| Pas de panique
comme je l'ai écris sur un forum de nos copains anglais :
The text contain statement : ( in the ECHA document http://echa.europa.eu/documents/10162/a55e40f4-9515-475a-a6de-25bd991c3f84 )
Table 2-B Article types which are exempted as covered by European Union legislation specifically regulating lead content
.....
3. Toys Directive 2009/48/EC on the safety of toys.
B. : Then I read the directive
Now in the Directive, we read ( http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2009:170:0001:0037:en:PDF )
List of products that, in particular, are not considered as toys within the meaning of this Directive (as referred to in Article 2(1))
....
2. Products for collectors, provided that the product or its packaging bears a visible and legible indication that it is intended for collectors of 14 years of age and above. Examples of this category are: (a) detailed and faithful scale models; (b) kits for the assembly of detailed scale models; (c) folk dolls and decorative dolls and other similar articles; (d) historical replicas of toys; and (e) reproductions of real fire arms.
So I think that from now, all producers, importers, sellers must add on the packaging " intended for collectors of 14 years of age and above "
But, I guess, it must be written in the country official language .. So importers prepare some stickers ( exemple; in Belgium it must be in french, netherland, german . those are the 3 officials in Belgium )
http://www.leforumlafigurine.com/t14585-interdiction-du-plomb-dans-les-figurines#301414
Indeed, and in particular with toys, requiring a CE safety mark (meaning a CE log must be affixed on toys, to state their safety Under the responsibility of the manufacturer, 1) we should probably avoid these flats to be named "TOYS", by a statement of the device on the package2) That statement should indeed exclude the use of the device as a TOY explicitely as suggested3) Such statements must be in the language of the country of sales, everywhere sold, as part of the packaging, and of the unit pack (if it can be sold as a single unit). If sold in a neutral box as second hand, be careful to keep such statement affixed with a self adhesive sticker too !!! Therefore that sentence "intended for collectors of 14 years of age and above " might have to say also, "This is not a toy, but ....." to exclude such intended use !Also the sentence must be affixed on the packaging of the unit(s) on sales, in the languages of the countries where sold. This means if selling in Germany, with German, in Italy, with Italian, in Swtzerland, with 4 languages, in Belgium also in three(FR, NL, DE), etc.... A group should coordinate the multilingual translation of the final sentence (like "This is not a toy, intended or collectors of 14 years age and above, contains lead" in all languages in Europe and byond Europe (Russian see Vladimir Nuhzdine), ... and freeeze these translations are totally equivalent (no addition, no shortcut), for use by all manufacturers and distributors on the same way. My recommendation is to define globally, or by manufacturer where they are selling their flats, then define the first three largest sales for fixing three languages mostly used, perhaps four ... Then affix the most used on the packages of the manufacturer (German editors may choose German, English, ...) French ons, like (deleted) perhaps French (only? or French/German/English), and include this in their base pakaging lay-out. But then when selling to other countries (like EBay, or exhibitions elsewhere, ), they will have 1) to post explicitey these sentences visibly on the selling boot2) when selling a flat to a user not of the language present, Add a small sticker in the missing language (example, when coming at Ransart Belgium, add a Dutch sticker on the pack sold, when shipping to Italy, add a Italian sticker on the pack (in addition to the statement in the EBay ietm to warn the user; when selling in Spain, add a Spanish sticker before moving there on one pack exposed of each item, or add at time of sales !!) Indeed, information must be available in the language of the USER to be understood, as a saety notification !! Working on these proposals, perhaps with advise of the ECA on the sentence, BEFORE Kulmbach would be an excellent initative to offer concretely to care about such risk !! Although in Turkey now till Kulmbach, if I can be of ay support, don't hesitate... Please establish a link with the key producers or most representative editors, at least in each country like FR, GE, ITaly, Spain, UK, .. to have at least on key eprson t participate to these discussions and perhaps be present at Kulmbach in August to finalize with the representative invited ..... This is a good exercise, that IFFS could lead with Germany, largest manufacturing country and organizer of Kulmbach in the coming two months, to bring an effective proposal to this safety concern. We may end up with some recommendation guideleline to the editors, producers, distributors of flats on the European market via National association and this Society to be in line with these actions !!
With best regardsHannibal/Michel |
