How do toy companies respond to EU REACH regulations?

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China's toy products exported to the EU generally include dozens of products such as wooden toys , PU toys, electric toys , stuffed toys, plush toys , intellectual toys , baby carriages , remote boat models, models and puzzles. In the REACH regulation, toys can be broadly classified into four types: (1) "items" that do not contain intentionally released substances, such as ordinary toy cars, and (2) "items" that contain intentionally released substances, such as scented puzzles. Etc.; (3) "Substances/preparations in special containers", such as bubble guns, etc.; (4) "Substances/preparations" such as watercolor paints. Different types of toy products have different responsibilities in REACH, so the first step in the REACH response of toy companies is to analyze the type of their products in REACH and the responsibilities that need to be fulfilled against the REACH regulations and related guidance documents. For products that are more difficult to identify, you can seek the help of a professional agency).

The following discussion will be based on the case of a "scented bubble gun". This analysis is based on a case study of the China Inspection and Quarantine REACH Solution Center and toy companies.

The “scented bubble gun” is defined in the REACH regulation as “the substance/preparation in special containers” and contains “intentionally released substances”. That is, the bubble gun itself belongs to the "special container", which belongs to the category of "item", and the bubble liquid inside belongs to the category of "preparation", and the aroma substance contained in the bubble gun belongs to the "intentionally released substance". The responsibility of the “scented bubble gun” in REACH is: (1) the responsibility of the bubble gun itself may be notified and limited; (2) the responsibility of the bubble liquid may be fulfilled (pre-) registered, authorized And restrictions; (3) The scent contained in the bubble gun may be subject to (pre) registration, authorization and restrictions. According to REACH regulations, China's toy companies need to appoint a professional and reliable neutral "single representative" to fulfill the relevant responsibilities in the EU REACH regulations.

The general steps for a scented bubble gun company to respond to EU REACH regulations are as follows:

1. List the type and quantity of bubble guns scented by the company on EU trade products;

2. Analysis of the substance components in the bubble liquid and the aroma substance;

3. According to other exemptions in the REACH Regulation, see if the bubble liquid and aroma substances are in the scope of exemption registration (substances in Annexes IV and V of REACH), and list all the substances that need to be registered;

4. According to the REACH registration guide (electronic version can be downloaded from the China Inspection and Quarantine REACH Solution Center website ) and the content of the substance in the finished cosmetics, calculate the tonnage of the company's exports of EU substances (it is more difficult to be Identify the product, you can seek the help of a professional agency);

5. List all the substances to be registered that are exported to the EU of 1 ton/year or more;

6. Collect information on substances subject to REACH regulations (name of substance, CAS number, etc.);

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