PROPOSAL FOR A COUNCIL DIRECTIVE ON THE USE OF PHTHALATES IN TOYS AND CHILDCARE ARTICLES

The European Commission has proposed that the use of phthalates in toys and childcare articles be addressed by a Council Directive (13308/99) amending for the 22nd time the Marketing and Use of Dangerous Substances and Preparations Directive (76/769/EEC) and by amending the Toys Safety Directive (88/378/EEC).

The Proposal

2. The proposal, a copy of which is at Annex A has two elements to it:

1. a ban on the use of six phthalates in toys and childcare articles for children under 36 months and which are intended to be mouthed. Such items include teethers, teething rings, dummies, bottle teats, and the parts of toys (e.g. toy musical instruments) which are mouth activated; and,
2. for all other toys and childcare articles for children under 36 months and which could be put in the mouth, a labelling requirement is proposed so that there is a clear indication that the item should not be kept in the mouth.

3. The first element of the proposal will make permanent the temporary ban introduced under the Commission’s Decision of 8 December which came into effect on 18 December. The Decision banned the use of six phthalates in teethers, teething rings, dummies and toys intended to be mouthed by children under 36 months and required that no such products containing phthalates be introduced to the market from 18 December. It is likely that the ban will stay in place until the proposed Directive is adopted and implemented.

4. The Commission’s Decision has been implemented in the UK through the voluntary commitment given by industry that all products covered by the Decision would be removed from shelves from 1 December 1999. The DTI and local authority trading standards departments are monitoring the voluntary agreement to ensure that it is observed.

Scientific advice regarding the safety of phthalates

5. There are a number of different phthalate compounds and their toxicological profile varies. DINP, which we understand is the most commonly used phthalate in toys and childcare articles, has been shown to produce liver toxicity in rodents at very high levels of exposure, that may lead to liver tumours following lifetime exposure. The mechanism of liver toxicity and eventual formation of tumours is believed to involve peroxisome proliferation. There is a large amount of data to indicate that humans are much less sensitive to this mechanism of toxicity. However, another phthalate, DEHP, has also been shown to have adverse effects on the reproductive system of rats at relatively low exposure levels; added to this the mechanism by which these effects come about are unknown. For these reasons the Department of Health has advised that DEHP could give cause for concern if used in toys and childcare articles which could be kept in the mouth for an extended period by young children. It is our understanding that DEHP is not used in the UK in such products. However, as part of the consultation process we should welcome any further information on this issue.

Timing

6. A meeting was held in Brussels on 7 February (the Council Working Party on Dangerous Substances) to initiate discussions on the proposal, although no significant amendments were proposed at this time. No dates for further meetings have been fixed. The purpose of this consultation is to inform the negotiations, and therefore any comments from business and consumers on the proposals should reach us as early as possible.

Comments from interested parties

7. It would be helpful if those whose businesses would be affected by the proposal as well as other interested parties could let us have their comments on the proposal as well as any they may have on the draft Regulatory Impact Assessment (RIA) attached at Annex B. As well as commenting on additional cost to business should the proposal be adopted, it would also be helpful if you could comment on the assumptions in the draft RIA. We are also particularly interested in having views on the costs and other implications of switching to alternatives to phthalates and on implementing the labelling provisions. Commentary on the current use of DEHP, in the light of paragraph 5 above, would also be welcomed.

8. Comments should be sent, in writing please, to:

Miss Sue Pain
Consumer Safety Unit
Department of Trade and Industry
Room 429
1 Victoria Street
London SW1H 0ET

Tel: 0171 215 0361
Fax: 0171 215 0357
E-mail: consult.phths@dti.gov.uk

9. Comments should reach the above address, if possible please, by Friday 14 April.

Publication of responses to the consultation exercise

10. To help inform the debate on the issues raised by this consultation it is our intention to publish a summary of the results of this consultation in a way which does not identify individual comments. This will be made available to the public at the end of the consultation exercise from the DTI’s mailing house:

ADMAIL 528,
London SW1W 8YT
Tel: 0870 1502 500
Fax: 0870 1502 333

11. A list of organisations being invited to comment on the proposals is also enclosed (Annex C). If you are aware of other interested bodies who may wish to comment on the proposal, please advise them that the consultation documents may be obtained from Sue Pain at the address given in paragraph 8 or from the DTI website at www.dti.gov.uk/cacp/ca.

ANNEX A

Draft

DIRECTIVE OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL amending for the 22^nd time Directive 76/769/EEC on the approximation of the laws, regulations and administrative provisions of the Member States relating to restrictions on the marketing and use of certain dangerous substances and preparations (phthalates) and amending Council Directive 88/378/EEC on the approximation of the laws of the Member States concerning the safety of toys (Text with EEA relevance)

THE EUROPEAN PARLIAMENT AND THE COUNCIL OF THE EUROPEAN UNION,

Having regard to the Treaty establishing the European Community, and in particular Article 95 thereof,

Having regard to the proposal from the Commission*,

Having regard to the opinion of the Economic and Social Committee**,

Acting in accordance with the procedure laid down in Article 251 of the Treaty,

*OJ

**OJ

Whereas:

1. Article 14 of the Treaty establishes an area without internal frontiers in which the free movement of goods, persons, services and capital is ensured.
2. Work on the internal market should improve the quality of life, health protection and consumer safety and the measures proposed by this Directive comply with the requirements that a high level of health protection and of consumer protection shall be ensured in the definition and implementation of all Community policies and activities.
3. The presence of phthalates in certain toys and childcare articles made of soft PVC and intended to be placed in the mouth, presents risks related to general toxicity to the health of young children.
4. The Scientific Committee on Toxicity, Ecotoxicity and Environment (CSTEE), after being consulted by the Commission, has delivered two opinions on these health risks.
5. The Commission Recommendation 98/485/EC on childcare articles and toys intended to be placed in the mouth by children of less than three years of age, made of soft PVC containing certain phthalates* invites Member States to take measures required to ensure a high level of child health protection in regards to these products.

*OJ L 217, 5.8.1998, p. 35-37

HAVE ADOPTED THIS DIRECTIVE:

Article 1*

Annex I to Directive 76/769/EEC is hereby amended as set out in the Annex hereto.

*This Article was accepted by the Working Party

Article 2

In Annex IV of Directive 88/378/EEC the following paragraph is added:  

"7. Toys, made of or including parts of soft PVC containing the phthalates listed in point XX of the Annex to Directive 76/769/EEC, which are intended for children under the age of three and which can be put in the mouth, although not intended for that purpose

The following warning shall appear in an easily legible and indelible form on the packaging for the toy.

"Warning – do not put in the mouth for extended periods as could release phthalates dangerous to child health".

The following shorter warning shall appear in an easily legible and indelible form on the toy:

"Not to be kept in the mouth".

Article 3

1. Member States shall adopt and publish the laws, regulations and administrative provisions necessary to comply with this Directive no later than [six month] after the date of its entry into force. They shall forthwith inform the Commission thereof.

They shall apply these provisions [one year] after entry into force of this Directive.

2. When Member States adopt these provisions, they shall contain a reference to this Directive or shall be accompanied by such reference on the occasion of their official publication. The methods of making such reference shall be laid down by the Member States.

6. Limitations already adopted or planned by certain Member States on the marketing of toys and childcare articles because of their phthalate content directly affect the completion and functioning of the internal market and it is therefore necessary to approximate the laws of the Member States in this field and consequently to amend Annex 1 to Directive 76/769/EEC^*.
7. It is necessary to provide for adequate labelling for child care articles made of soft PVC or including parts made of soft PVC intended for children under the age of three, which, although not intended for that purpose, can be put in the mouth. Such labelling also has to be provided for in Directive 88/378/EEC of 3 May 1988 on the approximation of the laws of the Member States concerning the safety of toys** for those toys, which fall within the scope of that Directive.
8. The Commission will review the provisions in this Directive in the light of further scientific knowledge within four years of adoption.
9. This Directive does not affect Community legislation laying down minimum requirements for the protection of workers contained in Council Directive 89/391/EEC*** and in individual directives based thereon, in particular Council Directive 90/394/EEC**** and Council Directive 98/24/EC***** on protection of health and safety of workers from the risk related to chemical agents at work.

*OJ L 262, 27.9.1976, p.201. Directive as last amended by Commission Directive 1999/77/EC, OJ L 207, 6.8.1999, p.18.
**OJ L 187, 16.7.1988, p.1. Directive as last amended by Council Directive 93/68/EEC, OJ L 220, 30.8.1993, p.1.
***OJ L 183, 29.06.1989, p.1.
****OJ L 196, 26.07.1990, p.1.
*****OJ L 131, 5.5.1998, p.11.

Article 4

This Directive shall enter into force on the twentieth day following that of its publication in the Official Journal of the European Communities.  

Article 5

This Directive is addressed to the Member States.

ANNEX

The following point is added to Annex I to Directive 76/769/EEC:    

ANNEX B

DRAFT REGULATORY IMPACT ASSESSMENT ON A PROPOSAL FOR A DIRECTIVE OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL AMENDING FOR THE 22ND TIME DIRECTIVE 76/769/EEC ON THE APPROXIMATION OF THE LAWS, REGULATIONS AND ADMINISTRATIVE PROVISIONS OF THE MEMBER STATES RELATING THE RESTRICTIONS ON THE MARKETING AND USE OF CERTAIN DANGEROUS SUBSTANCES AND PREPARATIONS (PHTHALATES) AND AMENDING COUNCIL DIRECTIVE 88/378/EEC ON THE APPROXIMATION OF THE LAWS OF THE MEMBER STATES CONCERNING THE SAFETY OF TOYS.

Purpose and intended effect of the measure

1. The purpose of the proposal is to ensure that children are not exposed to any health risks from the use of certain chemicals, known as phthalates, in toys and childcare articles. The proposal has two elements to it:

• a ban on the use of 6 phthalates in toys and childcare articles for children under 36 months and which are intended to be mouthed, that is to say items such as teethers, teething rings, dummies, bottle teats etc.

• for all other toys and childcare articles for children under 36 months and which could be put in the mouth, a labelling requirement is proposed so that there is a clear indication that the item should not be kept in the mouth.

2. The first element of the proposal has already been met in the UK. A voluntary ban by industry in the UK, effective from the beginning of December, means that items intended to be mouthed and containing phthalates should not, in any case, be found on UK shelves.

Risk Assessment

3. Phthalates are plasticisers and have been used to soften PVC for over 40 years. Although there has been no direct evidence of negative impact on human health, laboratory rats exposed to very high doses of the most commonly used phthalate in toys (DINP), developed kidney and liver disorders including liver tumours. One particular phthalate, DEHP causes adverse effects on the reproductive system of male rats.

4. The Commission’s independent Scientific Committee on Toxicity, Ecotoxicity and the Environment (SCTEE) was consulted on the use of 6 phthalates in toys and childcare articles intended to be mouthed. It expressed the view that these phthalates could be used subject to the establishment of migration limits to ensure any leaching from the toy or childcare article did not exceed scientifically established tolerable daily intake. The TDI is an intake level that is considered tolerable over a lifetime. For the majority of phthalates, including the most widely used DINP, the UK supported the SCTEE approach and agreed that, providing exposures were kept below the TDI recommended by the SCTEE, it is very unlikely that there would be any health risk to children. The level for DINP was very prudent, being set at a value 100 times lower than identified as even beginning to have any effect in experimental animals. There is also considerable evidence to indicate that humans are much less sensitive to the liver toxicity caused by DINP. However, for DEHP the UK, along with other member states, recognised that there was a particular concern because of its reproductive toxicity at relatively low exposure doses and because the mechanism by which the toxic effects came about were unknown. Although DEHP is not used in toys in the UK, the UK has supported an EU-wide ban on the use of this phthalate in toys and childcare articles which are intended to be mouthed.

5. The US Consumer Product Safety Commission also looked at the use of DINP in toys and concluded that ‘based on the best available information...few, if any, children are at risk of liver or other organ toxicity from mouthing teethers, rattles and other PVC toys that contain DINP’. They did, however, consider that there were some areas where more work was needed, including mouthing behaviour of children, issues of chronic toxicity and work to establish a better laboratory test to simulate children’s mouthing.

6. The negative publicity surrounding the issue has nevertheless led to public perception of the risks involved being significantly higher than the science would warrant. The high level of public concern generated by the negative publicity is understandable given that the risk concerns babies and young children, a group for which levels of acceptable risk must be particularly low.

Issues of Equity and Fairness

7. Is it right to place requirements on suppliers that are not based on scientific evidence and which do not comply with the government’s policy on good regulatory practice?

8. Is it reasonable to expect the public to reach an informed view and remain unconcerned over the health implications for their children when faced with conflicting messages over the safety of childcare articles and toys from a variety of ‘authorities’ including environmental lobby groups as well as from the UK Government, from other Member States and from the Commission?

9. Is it fair to expect industry to take responsibility for ensuring the safety of any products which they place on the market, and hence responsibility for ensuring that any alternatives which come onto the market are safe?

Options

10. The proposal involves two separate elements and the options and benefits for each of the two elements are considered separately.

1. The Ban On Phthalates In Toys And Childcare Articles Intended To Be Mouthed

The options in this case are essentially either (a) to agree the ban proposal or (b) to reject it.

Benefits

11. Industry in practice has already stopped using phthalates in the products in question and in November the UK accepted a Commission Decision banning phthalates in toys and childcare articles intended to be mouthed. Even if a satisfactory migration test is now developed it seems unlikely that any of these products containing phthalates will be re-introduced onto the European market. The proposal formalises a regime which is already in place and supporting it would not therefore have any additional cost implications, either for industry nor for enforcement purposes.

2. The Labelling Of Toys And Childcare Articles For Under Threes And Which Could Be Put In The Mouth

The options under this element of the proposal are:

1. Reject the labelling proposal entirely
2. Agree to the labelling proposal as drafted
3. Agree to a modified, more neutral labelling requirement
4. Propose that migration testing, based on SCTEE recommended levels, replace the labelling requirement

Benefits

Reject the labelling proposal entirely (option a)

12. This option leaves the current position unchanged and therefore offers no identifiable health benefits.

Agree to the labelling proposal as drafted (option b)

13. The labelling requirement as currently proposed would almost certainly lead to the effective removal of phthalates from the products covered since industry is unlikely to sell many products intended for small children and which bear the warning ‘do not keep in mouth’. This option would thus effectively make sure that children were not exposed to the types of phthalates and levels that would have the potential to cause life-impairing diseases. This might also eliminate the future cost of medical treatment although, given that we are unable to make any direct link between use of phthalates and illness in humans, it is impossible to quantify to what extent, if at all, there might be future cost savings.

14. On the other hand, since the labelling requirement will have virtually the same effect as a ban it is also necessary to address the issue of the safety of substitutes which may come in to replace phthalates (ie other plasticisers) or softened PVC should manufacturers decide not to use this material. However, since even less is known about the safety of such substitutes, we are not in a position to take a view on any associated future health care implications arising from the displacement of phthalates and entry of alternatives.

15 A labelling requirement may also be more acceptable in meeting remaining public concerns. Although the practical difficulties of the labelling requirement could well result in the removal of phthalates from these articles, the fact that phthalates are permitted would preserve an element of consumer choice and signal that there is not a safety case for a total ban. It would also draw attention to the fact that safety is related to prolonged ingestion and at the same time would also give reassurance to the public that their concerns are being addressed.

Pursue agreement for a more neutral labelling requirement (option c)

16. This option would make sure that purchasers of toys and chidcare articles would be aware of which products involved the risk of exposure to the types of phthalates which might conceivably have the potential to cause life-impairing diseases. Reduced purchase or reduced use would still produce some of the possible reductions in the expose of children and the costs of medical treatment noted in paragraph 13. At the same time, even a modified label should help improve the level of public confidence that any remaining risks from phthalates are being recognised and managed.

Propose that migration testing, based on SCTEE recommended levels, with the exception of products containing DEHP, replace the labelling requirement (option d)

17. A migration test approach would accord with the original SCTEE recommendation, although a requirement to test childcare articles would probably go further than the SCTEE had envisaged. Whilst a migration test has not yet been finally approved, we believe we could be quite close if the Commission showed commitment to this route. Certainly by the conclusion of the negotiations, a test should have been confirmed.

18. A migration test would ensure that all phthalates (particularly those which cause the most concern) are only present in toys within acceptable safety levels. Safety achieved would be of the same level as for labelling. However, it may be that this option will not achieve the same level of public confidence as labelling and the use of the migration testing route by industry may therefore not be as appealing.

Business Sectors Affected

19. There are no UK-based manufacturers of phthalates currently used in toys and very little production of toys using phthalates. The main sectors affected would be importers and retailers and there are no statistics available about the number who may be importing toys and childcare articles. We will attempt to seek information as part of the formal consultation to be undertaken shortly.

20. There is a UK manufacturer who produces one of the feedstock chemicals which is subsequently used to manufacture one of the phthalates (DINP). Although we believe that for this company the impact of a ban on DINP for this specific application would be limited, the consultation process will help to clarify the position.

21. It is estimated that the annual retail value of sales of teethers is in the region of £6-7.5m. Although dummies and bottle teats are covered by the ban, these have not contained phthalates for many years now. Most are now made of latex or silicon. These have not therefore been included within any cost calculation.

22. There is some manufacture of childcare article accessories (raincovers etc.). Although we have yet to establish the scale, it is not believed to be significant.Industry argues that there may be a wider impact on the general PVC industry as there is a possibility toy manufacturers might reject alternative PVC plasticisers in favour of alternatives to PVC itself. The industry is strong in the UK with around 50,000 people employed across the whole PVC manufacture and processing industry, including the hundreds of firms involved in turning the PVC into final products e.g. pipes, cabling, window profiles and components for electronic equipment. Annual sales are around £5bn with exports of £1.5bn of PVC polymer, additives and products.

Compliance costs

23. DEHP has not been used in toys in the UK for some 10 years now. A number of suppliers of toys and childcare articles are already using the LGC procedure for testing for migration of DINP. Alternatives are being used increasingly and many suppliers, particularly of toys, are moving away from phthalates for very young children.

24. The ban provision is already in effect and option 1(a) would not impose any additional costs.

25. Option 2(a) would not impose any costs but is not a feasible option.

26. Options 2(b) and (c). A strongly worded warning label is likely to drive phthalates and perhaps PVC out of the market for toys and childcare articles, without additional safety benefit to consumers. Given the lack of manufacturing in the UK, the longer term costs to UK toy and childcare industry should not be significant as importers amend their requirements. Moreover, as more and more countries move away from phthalates in these areas, the cost of more expensive alternatives is likely to hit industry, both in the UK and elsewhere, equally. However, the knock-on effect for the PVC industry could be more significant. A key cost on industry, already being felt, has resulted from the negative publicity leading to consumer demand for non-phthalate and non-PVC products.

27 We are not aware of how far phthalates are used in childcare articles but believe this could be significant. It is difficult to quantify the direct costs to retailers and importers which would arise from labelling of potentially a huge range of products. However, the presentational and logistical problems of labelling toys and childcare articles means that a likely cost would be changes to alternatives. Alternatives to phthalates are more expensive although it is not possible to estimate how much this would add to the price of the product or how far it would be passed on to consumers. We hope to get more details on the possible cost implications for UK business following the formal consultation. It should be noted that the Commission’s Explanatory Memorandum does not reflect the true cost impact of the labelling proposal for industry.

28. Option 2(d) . The cost of testing for the migration of DINP is £100-£150 per sample. The overall costs to a business would in each case depend on the number of different types of product in their inventory.

Other costs

29. With the exception of some childcare article accessories, toys and childcare articles are manufactured mainly outside the UK. Although toy and some childcare importers and retailers are already moving away from phthalates as a response to consumer concerns, they are effective plasticisers which can be used at reasonable cost. Alternatives to phthalates are more expensive. This may mean increased costs to consumers.

Enforcement costs

30. Local authority trading standards departments are responsible for the day to day enforcement of consumer safety legislation and they carry out a significant number of checks at retailers to ensure the safety of products. It is believed that options 2 (b), (c) and (d) set out above would all entail additional costs for local authorities but the nature and size of such costs are difficult to quantify. In terms of cost ranking, of the most viable options, (b) and (c) would be less costly than (d).

Consultation

31. This issue has been under discussion at community level for 2 years and the Government is aware of the views of industry and of interested parties such as environmental groups. A formal consultation paper will be sent out shortly.

Enforcement and monitoring

32. The measures will be enforced by local authorities as part of their consumer safety work.

Summary and Recommendations

33. Option 1: agreeing to the proposal would simply formalise arrangements which are already in place in the UK and which are an industry response to consumer demand. It does not incur additional costs and we could therefore support the proposal to ban phthalates in toys and childcare articles intended to be mouthed by under threes.

34. Option 2(a) is cost free but does not offer any benefits to address any perceived risk or public concern.

35. Options 2( b) and (c) would involve amendments to packaging requirements and to manufacturing processes to ensure labelling in appropriate form. Many may switch to other non-phthalate products. The cost of testing and conducting trials on the safety of substitutes for phthalates is difficult to quantify but has already started within European standards bodies in which industry is closely involved. Although the labelling requirement is not strictly justified in health terms, it is better than an outright ban and allows the consumer the opportunity to choose. The increased costs of labelling, or of using more costly alternatives, are likely to be passed onto consumers.

36. Option 2(d) would involve the cost of migration testing. It is in line with the recommendation of the scientific committee, and represents a proportionate response to the health risk being addressed. However, it may not give the public as much assurance as the labelling options.

ANNEX C

CORE CONSULTATION LIST

MR A PAINTER, TRADING STANDARDS CONSULTANT

ROLAND ROWELL, CONSULTANT IN MARKETING LAW

PEAT HOUSE

JOHN LEWIS PARTNERSHIP

AMTAC LABORATORIES LTD

ASSOCIATION OF BRITISH CHAMBERS OF COMMERCE

ASSOCIATION OF COUNTY COUNCILS

ASSOCIATION OF COUNTY PUBLIC HEALTH OFFICERS

ASSOCIATION OF DISTRICT COUNCILS

ASSOCIATION OF LOCAL AUTHORITIES OF NORTHERN IRELAND

ASSOCIATION OF PUBLIC ANALYSTS (SCOTLAND)

ASSOCIATION OF BRITISH INSURERS

ASSOCIATION OF LONDON AUTHORITIES

ASSOCIATION OF METROPOLITAN AUTHORITIES

ASSOCIATION OF INDEPENDENT BUSINESSES

ASSOCIATION OF RESIDENTIAL LETTING AGENTS

THE ASSOCIATION OF SCOTLAND'S SELF-CATERERS

BEDFORDSHIRE COUNTY COUNCIL

BELFAST CITY COUNCIL

BHS PLC

THE BOND STREET ASSOCIATION

BRITISH MEDICAL ASSOCIATION

BRITISH SAFETY COUNCIL

BRITISH STANDARDS INSTITUTION

BRITISH NON-WOVEN MANUFACTURERS ASSOCIATION

BRITISH IMPORTERS CONFEDERATION

BRITISH ASSOCIATION FOR CHEMICAL SPECIALITIES

BRITISH SHOPS & STORES ASSOCIATIONS

BRITISH TELECOM

BRITISH PROPERTY FEDERATION

BRITISH HOLIDAY AND HOME PARKS ASSOCIATION LTD

BRITISH SELF-CATERING FEDERATION

BRITISH COATINGS FEDERATION

BRITISH RETAIL CONSORTIUM

PROFESSOR GEOFFREY WOODROFFE, BRUNEL UNIVERSITY

BSI TESTING

BSM LTD

LABORATORY OF THE GOVERNMENT CHEMIST

THE CHIEF & ASSISTANT

CHIEF FIRE OFFICERS ASSOCIATION

CHILD ACCIDENT PREVENTION TRUST

CONFEDERATION OF BRITISH INDUSTRY

CONSUMERS IN EUROPE GROUP

CONSUMERS ASSOCIATION

CONSUMER ADVICE CENTRE AND DISTRICT OFFICE, CAERPHILLY

CONSUMERS’ ASSOCIATION RESEARCH AND TESTING CENTRE

CONVENTION OF SCOTTISH LOCAL AUTHORITIES

DEPARTMENT OF HEALTH

DEPARTMENT OF CONSUMER AFFAIRS

DEPARTMENT OF ECONOMIC DEVELOPMENT

DIRECT SELLING ASSOCIATION

THE SOCIETY OF CHIEF OFFICERS OF TRADING STANDARDS IN SCOTLAND

ASSOCIATION OF PUBLIC ANALYSTS, LONDON

DTI HQ LIBRARY

DEPARTMENT OF ECONOMIC DEVELOPMENT

FEI

ENGLISH TOURIST BOARD

DEPARTMENT OF THE ENVIRONMENT FOR NORTHERN IRELAND

FEDERATION OF WOMEN'S INSTITUTES OF NORTHERN IRELAND

OFFICE OF FAIR TRADING

FIRE SERVICE INSPECTORATE

FORESTRY COMMISSION

GENERAL CONSUMER COUNCIL FOR NORTHERN IRELAND

GREEN ACRES

HIGHLAND REGIONAL COUNCIL

THE HIRE ASSOCIATION (EUROPE)

HONG KONG GOVERNMENT OFFICE

HOUSING FOR WALES

HOUSING CORPORATION

DTI INFORMATION SECTION

THE INSTITUTION OF ENVIRONMENTAL HEALTH OFFICERS

ITSA

INSTITUTE OF CONSUMER ADVISERS

INSTITUTE OF HOUSING

IRISH CO-OPERATIVE WOMEN'S GUILD

INCORPORATED SOCIETY OF VALUERS AND AUCTIONEERS

KENSINGTON HIGH STREET ASSOCIATION

LABTEST INSPECTION SERVICES UK

LAKELOVERS HOLIDAY HOMES

COUNTY LANDOWNERS ASSOCIATION

STEPHEN WEATHERILL, NOTTINGHAM UNIVERSITY

SOCIETY OF LOCAL AUTHORITY CHIEF EXECUTIVES

LONDON BOROUGHS ASSOCIATION

THE MAIL ORDER TRADERS' ASSOCIATION

MARIE CURIE CANCER CARE

MEDICAL COMMISSION ON ACCIDENT PREVENTION

MEDICAL RESEARCH COUNCIL

WHOLESALE MERCHANTS & MANUFACTURERS ASSOCIATION LTD

MID-WALES TOURISM LTD

THE MOTOR CYCLE INDUSTRY'S ASSOCIATION OF GREAT BRITAIN LTD

NATIONAL ASSOCIATION OF CITIZENS ADVICE BUREAUX

NATIONAL ASSOCIATION OF LOCAL COUNCILS

NATIONAL CONSUMER COUNCIL

NATIONAL FEDERATION OF CONSUMER GROUPS

NATIONAL ASSOCIATION OF SHOPKEEPERS

NATIONAL STANDARDS AUTHORITY OF IRELAND

NATIONAL CONSUMER COUNCIL

NATIONAL COUNCIL OF WOMEN OF GREAT BRITAIN

NATIONAL FEDERATION OF WOMEN'S INSTITUTES

NATIONAL FEDERATION OF HOUSING ASSOCIATIONS

NATIONAL ASSOCIATION OF ESTATE AGENTS

NATIONAL FARMERS UNION

NATIONAL TRUST FOR SCOTLAND

THE NEWSPAPER PUBLISHERS ASSOCIATION LTD

NIC/ICTU

NORTH CORNWALL DISTRICT COUNCIL

NORTH WALES TOURISM LTD

NORTHERN IRELAND SAFETY COUNCIL

NORTHERN IRELAND HOUSEWIVES LEAGUE

NORTHERN IRELAND HOME ACCIDENT PREVENTION COUNCIL

NORTHERN IRELAND ASSOCIATION OF CITIZENS ADVICE BUREAUX

NORTHERN IRELAND CHAMBER OF COMMERCE & INDUSTRY

NORTHERN IRELAND TOURIST BOARD

LOCAL AUTHORITIES CO-ORDINATING BODY ON FOOD & TRADING STANDARDS

THE OXFORD STREET ASSOCIATION

CO-OPERATIVE UNION LTD

PRODUCT ASSURANCE LTD

QATC (EUROPE) LTD

JENNIFER BRAVE, RETAIL AND CONSUMER LAW CONSULTANT

ROYAL COLLEGE OF NURSING

FACULTY OF PUBLIC HEALTH MEDICINE

THE ROYAL ENVIRONMENTAL HEALTH INSTITUTE OF SCOTLAND

THE ROYAL SOCIETY FOR THE PREVENTION OF ACCIDENTS

ROYAL SOCIETY OF HEALTH

INSTITUTE OF HOME SAFETY

HEALTH AND SAFETY EXECUTIVE

HEALTH AND SAFETY COMMISSION

HEALTH AND SAFETY AGENCY FOR NORTHERN IRELAND

SCOTTISH CHAMBER OF COMMERCE

SCOTTISH CONSUMER COUNCIL

SCOTTISH HOME & HEALTH DEPARTMENT

SCOTTISH TRADES UNION CONGRESS

SCOTTISH FEDERATION OF HOUSING ASSOCIATIONS

SCOTTISH HOMES

SCOTTISH PROPERTY OWNERS & FACTORS ORGANISATIONS

SCOTTISH TOURIST BOARD

SHAC-LONDON HOUSING AID CENTRE

SHELTER

SMALL LANDLORDS ASSOCIATION

WELSH OFFICE

THE CITY HOSPITAL HOUSE, SOUTHERN GROUP PUBLIC HEALTH COMMITTEE

ST CHRISTOPHER'S PLACE ASSOCIATION

HEALTH AND SAFETY SERVICE, UNIVERSITY OF SUNDERLAND

TOURISM OF SOUTH WALES

TOWNSWOMEN'S GUILDS

TRADES UNION CONGRESS

DEPARTMENT OF TRADING STANDARDS, READING

WALES TOURIST BOARD

TRADING STANDARDS DEPARTMENT, TROWBRIDGE

WOMEN'S NATIONAL COMMISSION

WOMEN'S FORUM NORTHERN IRELAND

NORTHERN GROUP PUBLIC HEALTH COMMITTEE

FISHER-PRICE LTD

PLAIN ENGLISH CAMPAIGN

NATIONAL CHAMBER OF TRADE

BRITISH PLASTICS FEDERATION

LAW SOCIETY

THE GENERAL COUNCIL OF THE BAR

LAW SOCIETY OF SCOTLAND

FACULTY OF ADVOCATES

BRITISH FURNITURE MANUFACTURERS FEDERATION

THE ROYAL INSTITUTION OF CHARTERED SURVEYORS

THE HONG KONG STANDARDS AND TESTING CENTRE LTD

UNIVERSITY OF DUNDEE

ROYAL COLLEGE OF PAEDIATRICS AND CHILD HEALTH

ICE (ERGONOMICS)

ASSOCIATION OF PUBLIC ANALYSTS, BRAXTON REYNOLDS

TESCO

INDEPENDENT RETAIL NEWS

HEALTH VISITORS' ASSOCIATION

DOE (NI) ENVIRONMENT SERVICE

THE UNIVERSITY OF WALES

GLASGOW CALEDONIAN UNIVERSITY

CO-OPERATIVE WOMEN’S GUILD

FEDERATION OF SMALL BUSINESSES

LAWCO CONSULTANCY

INSTITUTE OF DIRECTORS

EAST DUNBARTONSHIRE COUNCIL

SOCIETY OF LOCAL AUTHORITY CHIEF EXECUTIVES

GEEVAX LTD

DEPARTMENT OF LAW

DTI PARLY BRANCH

UK INTER-PROFESSIONAL GROUP

THE CARDIFF BUSINESS PARTNERSHIP

HSE

AGE CONCERN

HEALTH & SAFETY AGENCY

WELSH CONSUMER COUNCIL

DETR

FEDERATION OF INDEPENDENT ADVICE CENTRES

GAS CONSUMERS COUNCIL

LAW CENTRES FEDERATION

TOYS CONSULTATION LIST

LACOTS

ITSA

FIRA

BRITISH TOYMAKERS GUILD

BRITISH TOY IMPORTERS AND DISTRIBUTORS ASSOCIATION

BRITISH ASSOCIATION OF NURSERY AND PRAM RETAILERS

BRITISH TOY AND HOBBY ASSOCIATION LTD

GCI LONDON

BRITISH JEWELLERY AND GIFTWARE FEDERATION

THE MAIL ORDER TRADERS’ ASSOCIATION

SOAP AND DETERGENT INDUSTRY ASSOCIATION

COSMETIC TOILETRY AND PERFUMERY ASSOCIATION

BRITISH ELECTRICAL AND ALLIED MANUFACTURERS ASSOCIATION

BRITISH RETAIL CONSORTIUM

CO-OPERATIVE UNION LTD

THE BICYCLES ASSOCIATION OF GREAT BRITAIN

PACKAGING AND INDUSTRIAL FILMS ASSOCIATION

BRITISH OFFICE SYSTEMS AND STATIONERY FEDERATION

WRITING INSTRUMENTS ASSOCIATION

BRITISH ASSOCIATION OF TOY RETAILERS

BRITISH PAEDIATRIC ASSOCIATION

INSTITUTE OF CHILD HEALTH

TAIPEI REPRESENTATIVE OFFICE IN THE UK

HONG KONG GOVERNMENT OFFICE

EMBASSY OF THE PEOPLE’S REPUBLIC OF CHINA

HUNTER TOYS LTD

H C FORD & SONS LTD

DAVID HALSALL PLC

PLATIGNUM PLC

PMS INTERNATIONAL GROUP PLC

D ACKERMAN & SONS LTD

IVADEN LTD

MOTHERCARE UK LTD

MARKS & SPENCER LTD

L I PRODUCTS LTD

CONSUMERS IN EUROPE GROUP

THE BOOTS COMPANY LTD

CWS CENTRAL LABORATORIES

NATIONAL ASSOCIATION OF TOY AND LEISURE LIBRARIES

THE LITTLEWOODS ORGANISATION PLC

HASBRO EUROPE

BHS PLC

TOYS R US LTD

M GORDON & SONS LTD

GUS MERCHANDISE CORPORATION

KENT SCIENTIFIC SERVICES

MR A A PAINTER, TRADING STANDARDS CONSULTANT

COMMUNITY PLAYTHINGS/RIFTON EQUIPMENT

FISHER PRICE LTD

TESCO STORES LTD

TOP TOYS LTD

WOOLWORTHS PLC

ASDA STORES LTD

KITFIX SWALLOW GROUP LTD

JOHN MENZIES

HELGER RACING LTD

MR J SHORTLAND

BRISTOL NOVELTY LTD

WFS LTD

IAN SCOTT & ASSOCIATES

TULLIS RUSSELL & CO LTD

REFORM MARKETING LTD

SANDFORD BEROL LTD

FREEDOM TOYS & GAMES

BENROSS TRADING CO LTD

LADYBIRD TOYS & GAMES

THE NATIONAL CHILDREN’S BUREAU

THE NATIONAL VOLUNTARY COUNCIL FOR CHILDREN’S PLAY

NATIONAL PLAY INFORMATION CENTRE

QATC (EUROPE) LTD

QUALITY SOLUTIONS

INSTITUTION OF ELECTRICAL ENGINEERS

DUCTILE STEEL PROCESSORS

CONSULTATION LIST - NURSERY GOODS  

BRITISH ASSOCIATION OF NURSERY AND PRAM RETAILERS

BABY PRODUCTS ASSOCIATION

BRITISH TOY AND HOBBY ASSOCIATION LTD

FISHER-PRICE LTD

QUALITY SOLUTIONS

NATIONAL CHILDRENSWEAR ASSOCIATION

SHELLEY ANDERSON

HOME-START UK

NATIONAL CHILDBIRTH TRUST

CONSULTATION LIST - CHARITIES

ROYAL NATIONAL INSTITUTE FOR THE BLIND

THE BRITISH HEART FOUNDATION

BRITISH RED CROSS

WWF UNITED KINGDOM

THE SCOUT ASSOCIATION

SCOPE

GREATER LONDON FUND FOR THE BLIND

BARNARDOS

CANCER RELIEF MACMILLAN FUND

CANCER RESEARCH CAMPAIGN

THE ROYAL STAR & GARTER HOME

THE CATS PROTECTION LEAGUE

ANCHOR HOUSING TRUST

SAVE THE CHILDREN FUND

SUE RYDER FOUNDATION

HELP THE AGED

ROYAL SOCIETY FOR MENTALLY HANDICAPPED CHILDREN & ADULTS

THE ROYAL SOCIETY FOR THE PROTECTION OF BIRDS

NATIONAL CANINE DEFENCE LEAGUE

ARTHRITIS CARE

THE IMPERIAL CANCER RESEARCH FUND

LEUKAEMIA CARE

MIND

NATIONAL COUNCIL FOR VOLUNTARY ORGANISATIONS

BRITISH EPILEPSY ASSOCIATION

NSPCC TRADING COMPANY

PEOPLE'S DISPENSARY FOR SICK ANIMALS

RSPCA

THE ROYAL BRITISH LEGION

THE WRVS TRUST

OXFAM

THE MULTIPLE SCLEROSIS SOCIETY OF GREAT BRITAIN & NORTHERN IRELAND

CHARITY COMMISSION

CHARITY SOLUTIONS, THE CHARITY ADVISERS

CHARITIES AID FOUNDATION

INSTITUTE OF CHARITY-FUND RAISING MANAGERS

NATIONAL ASSOCIATION OF LEAGUES OF HOSPITAL FRIENDS

THE NOTTING HILL HOUSING TRUST

RNLI

THE CHILDREN'S SOCIETY

MARIE CURIE CANCER CARE

CHILDREN-NORTH EAST

THE GUIDE ASSOCIATION

FERNE ANIMAL SANCTUARY

NEWMARKET DAY CENTRE

THE SALVATION ARMY

SENSE TRADING

OKEHAMPTON UNITED CHURCH

EURO-LMSC (LEGISLATION MONITORING SERVICE FOR CHARITIES)

APPROVED BODIES - TOYS

A H ALLEN & PARTNERS - RICHARD BAUGH

AMTAC LABORATORIES LTD - IAN DALGETTY

BRITISH STANDARDS INSTITUTION - RICHARD HARDY

BTTG - MIKE NUNNEY

EUROFINS SCIENTIFIC LTD - CLIVE SHELTON

ITS TESTING & CERTIFICATION LTD - CLIVE PATTEN

INTERTEK TESTING SERVICES, LABTEST

LGC - JULIAN BRAYBROOK

PATTINSON SCIENTIFIC SERVICES - JOHN SCOWN

NOTTINGHAM TEXTILE TESTING SERVICES - STEVE DONOGHUE

SGS UNITED KINGDOM LTD, BRADFORD - NIGEL BEAUMONT

SGS UNITED KINGDOM LTD, WARLEY - STEVEN POWELL

SGS UNITED KINGDOM LTD, WEMBLEY - STEVEN POWELL

SPECIALISED TECHNOLOGY RESOURCES (UK) LTD - KEITH RICHARDS

THE CITY OF EDINBURGH COUNCIL, ANALYTICAL AND SCIENTIFIC SERVICES - DR ANDREW MACKIE

THE NORTHERN TESTHOUSE LTD - ROGER NORTH

WORCESTERSHIRE SCIENTIFIC SERVICES - TIM WILLIAMS

OTHER ORGANISATIONS

GREENPEACE

FRIENDS OF THE EARTH

UNITED KINGDOM ACCREDITATION SERVICE

MINISTRY OF AGRICULTURE, FISHERIES AND FOOD

MEDICAL DEVICES AGENCY

CABINET OFFICE

FOREIGN AND COMMONWEALTH

Last updated 6 March 2000