Toy Industries of Europe broadly welcomes the Delegated Act to the Radio Equipment Directive. It sets clear requirements on cybersecurity for connected toys and should make it easier to remove sub-standard products when they are found. We can only welcome this improvement for reputable businesses.
The toy sector is always looking for new ways to enhance play. Connectivity brings new benefits for children’s development and adds a bit of extra magic to the play experience. No matter what new capabilities a ‘smart’ toy might have, in one respect all toys made by reputable manufacturers are the same – they are designed with children’s safety in mind.
We feel the Delegated Act could have been even more ambitious by making sure it applies to all radio equipment products (regardless if they are capable to connect to the internet) children under 14 are likely to use. This shortcoming will for instance create a situation where toy cameras will need to meet the new requirements on data protection and privacy but non-toy cameras that are marketed to children do not need to take them into account. These cameras can share pictures through apps but do not require internet connection. From a consumer protection point of view, this makes no sense, nor from a level playing field for the industry.
The new Delegated Act will need to be applied with by mid-2024 which is a very tight deadline for manufacturers taking into account possible delays in the standardisation and citation processes.