Insights for Global Toy Recalls — Interview with the Experts

During UL’s webinar Overview of Global Toy Recalls, presented in September 2020, we received several questions from the audience.

In this interview, our experts, Elisa Gavazza, global toy lead, and Melissa Beran, senior human factors specialist, offer important insights about the recalls in the global market, including Europe (Safety Gate), U.S. (Consumer Product Safety Commission — CPSC), and Canada (Health Canada).

Contact us to receive more information about how UL can support your business to manage the challenges companies face with safety and quality assurance when trying to safeguard children’s toys.

Question: For Europe, where can I find a list of the national contact points for Safety Gate/Rapid Exchange of Information System (RAPEX)?

Elisa: The list of national contact points can be found on the Safety Gate/Rapex page on the EU Commission website. Here you can find useful details in case you need to inform the authorities if you find out that one of your toys sold in the EU market is dangerous.
Through this website, you can also visit the Business Gateway, a specific page strictly dedicated to the producer or distributor of the potentially dangerous product or the authorized representative. Please note that the submission of such notifications by third parties is strictly prohibited.

Question: Why are there so many notifications that are chemistry-related in Europe?

Elisa: There may be several considerations: the first one is that in general, there is a growing regulatory interest in the chemical safety of products, toys in particular, related to both human health and the environment. Another consideration is that there may be new products on the European market that can pose a specific type of chemical risks. For example, we can mention slimes and their noncompliance to boron limits in the EN 71–3 standard. This means that for certain types of slimes with certain formulations, specific risks not duly considered by the different manufacturers can arise. Chemical safety requires a high level of technical knowledge in the chemistry area.
If you want to read more about toy chemical safety, we invite you to read our article, “Key learnings from 2019 EU recalls: chemical hazard.”

Question: I am a toy manufacturer, until now, none of my products were notified in the European Safety Gate/Rapex. Unless any of my products will be notified, should I visit the Safety Gate page?

Elisa: This tool is very valuable for toy manufacturers who have not been affected by a notification, because you may find notification details of products that can be similar to what you produce or distribute. So, when you see a risk highlighted through the Safety Gate/Rapex, you should understand if any of the toys in your catalog may have a similar risk. I take this occasion to remind you that per the EU Toy Safety Directive 2009/48/EC, each toy design shall be subject to a Safety Assessment done by the manufacturer, taking into account the existing standards.

Question: In North America, is it true that a toy or other consumer products can be recalled even if there are no injuries?

Melissa: Yes. We see many recalls where there are no incidents or injuries, but the product has the potential to cause an injury. The product could also fail to meet a governmental requirement that bans the inclusion of a specific chemical or small parts that can be easily created. Therefore, CPSC or Health Canada can make the determination to recall the product. 

Question: Again, for toys in North America, is it design issues or manufacturing problems that cause the most recalls?

Melissa: Most errors that lead to recalls, not just of toys but of all kinds of consumer goods, are design mistakes. Flawed designs, such as sharp edges, long strings and small detachable parts, have been the cause of 75% of all U.S. toy recalls since 1988. Although a number of toys have been taken off the market due to safety concerns, year after year recalls steadily increase.

Question: What is the type of toy that is most often recalled in North America?

Melissa: In 2016, action figures and dolls accounted for the largest number of recalls, accounting for 25% of all toy recalls. Chemical content, most often phthalates, was the dominant product safety issue associated with these toys, most frequently with the heads of action figures and dolls. The second greatest number of recalls with action figures and dolls involved the detachment of a component, posing a potential small part choking hazard.