toy sector

4.6. Toy product life cycle: Example Plastic toy

4.7. Chemicals and potential release pathways

5. Existing CiP information systems

5.1. Existing CiP systems

6. Stakeholder needs and uses, current and future

6.1. Overview

6.2. Information uses by different stakeholder groups

6.3. Spotlights on information flows or needs

7. Gaps and obstacles in information exchange

7.1. Gaps

7.2. Obstacles

8. Considerations for addressing gaps and obstacles

8.1. Potential ways to address gaps and obstacles

8.2. Major steps towards the future: Outlook

9. Conclusions

10. Annex

10.1. Acknowledgments

10.2. Additional CiP Systems information

10.3. Online survey

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3. Introduction

3.1. Context of the Study This case study was carried out as part of the activities under the Chemicals in Products (CiP) Project. In May, 2009, the second session of the International Conference of Chemicals Management (ICCM2) adopted a resolution agreeing to implement a project on Chemicals in Products with the overall goal of promoting the implementation of paragraph 15 (b) of the Overall Policy Strategy of SAICM concerning the availability of information on chemicals throughout their life-cycle including, where appropriate, chemicals in products (CiP). With the view to take appropriate cooperative action, the Conference agreed to consider further needs to improve information on chemicals in products in the supply chain and throughout their life cycle, recognizing that further actions are needed to fulfil the goal that by 2020 chemicals are used and produced in ways that minimize significant adverse effects on human health and the environment.

The Conference invited UNEP to lead and facilitate the project and to constitute a Steering Group to advise on the project development and implementation. The Conference further

agreed that the following tasks be undertaken:

- collect and review existing information on information systems pertaining to chemicals in products including but not limited to regulations, standards and industry practices;

- assess that information in relation to the needs of all relevant stakeholders and identify gaps;

- develop specific recommendations for actions to promote implementation of the SAICM with regard to such information, incorporating identified priorities and access and delivery mechanisms In this context, UNEP’s goal for the CiP project is to provide to ICCM3 an assessment of information needs that would allow stakeholders to practice sound management of the chemicals in products, a report on status of existing systems and the extent to which they meet the identified information needs as well as recommendations for further cooperative actions needed to ensure that required information is available, accessible and appropriate to the needs of all stakeholders. UNEP will report on the project implementation and its outcomes to the SAICM Open-Ended Working Group (in mid 2011) and to ICCM3 (in mid 2012).

To date, an extensive Scoping Phase has been undertaken by the CiP project, resulting in a focused set of case studies being carried out in the product sectors toys, electronic goods, building materials and textiles.

Within the context of the three tasks which ICCM2 assigned to the CiP project, this toys case study seeks to build upon previous work done in the sector by similar investigations (see esp.

Massey, et.al., Becker and Kogg/Thidell) and to provide evidence for informed discussions and decisions on possible next steps to be taken under the activities of the CiP project.

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3.2. Why toys?

The product category “toys” was chosen as a case study during the scoping phase of the CiP project. In Becker’s scoping survey 77% of all respondents chose toys as a sector to study and learn from.

According to this scoping study the reasons of governments and stakeholder groups for

prioritizing children’s products included:

• the vulnerability of children to chemical exposures and health impacts

• increased consumption of toys

• the prevalence of imported toys with unknown material composition

• use of toxic metals in toys

• lack of information on hazards of toys

• ineffective regulation on toy safety

• reports that recalled toys may be sent to developing countries where there is little control1, and

• potential of recycling plastics with unknown content of hazardous substances (such as brominated flame-retardants).

Since international press coverage of product recalls in 2007 due to non-compliance with regulations on chemical content public awareness has been growing. This growing awareness is reflected in EU market surveillance data. The RAPEX (Rapid Alert System for non-food consumer products2) annual report shows that toys were the most frequently notified product category at 28% of all notifications, with the two most important risks associated with toys being choking and too high levels of restricted chemical substances such as certain phthalates. On the other hand, NGOs note low consumer demand for information on chemicals in toys in some markets. They explain low awareness among consumers means consumers do not know what chemicals to ask for, but it does not mean that they are not interested.

3.3. Scope and methodology We focused parts of this case study on the sub-product group “plastic toys” - specifically in order to map the life cycle of a toy and to select stakeholder groups to involve in our expert survey3. The aim of this approach was to reduce the complexity of studying a fragmented sector with heterogeneous products. However, in the course of the study, expert input and key findings actually addressed much higher level issues. Study participants did not speak specifically about plastic toys but about issues relevant to toys made of many materials and relevant for the toy sector overall. Electronic toys were excluded from this study.

In terms of the geographical scope, the study was designed to cover all regions, however the most input was received from organisations based in the EU.

Government respondent from Africa to the scoping survey http://ec.europa.eu/consumers/safety/rapex/index_en.htm The product group plastic toys was selected because it features a very complex supply chain on the one hand as well as encompasses many chemicals of concern. Furthermore, the product group plastic toys forms one of the major product groups in terms of sales volume. At the same time, we assume that market structures and product life cycles of plastic toy products do not vary in such a substantial way from other toy sub-groups that results cannot be transferred.

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3.3.1. Survey set-up The survey consisted of a series of expert interviews with relevant stakeholder groups.

Interviews were based on interview guidelines that established a framework of topics to be covered.

3.3.2. Survey responses Our survey was carried out in Q3 and Q4 2010 and included 30 experts from different stakeholder groups. For a more detailed participants list, please see our list in the annex.

We assume that the majority of organisations who were willing to share their insights in our consultation were organisations with good control over toy safety, are actively interested in the issue and hence willing to share their experience. We therefore assessed our interviewee’s answers as reflecting rather sophisticated approaches of dealing with chemical safety. This bias in the survey results was taken into account in their analysis.

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4. Overview of the sector The global toy sector is characterised by thousands of small firms and only a few large players. The majority of the world’s toys are manufactured in China and the largest market for toys is the United States. The US, Europe and Japan have more regulations on toy safety than other countries and as they represent the largest markets, their regulations are referred to by global manufacturers.

The exchange of CiP information among material suppliers, producers and retailers is linked to their size and buying power, but also the nature of relationships. Long-term relationships tend to favour more effective CiP information exchange.

As is the case in many other sectors, product offerings change rapidly with the seasons and a wide variety of materials are used, including wood, polymers, metal, textiles, electronics, paints and coatings. Thus, the market is dynamic and diverse.

Chemicals are added intentionally to convey certain functional properties to toys, and inadvertently as contaminants from processing. Chemicals are introduced during compounding, material conversion and painting, and may also be released as gaseous emissions, dust or spills. They are also released during use, where they may be ingested, inhaled or adsorbed via the skin. A list of chemicals particularly relevant for toys is presented in section 4.7.

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Toy Markets in the World 2009 Edition. NPD Group, June 2009.

U.S. Department of Commerce Industry Report: Dolls, Toys, Games, and Children’s Vehicles Toy Markets in the World for 2008, study by NPD Group in 2009.

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