An opinion piece by Catherine Van Reeth, director general of TIE, on how the organisation has engaged with policy makers on behalf of the industry on environmental sustainability issues.
Even though the success of the world’s governments to come to meaningful decisions at the COP26 may be doubtful, their ambition for industry remains very high and this is especially so in the European Union. Companies need to be aware of potential changes to prepare for, offset costs where possible and, in the best of circumstances, use the changes as opportunities for their business.
There are a number of areas where Toy Industries of Europe (TIE) has engaged with policy makers on behalf of the industry on environmental sustainability issues over the past year and this will continue into next year. Just to mention a few proposals that are underway in 2022:
- New RoHS (Restriction of Hazardous Substances in electronics and electrical products) rules will further restrict the use of certain chemicals for all toys with an electrical function, even if that is a secondary function.
- New Packaging and Packaging Waste proposals will impose consumer information on how to dispose of packaging materials correctly. There will likely be design requirements to enable recycling, encourage reuse and to restrict ‘over packaging’. There will also be ‘incentives’ to stimulate uptake of recycled content and likely reuse targets will be set.
- EU proposals for biobased, biodegradable and compostable plastics will interest companies that are planning to or are already using more biobased materials for their toys or packaging. Manufacturers of biobased plastics may need to address concerns about a perceived lack of information for consumers, measure biobased content in plastics or explain the sustainability of the feedstock used for production. For biodegradable and compostable plastics, companies may need to clarify their potential applications and ensure effective biodegradation. New proposals on microplastics are also expected
- Changes to the batteries’ legislation may see requirements introduced for all batteries to have recycled content, be removeable and replaceable.
A main preoccupation for TIE is our trusted Toy Safety Directive (TSD) which is being modified. As the main legislation impacting the toy industry, this will affect every toy company across Europe. Some of the areas under discussion are stricter rules around chemicals, particularly for toys for over 3s; stricter requirements to demonstrate compliance; potential increases in third-party testing and potential new changes on connected toys. These issues are likely to have a high impact across the sector and companies would be advised to follow the discussions closely.
TIE, and more widely the responsible toy industry, has always had toy safety as a priority concern. Making high quality, safe toys for children to play with must be top of our agendas, as it allows children to nurture the skills they need for life. However, increasingly we see emphasis being placed on environmental initiatives which have the potential to conflict with toy safety requirements.
There is a strong drive to avoid all chemicals of high concern, even when these are already restricted to ensure there is no exposure. The concern for our industry is that in some cases, they add extra safety for the child; for example, they can give plastics extra strength to prevent them from breaking and releasing hazardous small parts or causing dangerous sharp edges. Preservatives are used in finger paints to kill the bacteria children would otherwise be exposed to, and in (locked) battery compartments, we use flame retardants for obvious reasons. These are all very good reasons for the use of some chemicals of high concern. Nevertheless, the ‘green’ agenda seems to want total bans. This will lead to a loss of functionality and choice for children and families. We must collectively find a sensible way through these discussions, ensuring toys are safe, reduce our impact on our planet whilst ensuring children have a wealth of enriched play experiences.
With all these potential changes on the political agenda for 2022, companies need to remain aware of the discussions and potential challenges. Many of the proposals will involve costs and there may be multiple materials changes needed. In some cases, there may be no alternatives, and in other cases the alternatives will be considerably more expensive. The cost for external expertise and testing is also likely to increase significantly. Knowing what changes are coming can help companies to offset the worst of those costs.
TIE constantly addresses the need for new policy to be fair – to consumers and to business. But change is coming and it is best that companies prepare. That forward focus creates some opportunities for companies too. It is important for companies to be able to find the right balance between the costs of investing in sustainable changes and the positive benefits for the planet, the company reputation, the benefit of reduction savings and the positive impact on consumer expectation. Many of the changes that are in discussion are unstoppable, and it pays for a clever company to think ahead, embrace the inevitable and turn that into a positive benefit for the business.
Many toy companies have already recognised the need to embrace an environmentally sustainable agenda. We should not forget to celebrate those that are already making great achievements – so that is what TIE’s Play for Change Awards do each year with the Sustainability prize.
The sustainability award is given to a toy that will educate children about sustainability, or to an initiative which deploys sustainable practices.
The most recent TIE Play for Change Gold Award went to Dantoy’s Green Bean, a range of toys made from recycling the company’s own waste materials. The plastic used to make the toys is collected from in-house production and turned into new toys. The judging panel welcomed the efforts Dantoy has taken to reduce the consumption of virgin materials and tackle the generation of waste. The Green Bean toys have small variations in shades of colour, or ‘imperfections’ due to the use of scraps, and the panel thought this a brave but thought provoking and change-making initiative.
This year’s Silver Award went to Adventerra Games for their range of board games that cover a wide range of environmental topics. Ecologic Puzzle and Memories, Polar Adventure and Hungry Bins introduce children to complex topics from climate change to the importance of saving water, animal conservation and recycling. They educate children without overwhelming them and make learning fun through play.
BioBuddi won the Bronze Award for their BioBuddi Pixel and Create which enables children to create artwork using the pixels made of bioplastic. BioBuddi uses sugarcane that comes from sustainable sources, backed up with a Lifecycle Assessment, to ensure its toys are CO2 neutral and fully recyclable.
Every year the judging panel is overwhelmed by the breadth of initiatives that the toy industry is undertaking to make a difference to the planet. The 2022 awards will open in February and cover sustainability, empowerment and the promotion of future skills. If your company has an initiative to be celebrated, that was launched in 2021 and shows what you are doing to make a difference – we want to hear about it! You could be our change-maker of 2022! Visit the website here to find out more. There is also a link where you can register your interest so you will be notified when the awards open and to read about more of the initiative that received commendations from the jury.
If you would like to keep up-to-date on policy news, find out more about the topics in this article or join the discussion on future legislation, please get in touch to find out about membership – https://www.toyindustries.eu or contact info@toyindustries.eu.
If you would like more information on UK policy or how European issues impact UK companies please contact the BTHA at admin@btha.co.uk.
The February edition of Toy World has an environmental and sustainability focus and can be read here.
