TIE – Toy Industries of Europe – believes clear guidelines on the REACH restrictions are important; they provide clarity and business certainty to manufacturers on meeting their obligations under the regulation. It is key that such guidelines accurately reflect the legal requirements of entry 27 of Annex XVII.
We therefore welcome the initiative to develop guidelines on the restriction of nickel and its compounds. However, we are highly concerned that parts of this document, namely Annex I, goes beyond the scope of the restriction (and contradicts the text of the Draft Guidelines) by applying the restriction toy products that should be out of scope.
With this in mind, TIE calls for the removal of the toy examples that go beyond the scope of the Restriction included in Table 2 from Annex I of the Guidelines