Toy Industries of Europe (TIE) supports the European Commission’s aim to extend the life of electrical products and promote circularity by ensuring batteries can be replaced. However, a one-size-fits-all approach will have unintended consequences. TIE’s members are reputable toy manufacturers who are always looking to improve the sustainability of their processes and products, whilst making sure that toys remain safe and fun for children to play with. There is a wide variety of toys with portable batteries (from talking teddy bears, toy tablets, and remote-control cars). A one-size-fit-all approach in this case may be counterproductive both from a sustainability point of view, as well as the user experience.
We have a number of recommendations regarding Article 11 of the Batteries Regulation proposal to ensure consumer safety and functionality of products:
• No blank ban on products with non-replaceable batteries, specifically product that can still fulfil their basic function if the electrical current is off (talking teddy bears, singing birthday cards, key chains with LED).
• Battery replacement should be performed either by qualified independent operators or end-users with tools which are commercially available.
• An adequate transition period of at least 24 months for the application of obligations on replaceability.
Read the full position paper here: TIE Position Paper on Batteries Regulation