The UN Environment Programme’s (UNEP) Chemicals and Health Branch has published, as part of a Strategic Approach to International Chemicals Management (SAICM) project, a report on chemicals-related toy safety policies and regulations in selected low- and middle-income countries. The report seeks to help determine activities to be prioritized under SAICM. Toys often include such materials as plastics, textiles, wood, and metals, many of which are made of or contain manufactured chemicals, including polymers, pigments, or plasticizers.

Since children are more vulnerable to the health impacts of such chemicals, their use in toys is highly regulated throughout the world. Activities under SAICM also have prioritized chemicals of concern in toys, including through a Global Environment Facility (GEF)-funded project to accelerate the adoption of measures by value chain stakeholders, including governments, to track and control chemicals in the toy supply chain. 

The report focuses on the low- and medium- income countries with the highest total import value of toys from China. It analyzes toy safety policies in these countries that address chemicals of concern in toys, with the exception of “chemical toys” such as educational experimenting sets, and electronic toys.

All the medium-income countries reviewed (Mexico, India, Russian Federation, Kazakhstan, Malaysia, Brazil, Thailand, Viet Nam, the Philippines, and Indonesia) have toy safety policies with specific provisions for the content of certain chemicals in toys, on material-specific migration limits for eight elements (antimony, arsenic, barium, cadmium, chromium, lead, and selenium). While some countries detail specific requirements and regulations for these elements in their regulatory text, others merely reference national or international standards. In eight of the ten countries, safety policies address ortho-phthalates, a group of chemicals used to make flexible plastics, primarily PVC or vinyl. Five of those have explicit requirements regarding certain ortho-phthalates in toys.

In the low-income countries reviewed, the research found evidence of existing regulations in Tajikistan and Tanzania. No information was found regarding toy safety policies in the other countries (Yemen, Syria, Democratic People’s Republic of Korea, Mozambique, Madagascar, Benin, Guinea, and Democratic Republic of Congo).

For some chemicals, regulations in different countries are highly aligned. But considerable differences remain in many areas between chemical requirements of toy safety policies. For example, the EU toy safety directive severely restricts chemicals known, presumed, or suspected to have carcinogenic, mutagenic, or reprotoxic effects for use in toys. This differs from a chemical-by-chemical approach applied in many other toy safety regulations.

International standards are a key entry point for countries establishing chemical-related toy safety policies. The report states that standards and trade policies must be ambitious and flexible, and facilitate the establishment of stricter safety requirements where needed.

Compliance and enforcement are also key to protecting children from chemical-related risks in toys. Toy manufacturers must understand the regulatory requirements of the markets they are selling to and the capacity to control and ensure respective requirements in the raw material. The report explains that this can be challenging for small- and medium-sized companies or companies not integrated into highly controlled supply chains of original equipment manufacturers or large retailers. Countries manufacturing or importing toys should also establish enforcement mechanisms to ensure compliance with local regulatory requirements.

The report urges enhancing collaboration among stakeholders in the toy value chain and improving synergies among regulatory requirements, industry capacity for compliance, transparency along the supply chain, and coordinated enforcement.

This document was developed within the framework of the GEF project on Global best practices on emerging chemical policy issues of concern under SAICM. The project is funded by the GEF, implemented by the UN Environment Programme (UNEP) and executed by the SAICM Secretariat. [Publication: Review of Chemicals-related Toy Safety Policies and Regulations in Selected Low- and Middle-income Countries]