Toy Safety

When implementing the Directive 88/378/EEC on the safety of toys, some Member States considered children’s books as toys. This led in several cases to considerable difficulties for the European children’s book publishing industry, especially in complying with the extra requirements applied to paper and cardboard books.
In January 2008, the European Commission proposed a new Directive of the European Parliament and of the Council on the safety of toys, repealing the existing one. The revised Directive, entered into force in July 2009, aims to improve the quality of toy safety regulations and simplify legislation. The technical product specifications are left to the European standardisation bodies CEN and CENELEC to regulate. Among the main objectives of the updating process was the clarification of the scope and definitions of the Directive; neither the old nor the new Directive explicitly mention children’s books, but toy books are presumably covered. The application of the Directive to economic operators (such as publishers) was subject to a transitional period of 2 years, expired in July 2011.
Upon adoption of the Directive, the Commission officially charged CEN with the task of revising the standards on toy safety; the mandate contained a specific reference to books, in particular those made of paper and cardboard, which prompted CEN to create a Task Group on toy books within its Technical Committee on Toy Safety. The Task Group, which met in March 2010, April 2011 and April 2012, has proposed an amendment aimed at exempting all types of paper and cardboard from certain extra mechanical tests; the amendment is under consideration by the CEN Technical Committee on Toy Safety.
Independently from the process of revision of the Directive, the Commission issued interpretative guidelines on the classification of books in the light of the toy safety regulation, found unsatisfactory by publishers.

  • FEP continued collecting all the available information on the European legislation and standards, from the institutions and directly from the standard setting bodies.
  • FEP maintained contacts and attended meetings at CEN with the people responsible for the management of the Technical Committee in charge of the toy safety standards, in order to obtain information, present the publishers’ case and create a liaison with the standardisation body with a view to an involvement in the process of revising standards.
  • Thanks to the liaison status obtained with the CEN Technical Committee 52, in charge of toy safety issues, FEP has appointed an observer to attend the discussions of the committee, and in particular of Task Group 4 “Toy Books”; the expert, Jean-François Lyet of Hachette, participated in the meeting of April 2012.
  • FEP provided information and advice to its members in order to reach out to the national standardisation bodies, which are the main decision-makers in the CEN Committees.
  • FEP attended regularly the Expert Group meetings on Toy Safety organised by the European Commission.
  • In February 2012, FEP organised a meeting between the Toy Safety Unit of DG Enterprise and the managers of the Publishing Industry Product Safety (PIPS) initiative, an online database that captures information on the chemicals used in books, to provide an example of best practice on behalf of the publishing industry.
  • FEP agreed with the Toy Safety Unit to keep an open dialogue with regard to the guidance document on the interpretation of the Toy Safety Directive on toy books.