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SAFEGUARDS | Toys & Juvenile Products NO. 167/16

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Turkey has recently published new regulations for toys. The landmark legislation is adopted from the European Union and will become effective on April 4, 2017.

On October 4, 2016, Turkey published the Toy Safety Regulations (Oyuncak Güvenliği Yönetmeliği) [1] under Number 29847 in the Resmi Gazete, the Official Gazette of the Republic of Turkey. This landmark legislation is essentially adopted from the European Toy Safety Directive 2009/48/EC [2] (TSD).

The new law has a number of important requirements, including:

  • EC declaration of conformity (DOC)

  • New requirements for chemical, physical and mechanical, flammable and electrical properties

  • Obligations for economic operators

  • Safety assessments

  • Technical documentation

  • The use of chemicals that are classified as carcinogenic, mutagenic or reprotoxic (CMRs)

  • The use of European (EN) standards for presumption of conformity

The new law on Toy Safety repeals the former legislation under Number 28807 of 31 October 2013. [3] It is enforced by the Minister of Customs and Trade and will become effective on April 4, 2017; six months after publication in Resmi Gazete.

It is important that toys are also obliged to conform to hazardous chemical requirements such as azo dyes and phthalates prescribed in Regulation Number 29263 of 14 January 2015. [4] Turkey at present has not published legislation to regulate  formamide, certain preservatives, bisphenol (A) BPA and flame retardants for certain toys that are stipulated in Appendix C of the TSD. These substances may be regulated by amendment.

Highlights of the new law are summarized in Table 1. 

Item Parameter Highlight
1 Chemicals

New requirements such as:

  • 66 Allergenic fragrances
  • Migration of n-nitrosamines and n-nitrosatable substances in toys intended for children under 36 months or in other toys intended to be placed in the mouth
  • 19 Soluble elements. It is interesting to note that the strengthened limits for soluble barium [5] and soluble cadmium [6] from the TSD are adopted
2 Chemicals classified as CMRs
  • CMR substances category 1A, 1B or 2 are restricted or prohibited in toy components or micro-structurally distinct parts of toys
  • The use of nickel, a CMR category 2 substance, is permitted in stainless steel materials
3 Cosmetic toys
  • To comply with the compositional and labeling requirements under the Cosmetic Regulations in Number 25823 of 23 May 2005 [7]
4 Economic Operators
  • Obligations for manufacturers, authorized representatives, importers and distributors
  • An importer or distributor placing a toy on the market under its name or trademark can be considered a manufacturer
5 European Community Declaration of conformity (EC DOC) and technical documentation
  • Both are to be drawn up by the manufacturer and to be kept for 10 years after the toy has been placed on the market
6 Safety assessment
  • Manufacturers to carry out a safety assessment on chemical, physical, mechanical, electrical, flammability, hygiene and radioactive hazards that the toy may present before placing it on the market
  • This assessment must be kept in the technical documentation
7 Toys that are substances or mixtures
  • Comply with Number 28848 (Mükerrer) of 11 December 2013 [8] relating to classification, labeling and packaging of dangerous substances
8 Toy safety
  • Toys must conform to general safety requirements, and the prescribed specific safety requirements in Appendix 2 of the regulation
9 Toy safety standard
  • Recognizes harmonized standards [9] that are published in the Official Journal of the European Union (OJEU) for presumption of conformity

SGS offers a wide range of services to ensure that your products comply with the EU Toy Safety Directive. We offer training, safety/risk assessment, technical documentation check, labelling review, testing according to harmonised standards, SVHC screening, inspections and audits. With the largest global network of toy experts and testing facilities around the world - around 20 toy labs worldwide including 3 EU Notified Bodies (France, Germany and Netherlands), SGS is the partner to trust. Please do not hesitate to contact us for further information or visit our website.

For enquiries, please contact:

Hing Wo Tsang
Global
Hardlines
t: +852 2774 7420

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