Fielding: Toys, Electronics Manufacturers in UK, Europe Face Evolving Regulations

Electronics manufacturers operating in the United Kingdom and European Union are facing a range of new regulations as policy makers try to keep up with changing technology. Meanwhile, companies that manufacture toys in Europe face an equally evolving regulatory framework, according to Shook Senior Counsel/Solicitor Leo Fielding.

Fielding wrote two articles for Sedgwick’s Recall Index 2023 Edition 3, titled “Electronics Products Face New Rules” and “New EU Regulations Make Navigating the Toys’ Industry Anything But Child’s Play.”

In the electronics article, Fielding said manufacturers now must contend with regulations that seek to strengthen Europe’s semiconductor ecosystem, ensure batteries are more environmentally friendly and safe, standardize product chargers, and ensure the security of internet-connected consumer products. 

Discussing the latter, Fielding said that the U.K.’s consumer connectible product security regime will take effect April 29, 2024, subject to Parliament’s approval of draft secondary legislation. The law will require manufacturers of consumer connectible products placed on the U.K. market to comply with certain minimum security requirements. Additionally, E.U. legislators have been active on cybersecurity.

“British companies exporting relevant goods and software to the EU market should be aware that they could face the burden of overlapping cybersecurity obligations under both the EU’s [Cyber Resilience Act] and the UK’s Product Security and Telecommunications Infrastructure Act 2022,” he said.

In the toys article, Fielding advises companies that rules proposed by E.U. lawmakers are expected to have a major impact. He discusses the European Commission’s Toy Safety Regulation, which replaces the current Toy Safety Directive. One of the changes includes increased protection from potentially harmful chemicals. He said the current directive already bans substances that are carcinogenic, mutagenic or toxic for reproduction.

“The proposed regulation expands this ban to include other substances such as endocrine disruptors or substances that affect the immune, neurological, or respiratory systems that may be particularly harmful to children,” he said. “To address stakeholders’ concerns, the new rule allows for derogations to this ban when the use of a substance in toys is considered to be safe by the relevant scientific committee of the European Chemicals Agency and there are no alternatives available to manufacturers.”

Read the electronics article and toys article in Sedgwick >>