TIE raises concerns about the proposed amendments to the Critical Raw Materials Act (CRMA). Under the European Commission’s proposal, all motorised toys, regardless of size or permanent magnet content, would be required to carry a physical label detailing the material composition of their magnets and a QR code for other information.
The proposal does not include clear definitions, thresholds and lacks feasibility, proportionality and effective implementation. It will impose unnecessary operational costs for minimal recovery value, as the magnets used in most toys contain negligible amounts of critical raw materials. Translation of the label in national languages will also undermine the Single Market. The label will not fit, so the same toy cannot be sold in other EU Member States.
TIE urges policymakers to:
- Address the right products – The CRMA should focus on products where material recovery is feasible and impactful.
- Allow digital labelling – Labelling requirements designed for larger appliances are a challenge for small products. Digitalisation will support implementation and is in line with the Commission’s simplification agenda.
- Align implementation timelines with relevant EU laws – Manufacturers need sufficient time to adapt to the CRMA requirements and must have equal opportunities to exploit the potential of the Digital Product Passport (DPP). For toys, this means aligning the date of application with the introduction of the DPP for toys under the Toy Safety Regulation. Otherwise, toy companies need to work with several digital labelling systems, whereas the introduction of the DPP will already be a big challenge for SMEs.
To read the TIE Position Paper, see here
