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eu commission, transparency and toy safety June 5, 2008

Posted by Bradley in : Uncategorized , trackback

The Commission has published the final report of an expert group on Evaluating Business Safety Measures in the Toy Supply Chain. The fact finding exercise which led to the report was announced in a press release on what the Commission was doing about toy safety issued in November 2007. It’s an interesting report which raises some good questions, and makes a list of recommendations, including a focus on harmonisation of toy standards at the international level. There’s an issue about the need to make it easier for manufacturers of toys outside the EU to know what rules they need to comply with (this is, of course, a general issue about the limits to the usefulness of harmonisation initiatives):

Chinese manufacturers claim that it is difficult for them to fully understand the legislative approach in the EU whereby conformity with a certain harmonised safety standard does not necessarily mean the product is in compliance with all applicable safety requirements as set out in the legislation. Although efforts from the EU and the Chinese authorities, as well as the European toy industry, to inform the Chinese toy manufacturers about the applicable regulations and harmonised safety standards for toys in the EU have resulted in greater awareness, there is still a need to improve in particular the understanding of requirements that are regulated in nontoy specific legislation such as for certain phthalates and azo colorants.

On the other hand, the whole exercise doesn’t seem to be a model of transparency. The report does not identify an author, nor does it list the members of the expert group. It states:

This report reflects the results of an evaluation project undertaken under the direction of an independent expert group with the support and technical assistance of the European Commission. The contents of this document do not necessarily reflect the views of the European Commission and are in no way an indication of the Commission’s future position in this area. Neither the Commission nor any person acting on its behalf can be held responsible for any use that may be made of the following information.


An ad hoc expert group was established providing independent advice and consisting of representatives of the main stakeholders including manufacturers, importers, retailers, test laboratories, consumers and Member States. The Commission provided support and technical assistance to this group.

The Commission published one press release about Commissioner Kuneva presenting the report, and another press release which gives some information about the members of the expert group which states:

The group included following experts:

* Helen Amundsen (ANEC/BEUC)
* Wim Berkel (Dutch Food and Product Safety Authority)
* Jerome Billot (Carrefour)
* Alf Cash (Mattel)
* Natale Consonni (Istituto Italiano Sicurezza dei Giocattoli)
* Linda Crane (British Retail Consortium)
* Brian Ellis (Toy Industries of Europe)
* Ton de Koning (Dutch Food and Product Safety Authority)
* Daryl Scrivens (HASBRO)
* Sanda Stefanovic (SGS)

It’s not clear whether the “the group included” language is just eurospeak, or whether there were other experts also included who are not listed. And why make it anything other than really easy to find out who the experts were?


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