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    Protecting children from unsafe toys - feedback to European Commission

    Have your say – Protecting children from unsafe toys

    Have your say –  Protecting children from unsafe toys

    When

    July 28, 2023 - October 31, 2023    
    12:00 am

    Where

    You can also get involved in forming EU laws. The European Commission would like to hear your views on laws and policies currently in development. They offer a platform “Have your say” with the list of all new EU initiatives open for public consultation. You need to register to write your feedback. https://ec.europa.eu/info/law/better-regulation/have-your-say

    There are always 5 stages of each EU initiative, each stage is open for public consultation for a specific time frame:

    1. In preparation
    2. Call for evidence
    3. Public consultation
    4. Draft act
    5. Commission adoption

    Protecting children from unsafe toys and strengthening the Single Market – revision of the Toy Safety Directive

    About this initiative: This initiative aims to protect children better against risks in toys, particularly from chemicals. It builds on work such as the chemicals strategy for sustainability, and on an evaluation of the current toy safety rules completed in 2020.

    Feedback period: for stage 5 it is 28 July 2023 – 31 October 2023

    Link: https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/13164-Protecting-children-from-unsafe-toys-and-strengthening-the-Single-Market-revision-of-the-Toy-Safety-Directive_en

    Feedback from Europeans for Safe Connections

    We “Europeans for Safe Connections” welcome this initiative to ensure a high level of toy safety to safeguard the health and safety of children by setting harmonised safety requirements. We agree with the Article 5 Product requirements:
    Toys shall not present a risk to the safety or health of users, including the psychological and mental health, well-being and cognitive development of children,

    Therefore we have the following comments to The Proposal for a Regulation:

    1) Article 6 Warnings:
    We want to add one more category into point 2: toys with wireless radiation

    2) Article 21 Safety assessment:
    We want to add one more hazard into point 2a: “Cover all the…electrical, electromagnetical, …hazards…”

    3) We suggest to add into Annex V or Annex VI the information whether the product emits the radiofrequency electromagnetic fields and the exact parameters – frequency, intensity, how to switch the wireless radiation off and if the product can be used without this radiation.

    EXPLANATION:

    We refer to the first part of The Proposal – The context of the proposal: “The Directive already contains a general prohibition on substances in toys that are carcinogenic, mutagenic or toxic for reproduction (CMRs).“

    In 2011, The WHO/International Agency for Research on Cancer has classified radiofrequency electromagnetic fields (RF EMF) as possibly carcinogenic to humans *1, based on an increased risk for glioma *2, associated with wireless phone use.

    Children are more sensitive to environmental pollutants than adults. See our proposal to EC *3. Connected toys, smart watches, wireless headphones and other radio devices should be subject to precautionary measures in relation to children and the adverse effects of non-thermal non-ionising radiation from wireless – radio equipment should be included in this regulation.

    Since 2022, together with the NGO Phonegate Alert *4 we have been addressing consumer protection authorities, EC and EP policy makers to recall 42 non-compliant mobile phones that have been found to exceed legal exposure limits by the French agency ANFR inspections. In addition to violating legislation, there is a risk to human health. We estimate millions of defective phones, tablets, etc. on the EU market. We conclude from these findings that a number of non-compliances may accompany other wireless (connected) devices.

    E.g. such a non-compliant children’s smartwatch with mobile phone functions could generate excessive radiation exposure at poor signal quality, not only at 0 mm from the child’s body. With active position tracking, etc., there is constant exposure of the child to the radiation. In recent years there is explosion of wireless electronics, toys, drones and an absence of caution. With wireless headsets, wireless VR, an increased dose of microwave radiation is reaching the brain through the eyes and ears, due to the absence of skull bone as a barrier. Children are in close contact with the connected toys. A lot of valuable scientific literature demonstrated the adverse non-thermal biological health effects of RF EMF harms reproductive functions *10-17 and fetal development *18, *19.

    Every child has the right to health. We ask that children should have option to use radiation-free non-wireless solutions. To avoid consumers being exposed unknowingly, they must be given explicit informed consent about possible adverse health effects from RF EMF. If a manufacturer offers wireless device, the child’s exposure as low and as infrequent as possible must be ensured. Wireless radiation from the device must be able to be stopped completely without any software override (e.g. by a specific hardware switch).

    We call on those responsible for health protection to start regularly inspecting all mobile phones, but also all other wireless devices, by independent authorities, before placing the devices on the market and preferably radio equipment provided to children. Some toys on the EU market do not state that it´s emitting radiation. Clear visible warning about the risks should be placed on every wireless consumer equipment and reports of measurements for all wireless antennas must be included. If non-compliance is found, the devices is immediately withdrawn from the market and reported to RAPEX and ICSMS.

    Moreover, many connected toys on market are vulnerable to security threats *5 and sensitive data *6 of children are collected.

    Best regards
    Kamil Bartošák,
    board member of Europeans for Safe Connections

    Reference list:

    *1 https://www.iarc.who.int/wp-content/uploads/2018/07/pr208_E.pdf;
    *2 http://www.pubcan.org/icdotopo.php?id=5605;
    *3 https://signstop5g.eu/en/solutions/protection-of-all-life-on-earth/proposal-1;
    *4 https://phonegatealert.org/en/phonegate-alert-ready-to-take-legal-action-against-anfrs-failings/;
    *5 https://resources.infosecinstitute.com/topics/iot-security/smart-toys-and-their-cybersecurity-risks-are-our-toys-becoming-a-sci-fi-nightmare/;
    *6 https://www.cbsnews.com/news/smart-toys-data-collecting-advertisers/;

    *11 https://www.tandfonline.com/doi/full/10.1080/09603123.2022.2030676;
    *12 https://www.frontiersin.org/articles/10.3389/fphys.2021.732420/full;
    *13 https://www.ncbi.nlm.nih.gov/pmc/articles/PMC6240172;
    *14 https://www.sciencedirect.com/science/article/abs/pii/S0013935121010781;
    *15 https://www.sciencedirect.com/science/article/abs/pii/S0269749121005340;
    *16 https://pubmed.ncbi.nlm.nih.gov/18804757/;
    *17 https://pubmed.ncbi.nlm.nih.gov/17669405/;
    *18 https://pubmed.ncbi.nlm.nih.gov/29165149/;
    *19 https://www.ncbi.nlm.nih.gov/pmc/articles/PMC3341445/;

    toys_feedback_en

    Link to our feedback: https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/13164-Protecting-children-from-unsafe-toys-and-strengthening-the-Single-Market-revision-of-the-Toy-Safety-Directive/F3436172_en

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