Know Your obligations!

The European Union implemented an electronic waste recycling system in 2003, under the Waste Electrical and Electronic Equipment Directive (WEEE 2002/96/EC). The WEEE Directive has now been transposed in national laws in all member countries of the European Union. The WEEE directive was designed to make equipment manufacturers financially or physically responsible for their equipment at its end–of–life under a policy known as extended producer responsibility (EPR).

Manufacturers must collect e–waste from consumers free of charge, and dispose of it in an ecologically friendly manner. EPR was seen as a useful policy as it internalized the end–of–life costs and provided a competitive incentive for companies to design equipment with less costs and liabilities when it reached its end–of–life. Since 13 August 2005, the electronics manufacturers became financially responsible for compliance to the WEEE directive. Under the directive, by the end of 2006 – and with one or two years' delay for the new EU members – every country has to recycle at least 4 kg of e–waste per capita per year.

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The Directive on the Restriction of the Use of Certain Hazardous Substances in Electrical and Electronic Equipment 2002/95/EC (commonly referred to as the Restriction of Hazardous Substances Directive or RoHS) was adopted in February 2003 by the European Union. The RoHS directive took effect on 1 July 2006, and is required to be enforced and become law in each member state. This directive restricts the use of six hazardous materials in the manufacture of various types of electronic and electrical equipment.
RoHS is often referred to as the lead–free directive, but it restricts the use of the following six substances:

1. Lead
2. Mercury
3. Cadmium
4. Hexavalent chromium (Cr⁶⁺)
5. Polybrominated biphenyls (PBB)
6. Polybrominated diphenyl ether (PBDE)

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Directive 2006/66/EC of the European Parliament and of the Council of 6 September 2006 on batteries and accumulators and waste batteries and accumulators and repealing Directive 91/157/EEC, commonly known as the Battery Directive, regulates the manufacture and disposal of batteries in the European Union.

In the 1980s, batteries commonly contained hazardous elements such as mercury, cadmium, and lead, which when incinerated or landfilled, presented a risk to the environment and human health. Directive 91/157/EEC was approved in March, 1991, to reduce these hazards, with standardized requirements across EU countries. The 2006 law repeals and replaces older legislation.

The Battery Directive explicitly bans certain chemicals and metals in batteries; sets maximum quantities of chemicals and metals in batteries; requires proper waste management of these batteries, including recycling, collections, "take–back" programs, and disposal; sets financial responsibility for programs; and makes rules covering most phases of this legislation, including labeling, marking, documentation, reviews, and other administrative and procedural matters.

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Registration, Evaluation, Authorisation and restriction of CHemicals (REACH) is a new European Union Regulation of 18 December 2006. REACH addresses the production and use of chemical substances, and their potential impacts on both human health and the environment. Its 849 pages took seven years to pass, and it has been described as the most complex legislation in the Union's history and the most important in 20 years. It is the strictest law to date regulating chemical substances and will impact industries throughout the world. REACH entered into force in June 2007, with a phased implementation over the next decade.

When REACH is fully in force, it will require all companies manufacturing or importing chemical substances into the European Union in quantities of one tonne or more per year to register these substances with a new European Chemicals Agency in Helsinki, Finland. Because REACH applies to some substances that are contained in objects ('articles' in REACH terminology), any company importing goods into Europe could be affected.

REACH also addresses the continued use of chemical 'Substances of Very High Concern' (SVHC) because of their potential negative impacts on human health or the environment. The European Chemicals Agency may need to be notified of the presence of SVHCs in articles, if they are present above certain tonnage and concentration thresholds. Depending on the substance in question and its use, producers and importers may then be obliged to investigate its effects on human health and the environment.

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Electromagnetic compatibility (EMC) is the branch of electrical sciences which studies the unintentional generation, propagation and reception of electromagnetic energy with reference to the unwanted effects (Electromagnetic interference, or EMI) that such energy may induce. The goal of EMC is the correct operation, in the same electromagnetic environment, of different equipment which use electromagnetic phenomena, and the avoidance of any interference effects.

In order to achieve this, EMC pursues two different kinds of issues. Emission issues are related to the unwanted generation of electromagnetic energy by some source, and to the countermeasures which should be taken in order to reduce such generation and to avoid the escape of any remaining energies into the external environment. Susceptibility or immunity issues, in contrast, refer to the correct operation of electrical equipment, referred to as the victim, in the presence of unplanned electromagnetic disturbances.

Interference, or noise, mitigation and hence electromagnetic compatibility is achieved primarily by addressing both emission and susceptibility issues, i.e., quieting the sources of interference and hardening the potential victims. The coupling path between source and victim may also be separately addressed to increase its attenuation.

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The Pencils and Graphic Instruments (Safety) Regulations and the General Product Safety Regulations 2005 will control the safety of this type of product. These Regulations provide a legal framework to ensure that a producer or distributor supplies a safe product. The BS 7272 standards are designed to assess if safety caps or end closures are likely to present choking hazards.

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Compliance with the standard is legally required for all toys sold in the European Union.
The standard has been published in 11 parts:

• EN 71–1: Mechanical and physical properties
• EN 71–2: Flammability
• EN 71–3: Specification for migration of certain elements
• EN 71–4: Experimental sets for chemistry and related activities
• EN 71–5: Chemical toys (sets) other than experimental sets
• EN 71–6: Graphical symbols for age warning labeling
• EN 71–7: Finger paints
• EN 71–8: Swings, slides and similar activity toys for indoor and outdoor family domestic use
• EN 71–9: Organic chemical compounds – Requirement
• EN 71–10: Organic chemical compounds – Sample preparation and extraction
• EN 71–11: Organic chemical compounds – Methods of analysis

We will focus more on EN 71–9:

The standard is intended to restrict the presence of &organic chemicals& which can be toxic in toys for children. The European Commission instructed the European Standard Committee CEN to produce a standard to address the issue, but not to include chemicals already addressed elsewhere in other European legislation. – this explains some of the important exclusions such as:

• Chemicals covered by Directive 76/769 on the marketing and use of dangerous chemicals
• Toluene in pens
• Phthalate plasticizers

The standard covers the toys where there is the most likelihood of exposure of the child to toxic chemicals through:

• Mouthing
• Ingestion
• Skin contact
• Eye contact
• Inhalation

For most of the chemicals, the standard addresses the likely &migration& away from toy into child and not the total quantity of chemical in the product, so the techniques involve simulated extractions into water to represent a child sucking or chewing the product. This does not include packaging materials unless they have intended play value.

EN 71 Part 9 is only required if toys fall into specific groups

• Textile toys for children under 3 years
• Toys for children under 3 years intended to be mouthed
• Toys or components for children under 3 weighing less than 150g
• Mouth–actuated toys
• Inflatable toys >0.5m2
• Toys worn over nose or mouth
• Toys which child can enter
• Wooden toys
• Components of graphic instruments
• Toys which mimic food
• Toys intended to leave a trace
• Accessible liquids in toys
• Modelling clay (except those covered by EN 71 Part 5)
• Balloon–making compounds
• Imitation tattoos with adhesive
• Imitation jewellery

AZO dyes are sometimes used in printing inks so care should be taken with printed paper products. There is no requirement for packaging or cardboard to be tested unless it has play value.

Interpretations – There are a number of interpretations yet to be clarified for example:

• Does paint render a wooden surface not accessible?
• Should non aqueous liquids from pens be tested?
• Should non detachable components on large toys be tested?

Routes to conformity – EN 71 Part 9 specifically allows for both testing and declarations of conformity as ways of showing compliance.

We are committed to assisting and guiding our customers through this maze of legislation and make sure they and the recipients of the gifts are not only safe, ethically positioned, but you are protected legally, morally sound.

Book your executive briefing now.