STILL toying with children's safety - .the UK government and online platforms are still not stopping the sale of dangerous toys to UK children ...
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STILL toying with children’s safety. ….the UK government and online platforms are still not stopping the sale of dangerous toys to UK children. The British Toy and Hobby Association calls for the law to change.
2 3 INTRODUCTION The British Toy and Hobby Association (BTHA) believes The BTHA calls on the UK government into examination at her local hospital. X-rays were taken and to to the family’s horror, they revealed that that online marketplaces should owe a duty of care to 14 miniature magnets were lodged inside Rebecca’s intestines. They had to be removed immediately and to regulate these sellers and platforms their customers to ensure that all toys that are available Rebecca was rushed to Royal London Hospital for emergency surgery. to purchase via their platforms are safe. before there is a fatality. Sam and her husband Steven, were warned that Rebecca could lose all or part of her intestines, depending The BTHA has been reporting unacceptable levels Natasha Crookes, Director of Public Affairs for the BTHA on the damage caused. Sam says those two hours in surgery were the worst hours of their lives. They didn’t of unsafe toys sold via third-party sellers on online said, “It is not acceptable that unsafe and non-compliant know if Rebecca was going to survive. marketplaces since September 20181 as part of its toys are simply allowed to enter the UK market, Eventually the surgeon returned with a pot containing the 14 multi-coloured magnets that they had commitment to identify and stamp out the sale of unsafe putting children at risk of serious harm. We believe the successfully removed from Rebecca’s body. Those magnets had managed to burst through and rupture toys. This report demonstrates that online marketplaces government has to step in to legislate this wild-west of three parts of Rebecca’s intestines. She was lucky to be alive. are hosting the sale of toys that do not comply with safety and we must see politicians from all sides of the safety standards. It lays bare the ongoing levels of house coming together to protect children as part of the But Rebecca is not fully out of the woods yet. Her scar tissue from unsafe and non-compliant toys that continue to be UK review of the product safety framework in 2021.” surgery could tear and the family has been warned to closely watch allowed to be sold to unsuspecting UK consumers and out for any recurring sickness. shows that the situation is not improving. The report; Sam says “I would hate for any other child to go through what Children in the UK are at risk of death • Identifies the latest levels of unsafe toys from a Rebecca suffered because of buying dangerous toys via online and serious injury from the sale of random selection purchased from third-party sellers marketplaces. The government needs to take action, the law unsafe toys via online marketplaces. on Amazon, eBay, Aliexpress and Wish.com urgently needs to change and online marketplaces need to be held • Compares those figures to the past two reports and accountable for the products they allow to be sold. Consumers often believe they are buying from a trusted international retailer (the platform), when the reality shows that there is an ongoing issue that needs “That is why our family is committed to supporting the BTHA's can be very different. In fact, the sellers are third-party addressing by legislation campaign – to bring about tougher product safety laws for vendors, often based overseas, that ship direct, or via • Lays out options for government to make regulatory marketplace sellers and platforms before a child dies and many the online marketplaces’ fulfilment channel. Consumers changes to hold the platforms and sellers to account more are critically injured. believe that somewhere in that process there will • Calls on government not to rely on voluntary be checks on the products that are sold – but unlike pledges from platforms, as they have not limited Electrical Safety First CEO, Lesley Rudd The law needs to change to ensure that online traditional retail, this process has no, or very limited, unsafe toys during the same period we have platforms have responsibility for the safety oversight from the platform where the toys are listed, or "Electrical Safety First supports the BTHA call for been testing. of products that are offered for sale on their the online marketplaces themselves. change. Electrical Safety First has conducted a marketplaces." number of studies of electronical products over recent years.2 Child Accident Prevention Trust (CAPT), CEO, Katrina Phillips In one study we tested 15 products available on Amazon Marketplace, eBay and Wish.com in a “We’ve grown increasingly worried that many toys specialist test laboratory. 14 out of 15 (that’s over sold through online marketplaces don’t comply with Becca's Story 90%) of the products purchased failed against UK UK safety standards. As consumers, we assume that Last Christmas Sam McCarthy brought a present from a third-party seller safety standards and could have caused serious online marketplaces are actively policing the safety on a well-known marketplace for her eldest son which nearly killed her electric shock or fire. of the products they sell. Unfortunately, that’s not 3-year old daughter, Rebecca. the case. What’s more, the government has limited Our investigations have also found electrical powers to force them to check if toys are safe or not. Freddie, 10 got swept up in the magnetic ball craze and was absolutely products listed on online marketplaces that had been thrilled to find three packets of them when he unwrapped his gifts on recalled for safety reasons. That’s why we really welcome the work that Christmas Day. But the festive fun quickly turned into a nightmare. BTHA is doing to raise awareness and put forward The BTHA report reflects our own findings; in their potential solutions. We need everyone who sells On the 28th January, Rebecca started to vomit and clutch her stomach study 34 electronic toys had missing safety labelling, toys to sell safe toys. Online marketplaces shouldn’t repeating a word that the family had never heard her say before: “Owie.” 14 failed temperature testing and could have caused be the exception to this rule.” Her symptoms grew increasingly worse and she was rushed straight burns or fires, 11 had easy access to coin batteries which can cause horrific injuries to children if swallowed, 10 gave access to internal parts which could give an electric shock. https://www.btha.co.uk/wp-content/uploads/2021/09/Dont-toy-with-childrens-safety-Online-Marketplaces-Report-2020.pdf 1 2 https://www.electricalsafetyfirst.org.uk/media/wvwdtpjo/online-marketplaces-the-evidence-and-impact.pdf) https://www.btha.co.uk/wp-content/uploads/2021/09/Dont-toy-with-childrens-safety-Online-Marketplaces-Report-2019.pdf
4 5 The Methodology Note 1: Warnings – in some cases warnings are missing and this has not resulted in a failed test 255 products were selected at random and purchased by a non-toy trade purchaser. Any type of toy could be report. Our laboratory has confirmed “In regards selected, and the only guide was to get a wide range of to the attached report and also the types of toy. Counterfeit lines were not actively sought question relating to specific warnings out and the brief to the purchaser asked them to search / labels, if the issue found is solely in for more “generic”, or unbranded types of toys. Third Party sellers were targeted in particular. On delivery regards to packaging / warning labels it toys were analysed based on the pack labelling. Toys has always been our policy to still pass the toy if the toy itself passes all the THE RESULTS displaying appropriate warnings, CE mark, item codes and EU addresses were determined as “compliant” and in most cases no further assessment was conducted. physical safety checks and to call out the issues regarding missing or incomplete However for this project some seemingly compliant toys The latest BTHA study, of third party sellers via online marketplaces, has found: were sent for further testing. warnings so the client can rectify prior to the goods being sold. It would be Toys without the legally required labelling were the same approach should a client only determined as “illegal” and were assessed to establish what testing would be conducted. Due to having just submit a physical toy ‘development’ one sample, tests were limited to one or two key checks sample without finalised packaging, the 88% 48% 69% and do not reflect a full compliance check. Testing was conducted by Bureau Veritas, an independent third- toy itself could pass but the report would carry appropriate comments showing the party test laboratory. Having completed our initial assessment, the results were verified by a panel made labelling hadn’t been assessed.” up of Trading Standards, laboratory representatives, However, this means that a serious age warning or non-member retailers, BTHA members and the BTHA’s identification of a hazard that is missing has not resulted of toys tested were of toys tested were of recalled toys that have Toy Safety Advisor team. in a fail report. Given that the toy was made available illegal to sell in the UK unsafe for a child to seemingly identical listings still for sale in its non-compliant state, it is clear that no play with for sale (see appendix 3). Products were categorised as “Illegal” rectification of this omission has been carried out by the or “Unsafe” in the final report. manufacturer. We would argue this is a serious issue The resultant injuries that could have been caused by the unsafe and non-compliant toys identified ranged from Illegal toys usually had technical non-compliances such that raises safety concerns for the children exposed to choking and strangulation, damage to sight or hearing, burns, chemical poisoning and electric shocks, through to as missing conformity markings and therefore did those toys as a result, and have included the toy in the injuries that would need surgical intervention to remove coin cell batteries from a child’s throat or high-powered not comply with legal information requirements – this unsafe list. magnets from a child’s colon. A full list of the 255 products can be found in Appendix 1 and the top reasons for non- includes missing CE marks (note that missing UKCA conformance are listed in Appendix 1. marks have been ignored in this project even where Note 2: Incorrect age determination – in some cases mentioned in reports, due to Brexit transition period the laboratory has decided that despite the lack of a 3+ Full results for the 255 toys tested in 2021; warning the toy should be tested to 'over three years'. requirements). The conformity markings include missing traceability addresses which can be seen as minor but This is without the laboratory having knowledge that 2021 - 255 Toys Assessment Results Independent lab Total a baby is used in the marketing of the toy. Where our do prevent effective enforcement, tracing companies and Results testing verification panel disagree with this and feel there is a effective recall. serious omission, this has been highlighted and the toy Platform Sample Illegal Unsafe Total Tested Failed % Unsafe % Non- Possible Unsafe toys included those that were (in most cases) has been classified as unsafe. size Non- Test compliant Counterfeit illegal and failed a test report plus those that stated compliant warnings were missing in the report (see note 1), Amazon 77 24 41 65 60 41 53% 84% 0 and those where the laboratory had tested the toy for Marketplace 'ages over three years' incorrectly (see note 2). To be eBay 80 23 39 62 57 39 48% 78% 0 clear toys determined to be unsafe in this report failed independent testing against current UK toy safety AliExpress 80 46 34 80 56 34 43% 100% 0 regulations. Wish 18 10 8 18 11 8 44% 100% 0 Total 255 103 122 225 184 122 48% 88% 0
6 7 IS THIS A LACK OF ACTION NEW ISSUE? The BTHA published its first report in June 2019, after years been harmonised with those of other countries in work in 2018, and followed this with a second report Europe by reason of the UK’s membership of the European No. We have shown over successive reports spanning three years and more than 500 toys that this is an ongoing in October 2020 to raise this issue with consumers, Union. However, following the UK’s withdrawal from problem that has not improved by the online marketplaces acting voluntarily, and will not be fixed without Government regulators and platforms but has been disappointed by the the European Union, and the end of the Brexit transition invervention. level of response. period, the Government now has more flexibility and opportunities to reform the UK’s product safety legislative Branded toys, and those bought directly from platforms acting as a retailer, were found to be compliant when tested While some platforms removed some of the identified framework, and has started to create the space to in 2018. However, unbranded toys bought from third-party sellers via the online marketplaces were much more products the BTHA reported, these (or identical products) investigate and act on this in 2021. This reflects the fact problematic and since 2018 the BTHA has accordingly focussed its testing on third-party seller toys. Of the selection are often relisted, by the original seller or by others. that the UK can now establish and control its framework of toys purchased from third-party sellers, i.e. all the independent sellers on an online marketplace platform, we found: Seemingly identical items to the illegal and unsafe ones for identifying and regulating economic operators, and has identified are still on sale across all platforms and little Individual Project Totals proactive work has apparently been done to prevent the opportunity to lead the way globally on legislating to take into account the role played by online marketplace Project Sample Illegal Unsafe Total Tested Failed % Unsafe % Non- Possible this relisting by the online marketplaces themselves. platforms in modern commerce, as well as the products size Non- Test compliant Counterfeit The volume of unsafe toys is so overwhelming that the they give a shop window to. It is imperative that the UK compliant platforms seem unable to remove them even on a reactive uses the powers repatriated to it following its withdrawal basis (see appendix 3 for a list of lines that have been Project No.1 150 70 45 115 34 23 30% 77% 13 from the European Union, and leads world governance on recalled on the EU Safety Gate as a result of the BTHA this issue by taking action given how important this sales Project No.2 100 25 60 85 72 53 60% 85% 3 projects but where seemingly identical items are still on channel is to consumers, and its growing prominence as sale) and so something else needs to change to ensure Project No.3 255 103 122 226 184 122 48% 88% 0 shopping habits shift more online – in order to futureproof these products do not make their way to market in the the safety of the products sold to UK consumers. Total 505 198 227 425 290 198 45% 84% 16 first place. The BTHA believes there should be more pre-vetting, by the platforms, of both third-party sellers The BTHA is calling on government to More detailed figures are available for each project on request. and their products, prior to them being placed for sale on take action now before a child dies. online platforms. The results vary over the three years of testing but overall continue to show levels of non-complianece that should be Since the BTHA first started reporting issues, 60 toys have Why is this happening? unacceptable given that this concerns the safety of toys put in the hands of children. Overall 84% of the toys sampled been recalled via the EU and UK safety alert systems but • Online marketplaces are not currently recognised as at random have been determined to be illegal as they do not meet the safety and information requirements set out in the BTHA purchaser has only received 19 notifications. economic operators in the UK regulatory framework, UK legislation, and 45% have safety issues that could make them dangerous to play with by children. The lack of notifications and contravenes the UK PAS even when products are purchased and transactions 7100 Code of practice on consumer product safety related completed via their platforms and fulfilment channels Still on sale recalls and other corrective actions, which details the • As a result, there is currently no legal requirement actions that are considered reasonable for companies to for online marketplaces to check the safety of the 59 toys have been recalled via the EU Safety Gate (RAPEX) from previous BTHA reports in 2019 and 2020. take in the event of a recall. These actions are simply not products that other sellers are listing on their sites Those recalled lines were checked on each individual platform to identify seemingly identical lines that were still on being undertaken effectively enough by the platforms. See sale. Lines that used exactly the same photographs and packaging were termed to be “seemingly identical” to the • Trading Standards Officers in the UK work hard to the Crocodile Story in Appendix 4. recalled lines. The BTHA accepts that these products could be a different model entirely or the manufacturer could of protect consumers but many third-party sellers are updated their product and made it compliant since the initial notification was issued. Despite the knowledge that illegal and unsafe toys are from overseas, outside UK enforcement boundaries being placed in the UK market via online marketplaces, • UK consumers find it difficult to distinguish between Similar looking lines were not accepted into the list. For the list of products see Appendix 3. the lack of an adequate legal framework to prevent those products offered by the online marketplaces direct As of 23.09.21 unsafe toys being sold in the UK, and that unsafe toys are and those marketed and sold by third-party vendors, not being effectively removed from sale or recalled, there or to identify who the trusted sellers are in any event 24 Amazon Marketplace recalled lines 12 can still be seen on sale 50% has been little activity at governmental level to address • UK consumers find it difficult and expensive to take 14 AliExpress recalled lines 13 can still be seen on sale 93% the issue or to make the legislative change necessary legal action against overseas sellers – if they can be 21 eBay recalled lines 16 can still be seen on sale 76% to hold these platforms to account for the products traced at all – if there is an accident they allow to be sold and make money from. The BTHA 59 toys recalled 41 seemingly identical on sale 69% acknowledges that, to some extent, the UK’s framework for regulating economic operators has for a number of As of 23.09.21 39 toys have been added to the UK Product Safety Database and recalled so far from the 225 illegal toys identified. We expect significantly more over coming weeks.
8 9 When you buy a product from a retailer in the UK If a safety issue does occur after a product has come to online marketplaces take some accountability for the Buyers can be left without the same level of consumer they have responsibilities, defined in the Toys (Safety) market, Trading Standards officers are able to monitor products sold through their platforms by third-party protection they should be entitled to and may believe Regulations 2011 (the “Regulations”), to check (at the and find unsafe items, and work with the retailer to sellers. they have when they shop on online marketplace very least) that the manufacturer has made a safe toy or remove them from sale. In cases where there is a danger platforms, and that they do have with other UK retailers. When third-party vendors sell to the consumer, they are labelled it correctly, and to act should the product later they can also initiate a recall so consumers know they are There may be no way of returning faulty, dangerous or responsible for the safety of the products. Third-party be found to have a safety issue. Where the manufacturer unsafe and can return them. But many third-party sellers counterfeit goods or of seeking compensation from the vendors can be any individual or company wishing to is not based in the UK they must add their address are based overseas, outside the jurisdiction of UK Trading seller in the case of an injury. sell products via the online marketplace platform. Some details and take on the role of an importer under the Standards, and therefore unenforceable under UK law. Regulations, which has more detailed obligations. But It is too late for effective action to be taken only after third-party vendors act responsibly and are trusted Voluntary pledge brands. However, others are not and it can be difficult for One solution that is being discussed is for platforms online marketplace platforms are not classed as being the illegal and unsafe toys find their way into children’s consumers to know the difference and make informed to voluntarily sign a pledge promising certain actions. either retailers or importers in the UK’s current economic hands and are identified. choices about the risks. In some cases the sellers' However, the BTHA would like to see government going operator model – simply the platform through which a Currently, online marketplaces that allow third-parties address and contact details are not clearly identified further, and legislating, for a number of reasons; sale is made. This is despite the customer data often to sell products through their platforms have limited on the platform website / seller profile. In this scenario being retained by the online marketplace, products insight into, or incentive to monitor, the quality and safety the online marketplaces generally do not accept that 1. Only the platforms that sign the pledge are included. marketed by the platforms' optimisation software, of those products because of the current lack of legal they have any legal obligation to check the safety of That means others that do not sign are making no and transactions often being completed through the accountability. Consequently, there are no systematic the items being sold by third-party sellers as they do commitment to trying to achieve ethical behaviour and platforms' fulfilment channels. Instead it is the individual changes being made proactively, by Government or not consider they are any of the ‘economic operators’ the law is still not in place to deal with those platforms, third-party seller on the platform that has the retailer online marketplaces, to ensure unsafe products do not who have various duties to ensure compliance under or for restricting access to market for the products sold responsibilities, but that could be the same person make it into the hands of children. Instead it is left to the the Regulations. Accordingly, online marketplaces are via those platforms. that made the product. In many cases no checks are platforms to voluntarily make changes – if they choose hosting the sale of toys that do not comply with UK being made whatsoever before the consumer receives 2. Four large platforms have been signaroties to a to do so (see appendix 6 for proactive checks made by safety standards, and making them available for sale in the product, and in the case of toys, put in the hands European Safety pledge since June 2018 – almost the online platforms). The BTHA is urging the government the UK, which in the absence of the online marketplaces of a young child (for more detail on the difference in same time we have been testing toys. The voluntary to take action to protect children from the threat of may not have a route to market in the UK at all. responsibilities for traditional verses new models of pledge has not stopped us finding unsafe toys on physical harm by taking steps to prevent the sale of supply see appendix 5) . This situation is exacerbated by the online platforms not those platforms’ sites. If the pledge worked we would unsafe toys on online platforms, and by making the policing their own sites well enough and not having legal not be finding unacceptable levels of non-compliance accountability for failing to do so, or for the unsafe and and safety concerns. counterfeit products for sale on their platform. We note, 3. The voluntary code does not commit to any pre-vetting for example, in its 2018 (page 22) annual report filed in of products or checks that other traditional retailers the US, Amazon acknowledged they may be and importers have to undergo. It has no commitment “unable to prevent sellers in our stores for platforms to police their own sites. or through other stores from selling Online marketplaces are aware of the problems. They are unlawful, counterfeit, pirated, or stolen some of the most highly sophisticated and automated goods…”3. companies in the world, but unfortunately voluntary In addition, Trading Standards Officers are responsible agreements, such as the European Safety Pledge and for enforcing product safety in the UK and work diligently in-house solutions have not solved an ongoing problem. to do that. However, they can only enforce against As the responsible toy sector, we are calling on the regulations and against companies in the UK. The government to take steps now to ensure a child is not lack of regulation governing online platforms means seriously hurt or killed by an unsafe toy (see appendix 7 Trading Standards officers cannot take action against for known incidents). the platforms; and often the third-party seller, that is Government legislative solutions regulated, is based overseas, so outside the jurisdiction of Trading Standards. In this common scenario there is no The BTHA believes that online marketplaces should one in the UK to take action against. have a duty of care to their customers to ensure that toys that are available to purchase via their platforms are https://s2.q4cdn.com/299287126/files/doc_financials/annual/2018-Annual-Report.pdf 3
10 11 legal and safe, but that the existing legal framework does Under section 75 of the Consumer Credit Act 1974, a introduce a minimum compensatory payment for fact-finding in respect of toys offered for sale on their not accurately reflect the role they play in non-compliant credit card provider will be jointly and severally liable breach irrespective of consumers’ ability to prove loss, platforms as is appropriate in light of reports of breaches and unsafe products being brought to market. The to consumers for misrepresentation and/or breach of and/or provide for third-party enforcement (e.g. by a made to the OPSS. This is particularly important given BTHA accordingly considers that legislation should be contract in respect of qualifying transactions for the specified regulatory body) which may be exercised in the current situation disincentivises platforms from introduced to provide consumers with routes of redress purchase of goods using a credit card, along with the circumstances where low value losses are suffered but conducting their own sampling and testing, as they that are clearly defined, and actionable in practice, in the supplier of the goods. It is envisaged that legislation may by a large quantity of consumers. need to be unaware of issues to remain a passive entity event that harm is suffered as a result of illegal and/or strengthen consumers’ rights by establishing a similar to have safe harbour provisions under the Euporean The BTHA considers that the above approaches unsafe toys purchased via an online marketplace. ‘like claim’ against online marketplaces such that they Ecommerce directive. Should that provision be removed represent a reasonable balance between the protection are fixed with joint and several liability (along with third- under UK legislation, now that the UK has withdrawn In the BTHA’s view, the most straightforward way to of consumers from harm suffered as a result of non- party sellers) for products purchased via their platforms. from the European Union and the transition period has improve accountability for the products purchased on compliant and/or unsafe toys, and the avoidance of Consumers would therefore be able to pursue claims come to an end, the OPSS could require more active platforms would be to strengthen consumers’ rights to unjustified interference with the platform services in contract against online marketplace platforms to monitoring by the platforms. bring private law actions against the online marketplaces offered by online marketplaces. It is noted in this regard recover damages, including for any non-pecuniary losses that toys have been purchased from, and place the that by imposing liability on the online marketplaces, Further, should legislation be introduced to impose suffered as a direct result of the illegal and/or unsafe toy burden on pursuing enforcement actions against third- the measures set out above would require them to do joint and several liability on online marketplaces for sold to them. party sellers on the online marketplaces (i.e. rather than no more than is currently expected of consumers to goods sold via their platforms (as proposed above), on consumers). Given the slow speed with which the Neither of the above options would transfer sole liability enforce their rights against third-party sellers. The online the BTHA considers that it would be appropriate for online marketplaces have been willing to act to remove for harms caused by defective or unsafe products to marketplaces are however significantly better placed the OPSS to be empowered to take representative unsafe products, and the limitations in the voluntary the online marketplaces as they may seek to join the than consumers to take such action to enforce their enforcement action against the online marketplaces remedial schemes they have established, it is considered third-party seller as a defendant in any proceedings rights given the resources available to them, and their on behalf of classes of consumers who have suffered that legislation will be required to effect meaningful and/or bring a contribution claim against the third-party pre-existing commercial arrangements with the third- harm or losses in consequence of defective and/or changes in practice. This may be achieved in at least two seller, for example under the Civil Liability (Contribution) party sellers. It is fair to shift the enforcement burden unsafe toys purchased via a platform, similar to the different ways: Act 1978. Additionally, any legislation in this area on to the online marketplaces in light of the use of their redress mechanisms provided in ‘opt-out’ collective may include provision similar to section 75(2) of the platforms being indispensable for the third-party sellers actions for infringement of competition law. Such 1. Implying through statute appropriate terms into Consumer Credit Act 1974 which provides that the to bring the defective and/or unsafe products to the UK powers for the OPSS will be essential to ensure that the contracts/terms of use entered into between supplier of goods shall indemnify the credit card provider market and the revenue they generate from those sales. online marketplaces’ liability to consumers is enforced consumers and online marketplaces for the use of their for any liability it suffers as a result of the statutory ‘like in circumstances where the losses suffered by platforms, similar to the statutory terms as to quality The BTHA also anticipates that shifting the enforcement claim’. Such provision would ensure that the online individual consumers are relatively low, and therefore and fitness for purpose implied into contracts between burden on to the online marketplaces in this way will markeplaces would have, and be able to enforce, claims uneconomical to pursue, but the volume of potential consumers and traders by the Consumer Rights Act promote better regulatory practices within the market against the third-party entities selling toys on their claims is significant. 2015; and/or by strongly incentivising the online marketplaces to platform for any sums they are required to pay as a result 2. Establishing a statutory ‘like claim’ for consumers of joint and several liability being imposed. proactively vet the third-party sellers that are permitted International concerns to supply goods via their platforms, and to more carefully The BTHA would also urge the government to against online marketplaces as they have against The effect of enhancing consumers’ rights to bring monitor the products that are offered for sale on their ensure that all trade agrements uphold UK consumer the third-party seller of toys sold via the platform private law actions against the online marketplaces for platforms (and promptly withdraw products which are protections. That includes ensuring new conditions provided by the online marketplace, similar to the toys purchased via their platforms would be: shown to be defective and/or unsafe), ideally before the are not established in trade agreements which would liability of credit card providers under section 75 of the point of sale. give safe harbour provisions for online platforms Consumer Credit Act 1974. 1. Consumers would be able to seek refunds and/or claim and ensuring the UK is able to update and uphold It is envisaged that terms to be implied into contracts damages against an identifiable and contactable party Regulatory action that is economically active in the UK; and its soverign right to establish legislation in line with between consumers and the online marketplaces, which In addition to liability for harm suffered as a result of changing routes of supply to protect consumers. would not be able to be excluded4, ought to take the 2. The responsibility, and associated risk, for pursuing the non-compliant and/or unsafe toys purchased by online form of statutory warranties that products purchased liability of third-party sellers operating outside the UK marketplace platforms, the BTHA also considers there via the platform are of satisfactory quality and are fit for and/or the EU will shift to the online marketplace on is scope for the powers of the Office for Product Safety purpose. This would provide consumers with a direct which the toys are marketed for sale. & Standards (OPSS) to be widened. This may include course of action against the online marketplace in the powers to issue legally binding, but specific obligations Other mechanisms which may be considered in to online marketplaces to engage in such monitoring or event that toys purchased are defective and/or unsafe, legislation to further strengthen consumer protections in the same way that section 19 of the Consumer Rights include imposing a contractual duty on online Act 2015 entitles consumers to reject goods, seek a marketplaces to ensure that products sold via their refund, and/or bring a claim for damages against traders. platforms meet all applicable regulatory requirements, https://ir.aboutamazon.com/static-files/0f9e36b1-7e1e-4b52-be17-145dc9d8b5ec 4
12 13 THE BENEFIT OF ABOUT REGULATORY CHANGE THE BTHA • Tackling the risk of serious physical harm (or fatality) to Action • Founded in 1944, the British Toy & Hobby Association • Members of the BTHA have access to a safety children (and their parents) posed by the prevalence of (BTHA) is the official organisation representing toy service to help them comply with the extensive The BTHA has tips to help keep consumers safe unsafe, non-compliant toys online; manufacturers. The BTHA’s members range from safety regulations that ensure toys are safe to play until the law changes - go to page 79. large international toy firms to small family-run with. That safety service is run by a number of toy • Alleviating the competitive disadvantage faced by British The problem is compounded as consumers are businesses. safety professionals with many years of experience toy firms which manufacture and sell toys in compliance often not aware who they are in fact purchasing of toy compliance between them with specialist with existing regulatory standards; • Membership of the British Toy & Hobby Association products from, or of the safety risks they are knowledge across the industry including areas such taking when buying products from third-party shows the member’s commitment to adhere to the • Returning approx. £400 million of toy sales revenue to as mechanical, physical, toxicological and internet vendors via the use of online marketplaces. Action BTHA Code of Practice under the umbrella of the Lion the economy, currently lost to counterfeit sales each connectivity. In addition, the BTHA works with is also required to educate consumers of the Mark which includes rules covering ethical and safe year; specialists from outside the BTHA on behalf of risks of buying from third-party sellers on online manufacture of toys, toy safety, a ban on counterfeit members, particularly with testing laboritories when • Returning significantly more revenue each year by marketplaces such as Amazon, Aliexpress, eBay, goods, an assurance to market responsibly, a needing to verify test results. removing illegal and unsafe toys from the market (our and Wish.com among the many other online commitment to improving sustainability and a desire estimate is that this could be worth up to £850 million to marketplaces that provide a platform for the sale of to promote the value of all play through support of the • The BTHA also administers the Toy Trust - the the UK economy if the illegal traders are removed); third-party products. Make Time 2 Play campaign. industry’s charity – and runs the Toy Fair, the largest dedicated toy trade event in the UK. • Removing non-compliant and unsustainable toy waste We have tips for consumers to use when they are from the supply chain and the waste stream; buying from a marketplace and the BTHA is calling • Enhancing Britain’s reputation for high safety standards; on politicians, media outlets and consumers to come together to raise awareness of the concern • Highlighting the UK government as a world leader, we have collectively for the safety of children in the taking action on an issue which is a problem across the globe; UK. We do not believe parents in the UK should be responsible for understanding complex toy safety ABOUT THE • Using new sovereign powers by demonstrating and exercising the regulatory freedom and control available regulation. They should be able to buy from any entity in the UK, safe in the knowledge that their TOY INDUSTRY children can enjoy safe play. to the UK, in a way which increases the protections FIGURES FROM NPD available to its citizens, now that it has left the European Union; • The UK is currently the largest toy market in Europe, and fourth largest toy market worldwide, • Cutting down on waste - reputable toy companies make toys that are designed to last and to bring years of play behind the United States, China and Japan. • There were more than 32,000 new toys launched 80% 37% and development to a child – they are far from single use. At a time when we are all aware of environmental by reputable companies in 2019, that’s 27% of the concerns the sale of cheap toys that break easily should toys sold in the UK, totaling £863 million of total be removed from the UK marketplace; and sales. The legitimate toy industry Online sales of toys are • Ensuring companies that trade in the UK pay the • Direct operations of the toy and hobby sector is worth £3.2 billion, with increasing year on year and proportionate level of corporation tax in order to make make a direct contribution to UK GDP of £1.4 around 80% of the toy accounted for 37% of total a fundamental contribution to the fabric of UK society. billion and an indirect contribution of £2.7 billion. industry falling into the toy sales last year. Without intervention UK companies will be unable to small to medium sized compete and will not exist into the future and the only category. option for consumers will be unregulated, unsafe toys.
14 15 APPENDIX 1: LIST OF TOYS No Toy Title as seen Non-Compliance & on Amazon Verification Panel Comments Test Results Toy Photo as seen on Amazon Classification BY PLATFORM 4 Toys for 3 year old girls boys buidling blocks Baby Flower No EU address Missing Conformity Markings BV Test Report: (5421)040-0034A Failed test report EN71-1 12/2/21 The following results came from products purchased between 16/12/2020 and 15/03/2021 and Garden Building Toy EN71-1: FAIL tested between late February 2021 and early May 2021. Floral Arrangement Playset 98 pcs 4. General requirements Unsafe 4.9 Protruding parts / AMAZON MARKETPLACE RESULTS puncture hazard EN71-1: noted labelling No Toy Title as seen Non-Compliance & Test Results Toy Photo as seen Classification to be modified - UK address / UKCA mark on Amazon Verification Panel Comments on Amazon 5 HERSITY Kids Pet Compliant BV Test Report: 1 ATOPDREAM Toys No address BV test report: Care Playset Dog Failed test report EN71-1 (5421)040-0029A for 2 3 4 5 6 year old No warning (5421)040-0007A grooming toy with 15/2/21 boys, Dinosaur Toys 24/2/21 Carry Case Costume No small parts within the toy EN71-1: FAIL Gifts for 2-6 Year Old Dress up Role play Missing Conformity Markings EN71-1: FAIL 5.1 General Boys Girls Toy Cars set gifts for children 6 packaging flexible requirements - Unsafe Boys Toys Age 2-8 Failed test report EN71-1 Toy Dinosaurs Toys plastics Unsafe generated small parts for Boys Kid EN71-1: noted missing EN71-1: noted missing labelling labelling BV test report: no UK address or UKCA (5421)040-0007A mark EN71-3: PASS 6 Musical Caterpillar No EU address BV Test Report: 2 CubicFun Cars track No EU address Not tested Toy, LIGHTDESIRE Missing Conformity Markings (5421)040-0038A Kids Toys for 4 year (Newest)Rattle 15/2/21 Missing Conformity Markings Warnings - missing washing old boy girls, car with ring Bell for instructions EN71-1: PASS adventure Toys for 3 Preschool Baby EN71-1: noted missing Illegal year old intelligence Illegal labelling Educational autism toys for 5 6 year old EU address, UKCA girls mark, washing/cleaning instructions, type, batch number 3 wgde toy cute No labelling except for CE mark BV Test Report: 7 Baby Bath Toys- No address BV Test Report: Octopus Baby toys 0 Missing Conformity Markings (5421)040-0013A Wind up Turtle (5421)040-0042A No label - CE mark on toy 3 6 9 12 18 months, 15/2/21 Bathtub Toys,Toy for Warnings - missing washing Missing Conformity Markings 12/2/21 double-sided flip soft babies 6-12 months instructions EN71-1: PASS EN71-1: FAIL reversible Octopus Floating Swimming Failed test report EN71-1 Plus stuffed Animals EN71-1: noted missing 4.10.2 Driving Turtles for Boys doll, Creative toys labelling mechanisms Girls,Baby Shower gifts for 0-3 address, UKCA mark, Bathtime Fun Pool 5. General requirements Illegal Unsafe washing/cleaning Toys for Toddlers,Gift - small parts generated instructions for 1 2 3 4 Year Old 6. Packaging flexible Boys Girls plastics BV Test Report: EN71-1: noted missing (5421)040-0013B labelling 15/2/21 address, batch/model AZO Dyes: PASS number, UKCA mark
16 17 No Toy Title as seen Non-Compliance & Test Results Toy Photo as seen Classification No Toy Title as seen Non-Compliance & Test Results Toy Photo as seen Classification on Amazon Verification Panel Comments on Amazon on Amazon Verification Panel Comments on Amazon 8 WEARXI Baby Bath No address - although possible scan BV Test Report: 13 Icnow 85 Pack No address BV Test Report: Toys Fun Bathtub code could show this. (5421)040-0039A Balance Math Game Toy is labelled 18m + but also has (5421)040-0031A Shooting Game CE mark is covered by sticker 12/2/21 Early Education Toy 0-3 sign and warning. 12/2/21 for Kids, Toddler Frog Balance Scale 3+ marked but back photos show EN71-1: FAIL Small parts within the toy EN71-1: FAIL Basketball Hoop Mathematical Digital baby seemingly under 3yrs 5. General requirements 6. packaging plastic Unsafe Gift Set, Bath Toys Addition Teaching for Boys and Girls - small parts generated Tool for Kids Family Missing Conformity Markings sheeting 1-4 Years Old Boys Missing Conformity Markings 5.4 cords and chains Table Gama to Learn Warnings - Inaccurate 3+ and small EN71-1: noted missing Unsafe included 3 Mini Warnings - contradictory 3+ 5.4.4 fixed loops, Counting Numbers parts labelling Basketball warnings and baby marketing tangled loops and and Basic Math address, UKCA mark Failed test report EN71-1 Failed test report EN71-1 nooses 14 E-More Erasable No address BV Test Report: EN71-1: noted missing Doodle Book, CE mark is too small (5421)040-0036A labelling Portable Kids’ 11/2/21 address, UKCA mark, No age, No 0-3 sign, No warning sign Writing Drawing CE hidden Small parts within the toy but no EN71-1: PASS Board Toy Double- Sided Sketchpad hazards / warnings labelling in EN71-1: noted missing 9 FGWAF Gift Cute No address Not tested Painting Book with place. (coloured pens with lids) labelling Astronaut Soft Plush Toy with Sound for 12 Colored Erasable address, CE mark too Missing Conformity Markings Pens for Kids small, no UKCA mark, Kids and Game Fans Illegal Missing Conformity Markings Toddlers Boys Girls Illegal Crewmate - Best specific warnings and Warnings - Inaccurate 3+ and small Gifts (10cm) Age 2 3 4 5 6 7 8 hazards parts Year Old BV Test Report: 10 FGWAF Gift Children No address BV Test Report: (5421)040-0036B LED Rechargeable (5421)041-0011A Music Phone - Best 11/2/21 Missing Conformity Markings 19/2/21 Educational Toy BS7272-1: PASS Warnings - missing EN62115 EN62115: FAIL BS7272-2: PASS warnings 9.4 bridged insulation Failed test report EN762115 9.9 temperatures rises 15 Baztoy Flying Ball, Labelling in place but BV Test Report: Unsafe Kids Toys Remote 0-8 warning sign instead of 0-3 (5421)040-0027A 9.9 working Control Helicopter (illegal use of 0-3 sign) 19/2/21 requirements Mini Drone Magic 13 strength of EN62115: FAIL Infrared Induction RC enclosures Flying Toy Christmas Warnings - Inaccurate 3+ logo 5.15 Tension test at 14.7 accessibility of Birthday Party Failed test report EN62115 70N batteries Gifts for Boys Girls 9.4 bridged insulation 7. missing labelling Children Teenager 9.9 temperature rise Indoor Outdoor 11 TEMI Carrier-Truck No address Not tested 9.9 working Unsafe Garden Game Transport-Car Play- requirements Vehicles Toys - 5 in 15.1 absence of contact Missing Conformity Markings 1 Friction Power Set with moving parts w/ Real Siren Sound Illegal 14.6 accessbility of & Bright Flashing button cells and type Light, Push and Go R1 batteries (remote Play Vehicles Toys control) w/ Mini Cartoon Bus/ Taxi/Airplane 5.15 drop test (remote control) 12 WELLXUNK Wooden No address BV Test report: Blocks,12 Pieces No CE mark (5421)040-0015A Wooden Magic 24/2/21 Warning - incorrect format Cube Face Emoji,50 no small parts within the toy EN71-1: PASS Cards Wooden Magic Cube Face EN71-3: PASS Illegal Pattern,Thinking Missing Conformity Markings EN71-1: noted missing Training Children labelling Face-Changing address, CE/UKCA Puzzle Building mark Cubes Interactive Toy
18 19 No Toy Title as seen Non-Compliance & Test Results Toy Photo as seen Classification No Toy Title as seen Non-Compliance & Test Results Toy Photo as seen Classification on Amazon Verification Panel Comments on Amazon on Amazon Verification Panel Comments on Amazon 16 Dancing Captain Everything in place except battery BV Test Report: 21 Push pop pop Toy arrived in silver bag with barcode BV Test Report: America Toy Robot information. (5421)062-0023A Bubble Sensory label. (5421)046-0022A Hand Model Dance 11/3/21 Fidget Toy, Autism 18/2/21 Hero Doll with Music Special Needs Stress No labelling Warnings - missing EN62115 EN62115: FAIL EN71-1: FAIL Light Reliever Toy Silicone warnings 5.15 drop test no small parts within the toy 6. packaging flexible Squeeze Toys with Failed test report EN62115 9.4 presence of a short 2 Fidget Beans, plastics Unsafe circuit Anti-Anxiety Tools EN71-1: noted missing Missing Conformity Markings Unsafe 9.9 tempertature rises for Kids and Adults labelling (green-2) Failed test report EN71-1 15.1 absence of contact All labelling missing with moving parts EN62115: missing BV Test Report: labelling various (5421)046-0022B 17 The New York Doll No EU address BV Test Report: 18/2/21 Collection 11 inch/28 0-3 sign too small (5421)046-0009A Phthalates: PASS cm Soft Body Boy 18/2/21 22 TALEEKEU Soft Toy arrived vacuum packed in clear BV Test report: Baby Doll in Gift Missing Conformity Markings Phthalates: PASS Plush Llama Alpaca bag with label. No information on the (5421)069-0006A Box - Doll Dummy Illegal Hug Pillow Cushion label. 16/3/21 Included - Toy Fluffy Doll Kid Sofa Dolls for Boys and No care label on toy. Cover detaches Azo Dyes: PASS Home Decor Toy Toddlers, B168 fully. Fluff detaches. Illegal (Pink alpaca) 18 Pack of 2 Forest No address Not tested Missing Conformity Markings Animals Panda batteries but no instructions Torch Projectors, Likely to fail EN62115 labelling Educational Toy, 23 RUIZHUO Wacky Toy arrived in plastic bag with bar Not tested requirements Bedtime Story Tracks Fidget Toys code inside Amazon box. Toy, Perfect Party Illegal Multicolor Snake Favor Stocking Missing Conformity Markings Chain Puzzles Snap No labelling. Fillers, Great Gift for Warnings - missing EN62115 and Click Finger Children Kids Boys No small parts within the toy Illegal warnings Sensory Simple Girls, 2 Themes - Dimple Fidget Toy Clear 48 images For Stress Relief Missing Conformity Markings 19 Baby Xylophone No EU address BV Test Report: Puzzle Educational Instrument w/ Play (5421)046-0024A Party Toys (3 Pcs) No 0-3 sign Blocks – Pull ‘n Play 17/2/21 24 RUIZHUO Wacky Labelling in place but BV Test Report: String holding beater is 38cm Xylophone Baby Tracks Fidget Toys (5421)046-0020A EN71-1: FAIL Toy – Supports Multicolor Snake 0-3 sign but too small 5. General requirements 23/2/21 Imaginative Play, Missing Conformity Markings Chain Puzzles Snap Great Toddler - small parts generated No warning signs EN62115: PASS Warnings - missing acoustics and Click Finger Musical Instruments warning 5.4 Cords and chains Sensory Simple EN62115: noted Unsafe No small parts Gift for Kids 3 Year 6. Packaging - plastic Dimple Fidget Toy missing labelling Failed test report EN71-1 Illegal and Older pkg thickness For Stress Relief Likely to fail EN62115 labelling retaining instructions, EN71-1: noted missing Puzzle Educational requirements battery information. labelling Party Toys (3 Pcs) UK address missing, Warnings - EN62115 warnings UKCA mark, Acoustics missing warning 20 QUACOWW 9 Toy arrived in clear plastic bag with BV Test Report: Pieces 24 Links barcode. (5421)046-0023A Wacky Tracks No labelling 18/2/21 Fidget Toy Wacky no small parts within the toy EN71-1: FAIL Tracks Snap and Click Fidget Toys for 6. packaging flexible Unsafe Stress Relief Party Missing Conformity Markings plastics Favors Failed test report EN71-1 EN71-1: noted missing labelling all labelling missing
20 21 No Toy Title as seen Non-Compliance & Test Results Toy Photo as seen Classification No Toy Title as seen Non-Compliance & Test Results Toy Photo as seen Classification on Amazon Verification Panel Comments on Amazon on Amazon Verification Panel Comments on Amazon 25 Drill Design Puzzle No address Not tested 30 Hot.Sale/JYC Color No address BV Test report: Creative Toys, Scoolr Random Boy Girl Small parts warning too small (5421)062-0020A Electric Drill Toy Set Battery information in place Learning Study 8/3/21 Educational Toys Camera Children Missing Conformity Markings EN71-1: FAIL Building Blocks Take Photo Warnings - Inaccurate 3+ and small 6 packaging flexible Pegboard Toy Missing Conformity Markings Illegal Educational Toy parts plastic Construction Toy Failed test report EN71-1 EN71-1: noted missing Unsafe Set Take Apart Toys labelling 3D Building Block UK address, UKCA Creative Puzzle DIY symbol, Warning to Set be modified, warning for age restriction 26 Mengonee Wolf No address BV test and small parts - Wolverine 3 Long report:(5421)057- unreadable Claws Plastic Action 0034A Missing Conformity Markings Figure Toys Cosplay 4/3/21 31 HUYURI Electric No address BV Test report: Props Halloween Failed test report EN71-1 Guitar Toy Musical No battery information (5421)057-0029A EN71-1: FAIL Play for Kid Boy Girl No screw in battery compartment 4/3/21 6. packaging flexible Unsafe Toddler Learning hole EN71-1: FAIL plastics Electron Toy Long strap 5 toys intended for EN71-1: noted missing Likely to fail EN62115 labelling children under 36 labelling requirements months address, UKCA mark 5.1 general Missing Conformity Markings requirements - small Warnings - Inaccurate 3+ and small parts generated Unsafe 27 JUMBO PRIMARY No EU address BV test report: parts 5.14 straps intended STRINGING BEAD No 0-3 sign (5421)046-0015A Failed test report EN71-1 for around the neck SET by SHAWE with 17/2/21 6 packaging flexible 30 Lacing Beads for plastic Missing Conformity Markings EN71-1: PASS Toddlers and Babie- EN71-1: noted missing EN71-1: noted labelling Illegal Montessori Toys for labelling Fine Motor Skills to be modified - UK UK address, UKCA Autism OT- A Great address, UKCA mark mark Toy for Both Boys & Girls Ages 3+ 32 Gifton - MYSTERY Webpage only - no address Not tested 28 Hifot 16 Pairs 0-3 sign too small Not tested TOYS BOX - Gift Other labelling correct on box. Clip-on Earrings for Boys Girls Kids Within the box were 5 small toys. No Pierced Design - Fidgets, Sensory Some labelled but squidgy toy no Missing Conformity Markings Earrings Dress up Stress Balls, Puzzles, labelling. Small button cell car - not Princess Jewelry Warnings - Inaccurate 3+ logo Table Games, Brain labelled. Illegal Illegal Accessories for Girls Teasers, Magnetic Small parts within the toy. Kids Toddler Building Blocks, Torches, Cars and Missing Conformity Markings More (1 Box of 5 Toys) 29 Color Cute Cartoon Magnetic earrings BV Test report: 33 Noxus Magnetic Toy arrived in plain tin. No labelling. BV Test report: Magnetic Clip On Strong magnetic pull (5421)088-0021 pen Interesting Very strong magnets. (5421)057-0028A Stud Earrings for 1/4/21 No information/No labelling combination toy | 4/3/21 Teen Girls Women Small parts within the toy but no EN71-1: FAIL Wonderful Magnetic Missing Conformity Markings EN71-1: FAIL Party Wear Gift Set, hazards / warnings labelling in place 4 general requirements Ballpoint Pen | Fidget Warnings - Inaccurate 3+ and small 4 general requirements Pack of 12 Pairs Toy Gift | Stylus pen | parts 4.22 small balls to be 4.23 magnetic flux (107 Unsafe creative boy birthday Failed test report EN71-1 modified Missing Conformity Markings kG2mm2) Unsafe present (Multicolour) 4.23 Magnets - small Warnings - Inaccurate 3+ and small partsand magnetic flux parts EN71-1: noted missing (441.14 kG2mm2) Failed test report EN71-1 labelling EN71-1: missing address, CE/UKCA labelling mark, specific warnings 7 all missing and hazards
22 23 No Toy Title as seen Non-Compliance & Test Results Toy Photo as seen Classification No Toy Title as seen Non-Compliance & Test Results Toy Photo as seen Classification on Amazon Verification Panel Comments on Amazon on Amazon Verification Panel Comments on Amazon 34 TOYANDONA Toy arrived in clear plastic bag with BV Test report: 38 6 packs Light up No battery information except for Not tested Magnetic Bead Maze barcode label. (5421)057-0023A Boat Bath Toy WEEE and RoHs sign. Puzzle Cute Monkey No information 4/3/21 Set, Flashing Color Button cell batteries but not Shape Magnet No small parts EN71-1: FAIL Changing Light in accessible. Wooden Maze Game 4 general requirements Water, Floating No 0-3 sign Toy Educational Toy Missing Conformity Markings - small parts generated Rubber Bathtub Toys No choking sign Illegal for Kids Boys Girls Failed test report EN71-1 4.22 small balls to be for Baby Toddler 3+ age grade - no small parts Toddlers modified Unsafe Infant Tub Play, Boy 4.23 magnets (113.61 Girl Kid Growing Pal Warnings - missing EN62115 kG2mm2) in Shower Bathroom warnings 6 packaging flexible or swimming pool plastics 39 KingbeefLIU Children Toy arrived in clear plastic box with BV test report: EN71-1: noted missing Science Bar Ring barcode labelling. (5421)062-0026A labelling Horseshoe Compass Instruction leaflet inside in chinese. 9/3/21 all labelling missing Magnet Car Kit No information on packaging. No EN71-1: FAIL 35 Hysagtek 4 PCS The lids are small parts BV test report: Experiment Tools A magnet warnings. Toy was broken 4 general requirements Ballpoint Pen Novelty No 0-3 sign (5421)057-0027A Fun Educational Toy inside. Small parts within toy. 4.8 points and wires - Cute Pizza & Bread No warning sign 4/3/21 Small parts within the toy but no sharp points Stick Magnet Ball Small parts within the toy but no EN71-1: FAIL hazards / warnings labelling in place 4.9 protuding parts - Unsafe Pens School Office hazards / warnings labelling in place 4 general requirements puncture hazard Kids Toy Gift - small parts - magnet Missing Conformity Markings 4.23 magnets to be Missing Conformity Markings detached Warnings - Inaccurate 3+ and small modified Warnings - Inaccurate 3+ and small 4.23 magnets (137 Unsafe parts EN71-1: noted missing parts kG2mm2) Failed test report EN71-1 labelling Failed test report EN71-1 6 packaging flexible address, CE/UKCA plastics mark, specific hazards; EN71-1: noted missing magnetic information labelling 40 HUALEDI Unicorn Toy arrived in clear plastic bag with BV test report: EU/UK address, UKCA Toys Gifts barcode. (5421)057-0024A mark, specific warnings Set,Unicorn Torch No labelling 9/3/21 36 3 In 1 Wooden EU address in place. BV Test report: and Projector,[5 Small parts within the toy EN71-1: FAIL Magnetic Fishing No 0-3 sign (5421)057-0020A Pack] Unicorn Girls No battery information 6 packaging flexible Board Games No CE mark 3/3/21 Accessories Toys Likely to fail EN62115 labelling plastics Montessori Toys Choking warning incorrect format. EN71-1: FAIL ,Girls gifts for age requirements EN71-1: noted missing for Kids Fine Motor Small parts within the toy 4 general requirements 2-3-4-5,Science toy labelling Unsafe Skills Toys Toddler - small parts magnet for 1 2 3 4 5 6 year Missing Conformity Markings address, CE/UKCA Learning Educational Missing Conformity Markings detaches old Warnings - Inaccurate 3+ and small symbol, warnings Toys 3 4 5 Years Old Warnings - Inaccurate 3+ and small 4.22 small balls to be Unsafe parts, missing EN62115 warnings with Magnet Poles parts modified Failed test report EN71-1 BV test report: and Clip (8 Magnetic Failed test report EN71-1 4.23 magnets (70.58 (5421)057-0024B Fish and 28 Bead) kG2mm2) 9/3/21 EN71-1: noted missing Phthalates: PASS labelling CE/UKCA mark, 41 welltop Dinosaur No address Not tested warnings Cars Toys, Dinosaur 37 LEEHUR Creative 0-6 sign instead of 0-3 and too BV test report: Toy Blaster for 2-9 Missing Conformity Markings Magnetic Putty small parts within the toy (5421)057-0031A Year Old Girls Boys with Funny Monster 2nd sample: same packaging but 4/3/21 Christmas Birthday Illegal Eyes for Children UKCA mark added - too small. EN71-1: FAIL Gifts Blue Kids Intelligent Strong magnet 4 general requirements Exploitation Gift 4.23 magnets (1307.11 Missing Conformity Markings kG2mm2) Warnings - Inaccurate 3+ and small EN71-1: noted missing parts labelling Unsafe Failed test report EN71-1 UK address, UKCA mark, small hazards warnings BV Test report: (5421)063-0016A 17/3/21 EN71-3: PASS
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