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Survey as well as health assessment of chemical substances in school bags, toy bags, pencil cases and erasers

2 Survey and legislation

• 2.1 Market surveys
  • 2.1.1 Introduction
  • 2.1.2 Market survey – categories
  • 2.1.3 Market survey – the Internet
  • 2.1.4 Statistics
  • 2.1.5 The retail trade
  • 2.1.6 Trade organizations
• 2.2 Legislation
  • 2.2.1 Selection criteria
  • 2.2.2 Selected products

2.1 Market surveys

2.1.1 Introduction

A study of the types of products which are on the Danish market has been carried out. Furthermore, a study of which materials they are made of or which materials being a part of them as well as at which age group these products direct.

This information is provided through contact to producers, suppliers and their trade organization, Legetøjsbranchens Fællesråd, which is the trade organization for the whole toy industry in Denmark. Booksellers and their common purchase organization has been contacted as well as large super markets such as Dansk Supermarked importing to Bilka and Føtex and COOP importing to Super-Brugsen and Kvickly. Products from 10 kroner shops such as Tiger, from bag shops and department stores such as Magasin are also included in the study.

For both school bags and erasers Statistics Denmark has calculated the yearly consumption of these products expressed both as quantities and as total value.

2.1.2 Market survey – categories

The Danish Safety Technology Authority has evaluated which products are classified as toys. This evaluation is based in the following documents:

• Toys Statutory Order (TSO)
• The General Product Safety Directive (GPSD)
• Guide no. 4 from the Commission dated 18.02.2003 (Price and size - items mentioned in Guide no. 4) is evaluated as being irrelevant for the purchased products
• Table showing the purchased products delivered to the Danish EPA
• Table 2.3 showing which products being CE labelled

This evaluation is shown in Table 2.3.

We have chosen to divide school bags, toy bags, pencil cases and erasers into the following categories:

School bags

Bags, which from the retail trade are labelled as school bags, may be regarded as and according to the Danish Safety Technology Authority are regarded as being school equipment and not toy as they are used for storing of books, pencil cases, papers etc. and the bag itself is not used for play purposes. There are school bags with appendage where the appendage is toy and not the bag.

Toy bags

Cover a very wide range of bags, for instance:

• Bags for use in the pre-school age for packed lunch and spare clothes in nursery/kindergarten.
• Bags with toy content such as doll change bags, medical bags and tool boxes.
• Bags with another content such as small bags with hair elastics or underwear where the bag only appeals for play purpose.
• Various toy bags such as decoration bags, hand bags, shopping bags and teddy bear bags.
• Bags for games such as V. Smile Pocket carrying case, Gameboy case, PS bag.

Toy bags are estimated as being a product under either the Toys Statutory Order or under the General Product Safety Directive as shown in Table 2.3.

Pencil cases

• For school purpose.
• For play purpose – pencil cases in a size or with content not suitable for use at school. Often these appeal to smaller children. Pencil cases for play purpose are estimated as a product under either the Toys Statutory Order or under the General Product Safety Directive as seen in Table 2.3.

Erasers

• The traditional ones – erasers of a good quality without print, colour or fragrance.
• The popular ones – erasers with popular prints, for instance Batman, Disney figures and Diddl being used for erase purposes. These erasers may contain fragrances.
• For play purposes – erasers in imaginative shapes and colours, perhaps with print and fragrances. Often these erasers are in a quality or size making them most suitable as collector's items or for play purposes. Erasers for play purposes are estimated as being a product under either the Toys Statutory Order or under the General Product Safety Directive as shown in Table 2.3.

2.1.3 Market survey – the Internet

In connection with this project the Internet is used partly to obtain an overview of the market of school bags etc., and partly as basis for continuous contact to relevant companies. A list of Internet pages of special interest and a list of products being sold are shown in Appendix A.

2.1.4 Statistics

According to Statistics Denmark the industry has stated an import and export CN (combined nomenclature) after units, import and export, goods and time in Table 2.1.

Table 2.1 Import and export of goods according to Statistics Denmark

Due to a changed practice for the release of the foreign trade figures, the trade figures for the latest month now contain detailed figures for the trade of goods with non-EU countries. The trade figures for the intra-community trade are still available at an aggregated level only. The detailed figures for the trade with countries outside the EU are found under foreign trade – Detailed foreign trade (monthly).

No value is stated for”the Industry’s sale of own goods after unit, product category and time” which indicates that no goods from these product categories are produced in Denmark.

2.1.5 The retail trade

Today, on the Danish market there are two large convenience chains, namely COOP Denmark (among others the convenience store chains Kvickly, Irma, Fakta, Super-Brugsen, Dagli’Brugsen and LokalBrugsen) and Danish Supermarket Group (DSG) (among others the convenience store chains Bilka, Føtex, Netto and A-Z). Both convenience chains control that the toy is delivered with CE labelling. Furthermore, school bags etc. are sold in bookstores, bag shops, department stores and 10 kr. shops.

Information from the retail trade is shown in Appendix A.

2.1.6 Trade organizations

The trade organization, the Toy Business Council (LF), has been contacted to obtain information regarding the market for toy bags etc. The organization works as a consultant for their members and ensures that they are updated with regard to new rules, laws, directives, news and warnings. The organization only works at product level if there are legal matters of dispute. The trade organization does not have its own set of rules but they inform the members about new regulations. Laws and rules are typically provided to the trade organization through the Danish EPA and Euro Commerce.

2.2 Legislation

Safety requirements to toy

For toy”Statutory order on safety requirements to toys and products which due to its appearance can be confused with foods” (Stat. Ord. 1116, 2003) is applicable. Toy is defined as products “which clearly are designed or intended for play purposes for children below 14 years”. If the erasers have a design as a figure (a burger, an ice or similar) the statutory order on safety requirements to toy must also be met.

According to the Toys Statutory Order (Stat. Ord. 1116, 2003) a toy must only be sold if it fulfils the EU legislation on safety requirements to toy or if it is produced in accordance with a technically approved prototype (and approved by a body of the authorities in an EU country). Toy fulfilling these safety requirements must be provided with a CE label before it is sold.

The EU legislation on safety requirements includes the standards which are stated in Appendix 3 of the Toys Statutory Order (Stat. Ord 116, 2003). These are the EN71 series on safety requirements to toy as well as the Executive order on high-voltage power for electric toy. EN71-3 (Part 3: Migration of special substances) includes limits for migration of metals when the toy is put into the mouth. These limits are shown in Table 3.4.

Ban on phthalates in toy for children

According to the Statutory Order no. 151 of 15.3.1999 “Statutory Order on ban on phthalates in toy for children at the age of 0-3 as well as certain infant articles” it is forbidden to produce, sell or import products containing more than 0.05% (w/w) phthalates for the following types of products:

• Toy clearly designed or intended for play purposes for children at the age of 0-3 years.
• Infant articles for children at the age of 0-3 years, i.e. products which are intended to or must be expected to be put into the mouth (dummies, bibs, jewelleries as well as bath equipment etc.).
• Product which is expected to be used as toy by children at the age of 0-3 years as a result of the design of the product including printing.

However, this statutory order is replaced by a new”Statutory Order on ban on phthalates in toy and infant articles” which became effective in the spring of 2007 (Stat. Ord. 786, 2006). The new rules include ban on six phthalates in infant articles and in toy for children up to the age of 14.

According to the new statutory order it is banned to use the phthalates DEHP, DBP and BBP in concentrations above 0.1% as well as to import and sell toy and infant articles containing these phthalates in concentrations above 0.1%. Furthermore, it is banned to use the phthalates DINP, DIDP and DNOP in concentrations above 0.1% in products which children may put into the mouth as well as to import and sell toy and infant articles containing these phthalates in concentrations above 0.1% which children may put in the mouth.

Finally it is banned to use all other phthalates in concentrations above 0.05% in toy for children at the age of 0-3 years as well as in infant articles for children at the age of 0-3 years which are intended to be put into the mouth.

Application limitation of certain heavy metals

For the heavy metals lead, mercury and cadmium legislation regarding limitation of the application of these substances is available. The following legislation is relevant:

• Statutory order on ban on import and sale of products containing lead. Stat. Ord. 1012 of 13.11.2000.
• Statutory order on ban on import, sale and export of mercury and mercurial products. Stat. Ord. 627 of 01.07.2003.
• Statutory order on ban on sale, import and production of products with cadmium content. Stat. Ord. 1199 of 23.12.1992.

According to these statutory orders it is banned to import and sell products containing more than 100 ppm (mg/kg) lead and mercury respectively and more than 75 ppm cadmium in the homogeneous single parts of the product.

2.2.1 Selection criteria

The following selection criteria for products for further analysis have been applied:

• Products from each of the above-mentioned categories have been selected so that both school bags and various categories of toy bags, pencil cases and erasers have been selected for analysis.
• All the above-mentioned contact groups (toy retailers, book sellers, supermarkets, department stores and 10 kroner shops) have been contacted and at visits at representatives for these contact groups all the goods being interesting for this project have been photographed and described. On this basis, products from all the above-mentioned contact groups have been selected.
• All the selected products contain plastic parts or are completely made of plastic.
• The products are selected on the basis of information from contact to various contact groups so that products selling well are selected. (It has not been possible to get a top 3 list of the most sold products within the above-mentioned categories from all contact groups but where possible it has been taken into consideration during the selection of products for analysis).
• Certain products are sold both in the shops and on the Internet and therefore products being sold both on the Internet and in various shops have been selected for further analysis.
• Several types of products are available at several types of contact groups (Spiderman school bag from Marvel is available at supermarkets, book sellers and in bag shops).

2.2.2 Selected products

26 different pieces of erasers are bought based on the above-mentioned selection criteria. These 26 pieces of erasers represent a wide choice of the types of erasers being on the market today. On the basis of the market survey the most frequently sold school bags are selected as well as a random choice of toy bags and pencil cases. In total 43 products are selected for the analyses.

Besides the 26 different erasers, the following products are selected for further analysis:

Table 2.2 Products selected for analyses

Information regarding material selection and other relevant information is also printed on the packaging of the individual products being selected for further analysis. This information is listed in Table 2.3 below. The Danish Safety Technology Authority’s assessment is also stated in the table. TSO in the table states that the product must comply with the Toys Statutory Order. GPSD in the table states that the product must comply with the General Product Safety Directive.

Table 2.3 Labelling or remark stated on the packaging of purchased products

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Version 1.0 August 2007, © Danish Environmental Protection Agency