Episode #86: Toy Safety 102: The EN-71 Toy Safety Standard with Bill Baxter
Listen Now
Tap Play Below or Listen On iTunes | Spotify | Google Podcasts
Remember Brexit? Well, back in late January when the UK left the EU, I reached out to a Toy Safety expert friend of mine and asked, “What is this going to do to our labeling requirements?” The answer was, “a little when it comes to testing” and, “a lot when it comes to paperwork.”
Today’s podcast episode is our Toy Safety 102 lesson, and we spend about 90% of this conversation focusing on the cost, complication, and changes in labeling and testing requirements brought about once the UK split from the EU. EN-71 is the European standard that specifies safety requirements for toys sold in the European Union. Bill walks us through what you need to stay compliant with and points out that we have until January of 2022 to have all product molds, deco, and packages updated with the new required labeling.
At the end of the episode, you’ll gain a little bit of perspective around accepting international orders for your product line too soon. If you don’t know anything at all about toy safety, you might want to check out episode number 43, Toy Safety 101. You’ll learn more about our guest, Bill Baxter, and get a clearer picture of the acronyms you’ll hear us tossing around in this episode. To listen to episode 43 just visit www.thetoycoach.com/43.
-
Baxter Regulatory Solutions https://www.brscompliance.com/
-
[00:00:00] Azhelle Wade: You are listening to making it in the toy industry. Episode number 86. Hey there toy people, Azhelle Wade here and welcome back to another episode of the toy coach podcast, making it in the toy industry. This is a weekly podcast brought to you by thetoycoach.com. Today's episode is going to be all about toy safety and the European toy safety standards and how they changed since Brexit.
[00:00:38] To be honest with you. This episode has been sitting in my vault a while, which you probably already noticed. Cause I mentioned Brexit, but a lot has been going on in the world. And I just had so many other timely episodes to share with you since this one was recorded, that it had to wait. So today we invite back friend of the show, Bill Baxter of Baxter regulatory solutions to give a toy safety 1 0 2 lesson.
[00:01:06] If you don't know anything about toy safety, I'm going to recommend that you hit pause right now. I know I normally don't do this, but I'm going to recommend that you hit pause right now. Go listen to episode number 43 by visiting thetoycoach.com/43. And listen to that episode first, then come on back to this one.
[00:01:28] Now episode 43 was our toy safety 1 0 1 episode. And it's an excellent starting point. This episode is our toy safety 1 0 2, where we dive a whole lot deeper. So if you don't know anything about toy safety, and if you don't know anything about Bill Baxter, this is not the episode you want to start with. You definitely want to go and start your journey with episode 43.
[00:01:51] And I also want you to remember if you're a podcast insider's club member, listening to this episode here. You should go to your private feed because you have a more extended episode waiting for you there, but you also have video of this interview. So make sure you head over to your members area. And if you want to join the podcast insiders club, just head over to club.thetoycoach.com to learn more.
[00:02:14] Now my conversation with Bill today begins talking about. EN 71, which is the European standard, that specifies safety requirements for toys sold in the European Union. The question that initially was posed to Bill when I first reached out to him for this interview was. What does Brexit mean for our toy labeling requirements?
[00:02:39] And he answers that question right off the bat. So are you ready? Let's dive in.
[00:02:45] Welcome to the show Thanks for coming back on the show.
[00:02:47] Bill Baxter: It's great to be here.
[00:02:49] Azhelle Wade: Let's start with an overview of just kind of testing in the EU before we had to think about the EU and the UK separately.
[00:02:56] Bill Baxter: So when the UK peeled off from the EU they didn't actually change any of the laws that apply to toy safety.
[00:03:08] What they did is they created a new certification mark and a new certification box. But all of the requirements are exactly the same. So the good news is that if your toy is already legal to sell in the EU with the CE mark that applies in the UK as well. So all the tests are the same is what I'm getting.
[00:03:29] I think the real difference between the us and the EU market is that they have 29 countries and each one of them has their own CPSC. We have one CPSC. I'm trying to translate this into American terms. So what they've done is they have put together a bunch of treaties between these countries to harmonize everything.
[00:03:54] They are much more dependent on standards and documentation than we are because in the end, if there's a safety problem in the U S the CPSC can just come in and say, there's a safety problem. I don't care if you pass you're done. In Europe, the people in France are regulating separately from people in Germany, from the people in Cyprus, from the people in Spain.
[00:04:17] And so what they've decided on is that they named certain laboratories as what they call notified bodies. And the job of those notified bodies is to try to stay on the same plane and to come up with the rules. And then they've created standards to say that if you meet this standard, you meet the requirements of the rules all the way across the EU.
[00:04:43] So that means that the standards are a little more detailed and they go into a lot of specific products just in different ways than the U S does. We sort of have the one big AST M F 9 63 standard. Right. And then the CPS, which is the law that is above. So like us, they have the EN 71 standard and then the toy safety directive, which is above that.
[00:05:12] Azhelle Wade: So theEN 71 standard. Can you give just an overview for someone who's never even heard of that term before?
[00:05:18] Bill Baxter: So if you're familiar with the F 9 63, it's a very similar, okay. The thing is. The specific tests are different and the problem is it's not the one is stricter than the other. They're just different. And about the same strict. So let's take drop testing, for example, in the U S you drop tests depending on the age of the child, but you drop tests onto a vital floor, a certain number of times, and then if parts break off, or if safety hazards are revealed, you've failed the test. In the EU you dropped from a slightly different height onto a concrete floor with a required rubber pad on it. Which one is more stringent in practice. They're about the same.
[00:06:03] Azhelle Wade: Okay.
[00:06:04] Bill Baxter: But you can't test for one and say, you've passed the other test because it is different. And so that's why you sort of have to do both tests. And so wherever possible, the people doing safety in Europe and the people doing safety in the U S writing the standards. They try to align them. They really try hard, but that brings us to the toy safety directive and the CPS. And. Because those are different and written by legislators who don't care about alignment between different countries. They've both put in some rules that the people writing the standards are like, well, that's in the law. We have to include it. Right. So as an example quick easy examples in the U S we do all of our chemical testing based on total led content. That's part of CPSIA. So the FDA 63, can't just ignore it.
[00:06:55] And that means you're testing for the amount of lead in the material itself. In the EU and this was picked up in our heavy metals testing in the U S but that's the aside though. It's not worth going. Into in the EU their focus is on how much of the heavy metal comes out of the material. So how much lead comes out of the material.
[00:07:15] And so they don't test to the total amount. They test you. What comes out into fake stomach acid. And again, it's not that the two tests are really that different in stringent MIS they're just different. And so you end up having to do them separately and some materials react better to one test, some materials, react better to the other test.
[00:07:37] Azhelle Wade: So I just, I want to throw out, I mean, we might've covered this in the first episode. CPSC for anybody that's just wondering what we're saying. Consumer product safety commission, but CPSIA, what does that stand for?
[00:07:51] Bill Baxter: That's the consumer product safety improvement act. It's a law that was put in in 2008 that brought me into the safety industry from the toy industry. That was when everything, when they made a federal law, they added led testing and kind of really invented and codified the idea that there are toys and then children's products as a category, larger than toys, but still more regulated than general.
[00:08:18] Azhelle Wade: Comparative for Europe, what is theirs called?
[00:08:23] Bill Baxter: There's this called the toy safety directive.
[00:08:25] Azhelle Wade: Okay. The toy safety directive. And that is the umbrella under which all like EN 71 falls?
[00:08:31] Bill Baxter: That's correct.
[00:08:33] Azhelle Wade: Okay. I want to keep it real broken down. Cause I already were to going in always going deep. People are probably listening, thinking. I don't understand any of these letters and acronyms, so I don't know what's going on.
[00:08:45] Bill Baxter: It's hard to talk about safety and not talking code. So thank you for catching me and please keep that up.
[00:08:51] Azhelle Wade: What does the code E N 71 stand for?
[00:08:55] Bill Baxter: What you have is you have a standard body in Europe called the CEN and that standards body writes all the standards. And so that those of us in the business can tell the different standards apart. They have a consistent way of numbering everything. And so EN just means it came from the CEN body. There's a couple of smaller bodies and I might have the actual. Authoritative body for the EN wrong. I mean, honestly, I would need to look that up to be sure. Yeah, fairly sure it's cen, but then you'll end up with something like ISEN or it used to be BSEN those won't happen anymore. Or F R E N where you have two letter code. That means this is the country whose standard body is putting out this version. And then the EN, which means this is a universal European standard.
[00:09:47] Azhelle Wade: Okay. Okay.
[00:09:48] Bill Baxter: The number after that is just 71 means toys.
[00:09:52] Azhelle Wade: I always wondered with F 9, 6, 3, and an AST M why are they so different? It's not just F 9 63 and then F 9, 6, 4 for arts and materials. So I always wondered why those letters were so different?
[00:10:05] Bill Baxter: So the a S T M in the U S is the equivalent of the CDN or the standards body in Europe. So STM is a group of people from industry regulators and child safety advocates who all get together and write safety standards.
[00:10:26] And so that's the body. And then F means that it is from a particular committee that handles product safety and D means it is a particular committee that handles chemicals and a means something else. So any standard from the AFTM will have a letter followed by a number and that letter lets you know which committee you should talk to if you want to make changes.
[00:10:49] Azhelle Wade: Ooh. Yeah, I know, but that's, I've never even asked that question before. I love that. I asked you, you gave such a great explanation. Thank you. Okay. Going back to Europe now, you did mention, you said, okay everybody calm down, just because you know, now we have to look at the EU and the UK differently. Luckily we don't have to make any major changes, but the major change that you mentioned was the mark. And then you said the body. So what, what do you mean by the mark?
[00:11:17] Bill Baxter: Okay. So on the product you currently, if you're selling in Europe, you have tested to the EN 71, and then you have put together a declaration of conformity to the toy safety directive, which is a piece of paper that should go along with import.
[00:11:34] It is a very likely as an American manufacturer that you've never seen that or had to deal with it because whoever is buying the product from you is handling all of that and not telling you about it. Really it is the responsibility of the importer to make sure all of that's taken care of.
[00:11:48] And since they know, we don't understand a lot of times they just leave us out of the loop. It's just like, oh, good. Do you have any and test report, I'll handle the rest.
[00:11:56] Azhelle Wade: Wow. Okay.
[00:11:57] Bill Baxter: So, the CE mark is means that you have met the toy safety directive and that's why it goes on the product and it needs to be visible at retail. So it goes on the package as well.
[00:12:11] Azhelle Wade: And a CE mark, just for anyone listening, if you've never done this before, it literally is a image. That's a CE that you would put on the packaging. Once you pass that testing.
[00:12:21] Bill Baxter: Direct on the product.
[00:12:22] Azhelle Wade: Yes. Oh yeah. Right on the product. Yeah. Yeah.
[00:12:24] Bill Baxter: That's, that's actually where it's supposed to be and that's the most important part. And then the packaging. So if it's on the product and that product is visible at retail, it doesn't need to be repeated on the package.
[00:12:35] Azhelle Wade: When you say on the product as a sticker or as a paint up or as?
[00:12:39] Bill Baxter: It needs to be permanent, so it can be in the mold. And I can be a paint as long as it withstands some. Permanency tests that aren't the craziest permanency tests. No, one's going out with a sandpaper for 20 minutes.
[00:12:56] Azhelle Wade: Are you telling me we have to test our labeling of our testing standards? So you're telling me someone is testing.
[00:13:03] Bill Baxter: Okay. That is, that is part of me EN 71 is to make sure that the market is. Permanent to where they even a reasonable standard. And if you've never heard of it, it means you've never failed that test
[00:13:14] Azhelle Wade: I have it. And now I'm wondering, so wait, what, what would be the process then with EN 71? Is it you create the product, put the mark on it, assuming you'll pass, test it. Or are you testing it before the marks on it? Cause you haven't passed putting the mark on it. Testing again. What, what has happened then?
[00:13:32] Bill Baxter: Most us manufacturers just put the mark on as soon as pass.
[00:13:36] Azhelle Wade: Okay. And that's okay. I don't know if they're, if the, if the lab is going to say we'll excuse you for thinking you'll pass.
[00:13:42] Bill Baxter: One time I ran into a lab that actually did that. Oh, they didn't. Well, they didn't shut down someone who submitted it, but they were. Okay. So in testing, there is a process of claim verification frequently for retailer testing. So if you put a claim on your product, like holds 200 pounds, the lab then puts 200 pounds on it and says, yes, it does that pass.
[00:14:05] Azhelle Wade: Okay.
[00:14:07] Bill Baxter: And so what happened is someone had submitted a product and because it had a CE mark on it, the lab said, oh, please give us your CE test for claim verification. And basically what we don't know, half one, because it hasn't, you know, we haven't gotten to the stage where we're selling into Europe. So we didn't do the test yet. It's like, well, you've made the claim on the product. And so, yeah, that went through several, this was what I was working at the lab and that went through several levels internal technical stuff.
[00:14:35] Azhelle Wade: Wait, was that a us lab?
[00:14:36] Bill Baxter: It was a U S lab, the U S just failing for claim verification for Europe.
[00:14:42] Azhelle Wade: Well, that makes kind of sense. It's picky, but it's also it, but it's not the situation that I'm imagining where you're actually submitting it for EN testing. And then they're saying, well, you haven't approved this yet. So that, that won't happen probably.
[00:14:56] Bill Baxter: That shouldn't happen because the idea is that if you fail the testing, then you just don't sell that in Europe.
[00:15:01] Azhelle Wade: Right.
[00:15:01] Bill Baxter: So you haven't broken any laws until you sell it?
[00:15:04] Azhelle Wade: Yeah. Okay. That's great to know. Okay. Great to know. All right. So the market's changed, right? We didn't even get to the change yet. Okay. So the change, what is the change?
[00:15:12] Bill Baxter: All right. So when, when the UK split off they actually found their consumers stuff was going pretty well. The things that drove Brexit were fishing rights and other immigration, whole other issues? The people running consumer products were like, wait, wait, this is working pretty well. Do we have to change? Right? And so what they did is they didn't change. Any of the laws. Oh, wow. This is going to go back down a rabbit hole.
[00:15:39] Azhelle Wade: It's okay. I love your rabbit holes. They're informative rabbit holes.
[00:15:44] Bill Baxter: So when you have these overarching things, like the toy safety directive and other treaties in Europe, what they did is they made each country write their own set of laws to incorporate that treaty into their local laws.
[00:15:59] Azhelle Wade: Okay.
[00:16:00] Bill Baxter: So you have the toy safety directive, but then in the UK you have a British toy law. And in France you have a French toy law. And so what happens is in a few cases like the French have included a bunch of extra chemical requirements that in Germany, they have a German toy law and then a voluntary standard that everyone complies with because Germany and if you have a standard, why wouldn't you do it?
[00:16:28] So in the UK, when Brexit happened, they pulled out, but that British toy law that's exactly aligned with the toy safety directive. Like, well, it's working fine. Why repeal it? They just changed the symbol. So now you don't put the CE mark, you put the U K C a mark, which is a, a U and a K and a C and an a, and a little square.
[00:16:51] And that's just taking the job of the CE mark. And then you have to write all of your declarations of conformity to say the British law instead of the toy safety directive, because now you're bringing it into the UK. Okay. So you have that document that I told you. You're a very important part that you probably never seen before.
[00:17:12] The declaration of compliance of the toy safety directive, that UK law still requires it. But now it has to say the name of the UK laws you comply with for the UKCA mark. You get to test one time for the UK and Europe, because they're both running off of the EN 71. So they're still working from the same standards. It's just that the mark that's required on the toy is different. And the documents that go along with the toy need to be changed to the UK rules.
[00:17:41] Azhelle Wade: And the rules that are the same.
[00:17:44] Bill Baxter: Yes. That the document uses the name, not the rules. So here we are.
[00:17:50] Azhelle Wade: Okay. So for people that are developing product now that they plan to sell in the EU and the UK, when they go to the lab and they test that product, they will have to either let the lab know that they need a certificate of compliance that, that specifies it's for the UK and the EU.
[00:18:06] Bill Baxter: What they will probably do is they'll have a check box for, you know, UK EU, U S Canada, Australia. That is the way most labs run it. And then the certification is a self-certification like it is in the U S so really all the lab has to do is give you the Aeon 71. And they don't normally put together.
[00:18:29] I mean, they're not required to put together a declaration of conformity. Many labs offer that as a service alongside the test. Okay. And often they will offer it for free. And so it is possible that so many customers will ask labs that, well, if I'm testing for the EU, I'm also testing for the UK. Can you just roll it all in the price will go up by $10 or whatever, and they'll stop charging separately.
[00:18:55] Azhelle Wade: Okay. So now people that have already been selling or updating their product for the UK CA so that they can continue selling and do they have to submit that product again for some other further review, if they've already been selling it, it passed EN 71, but now they're adding on that mark that you said has to be tested so do they have to like run it by tests again?
[00:19:16] Bill Baxter: You don't have to, so wait, let me add one other thing in here that has covered it. Yeah. Okay. Okay. Realize people were not going to be able to change on a dime. Okay. So you are allowed to have just a CE mark on your product until January 1st 2022. Okay. So you've got another six months or so to get your molds updated.
[00:19:38] And of course, anything that's already in country. Or it was manufactured before the switchover date is allowed to have the old just CE mark on it. But you should be in the process now of updating your molds or your printing or whatever, to have both marks. And as of January 1st, 2021, your documentation needed to update, to show the new laws. But the product didn't need to change at all.
[00:20:07] Azhelle Wade: The documentation needed to update meaning just stating that it also passes the UKCA?
[00:20:13] Right.
[00:20:14] Okay.
[00:20:14] Bill Baxter: Yeah. So the declaration of conformity needed to be changed.
[00:20:17] Azhelle Wade: Yes.
[00:20:18] Bill Baxter: But you didn't need to retest because the EN 71 is the same. It's the same for both.
[00:20:24] Azhelle Wade: Okay. Wow. That wasn't a journey. Okay. It was a journey.
[00:20:29] Bill Baxter: It's a journey with the wise.
[00:20:32] Azhelle Wade: I want to go to the second thing that you said change. I know when you first said your first statement, when you came on today, I was like, oh, this is going to be a quick convo. Not. So I wouldn't go to the second thing you said is changed. But before we do that, I made a note here because there are so many layers that I just want to clarify. So you mentioned the toy safety directive, right? Being the top umbrella in the EU and UK now. And then you mentioned that the rules are coming from the CEN. Right for the EN 71 rule. So the toy safety directive is the law that, that group CE N is perpetuating or like, I'm just trying to figure out the structure of it.
[00:21:15] Bill Baxter: Okay. So the toy safety directive is a law, but it's more like a treaty. Right. It is right. So it's a document. It's a set of laws. The CDN is a standardization body. So it's a group of people that get together and make up standards. Now they're required to incorporate what's in the law and the treaty into those standards. But those people are, you know, some people from Germany, some people from Ireland, some people from Italy and they're all getting together in a room and arguing about how much lead is really safe.
[00:21:50] Azhelle Wade: Oh, okay. Oh, thank you. All right. That's perfect. And how many tests are in the EN 71 for toys?
[00:21:56] Bill Baxter: So many you have no idea but there are, it, it matches the , which you've ever looked at it.
[00:22:03] Azhelle Wade: Oh my god, I just choked on how long it is. Okay.
[00:22:07] Bill Baxter: All right. And so then the EN 71 tricks you, because. They divided it into 13 parts. So the part you're thinking of is EN 71 part one, which is physical and mechanical requirements. Okay. Then part two is flammability. So that's the rules for flammability in Europe. Then part three is heavy metals, and then we get into the ones that I can never keep straight. So four through eight are playground equipment science kits. My favorite chemical products that are not science kits. So slime gets its own standard, separate from a chemistry set. And then you get all the way down into. You get to nine through 13, and those are dealing with specific chemicals and specific materials, and those are also voluntary, but highly recommended for safety.
[00:23:06] Azhelle Wade: What is like the average number of tests that one product will have to do because the whole standard covers all kinds of products. But when you're you have your specific product you're going to be doing, is it like three to five specific tests for your specific product?
[00:23:21] Bill Baxter: It is impossible to say because it depends on the features of the product.
[00:23:27] Azhelle Wade: Right. It could be like a feature plush that you take to the bath and then build into a furniture there is a problem.
[00:23:35] Bill Baxter: Yeah. Here's her projectile bath toy.
[00:23:38] Azhelle Wade: Ah, gotcha. Okay. Well, okay. A better question would probably be in those parts how many tests are in the park?
[00:23:47] Bill Baxter: So generally speaking, it kind of mirrors the . So if you think of it that way you're probably looking at could be as few as five tests because you'll do your drop tension torque. And then depending on features, you may have another one to another time. But your minimum is going to be five or six tests. And usually the way it works out is the parts, make it easier for the lab to quote because they can look at it and say, this needs EN 71 part one, plus EN 71 part three. It does not need four, but it needs six. And so they can look at them as here is a blanket cost for. The different parts when appropriate. Normally what will happen is the safety requirements that are specific to one of these other parts are really specific to that toy. So EN 71 part three is the expensive part of the EN 71. That's the heavy metal testing. That's 19 heavy metals instead of the eight we use in the U S and every material in your toy needs to be tested and they all need to be tested separately because they're doing it through the extraction methods rather than the total methods. So it is very difficult. If you drop three things into a block of hydrochloric acid, they react differently. And so. Led from one thing might go onto the other thing and not go into the acid. So you can end up with interference and false negatives, which is what they don't want it and toy safety. I mean, if they're going to have a false, they'd rather err, on the side of false positives. And so each individual material needs to be tested and that gets pretty expensive. Pretty quickly.
[00:25:51] Azhelle Wade: Before we run out of time, I want to ask you about the body. You mentioned that there was some change in the body information?
[00:25:59] Bill Baxter: So if you're working with a major test, They've almost certainly whoever was their lab in the UK is now authorized under the UK. And whoever were their labs in Europe is now authorized under Europe. And when you get your toys tested, usually in Asia you're depending on the numbers and paperwork of those labs. So for most cases, The change over to being a notified body in the UK will be seamless. It's not something we are going to notice. Labs had to do a lot of work, but we as lab customers don't need to.
[00:26:34] Azhelle Wade: Okay. Perfect. All right. Now the final thing I want to cover, and I'm really glad you came back today. Because when I refer people to you I tell them what to prepare. So I, I think it's important. And this is just from my experience of working with other safety people. I think it's important to have some sort of an Excel document that specifies like what your products is how it, how you intend for it to function the age grade that you want to use with it, pictures of the product and the components like the components listed out. I would just love to hear from you, what would you like potential clients to come to you ready with if they are thinking they might want to work with a safety expert to get their product tested.
[00:27:18] Bill Baxter: Okay. So those were all good. The material is hugely important. And the more detailed the better. And when we're saying that, I don't mean just plastic. I mean, types of plastic on your bill of material, because that can affect what testing is required.
[00:27:36] Azhelle Wade: Interesting.
[00:27:37] Bill Baxter: The. So we got bill of materials the use who, your age grade, and that means who your intended. A customer is and how you expect the intended customer to use it is also hugely important. And the one that got left out that matters particularly for today.
[00:27:59] Azhelle Wade: I know what you're going to say, I know what you're going to say. I know. Yes. Mark is of distribution.
[00:28:06] Bill Baxter: Because that's, that's a huge piece because the laws in the U S and Canada are slightly different. I mean, as a consultant, I'm supposed to say they're very different and you must really freak out about it and you must call me. But the reality is they're slightly different. They are designed to work together. And similarly, the rules in Europe are all slightly different by country, but again, they're designed to work together.
[00:28:31] Azhelle Wade: I love to just like specify the best uses for a choice safety consultant, because I think people don't know the best way to utilize your services. And especially when they have a limited budget, like what is their ideal time to come in? I know you would love them to come in, like as they're designing the product, but,
[00:28:48] Bill Baxter: I honestly think earlier is better, but there is a point where it's too early because. It needs to exist enough that we can see where the unintentional things happened. Okay. And the problem is, I mean, so one time I was at the toy fair and someone came up to me and was like, alright, I need you to tell me all of the safety requirements for a game about a hippopotamus.
[00:29:13] Azhelle Wade: No, they didn't.
[00:29:15] Bill Baxter: They totally did.
[00:29:16] Azhelle Wade: I just have a new question for you that I just noticed the other day on a package. Maybe this was just the two boxes I saw, but I saw two items that were clearly like a three-plus age, grade warning. So they had the warning on the box, like three plus. The eighth grade was eight plus, but it had the choking hazard warning on it.
[00:29:37] Bill Baxter: So a lot of people just put the three plus on the, the federal choking hazard on. As a catch all, they put it on everything and they don't worry about the age grade of the product. to the CPSC, if that really is a product that actually is intended for an eight year old. Yeah. Then the fact that the warnings on there doesn't matter to them and it is not illegal.
[00:30:00] Azhelle Wade: I see. Okay. That makes sense.
[00:30:03] Bill Baxter: but I mean, but the other thing is a lot of people just slap it on there so that they're sure they're covered and don't have to think about it.
[00:30:10] Azhelle Wade: Interesting. I wondered if there was a drawback to putting it on. If you when you don't need.
[00:30:15] Bill Baxter: It's not an enforcement drawback on the person doing it. It's on the overall community of safety, because if you put warnings on everything, then the warnings become meaningless. Yeah. And so that's the real drawback to it is. Warning when something is not safe means people will just start ignoring the warnings and don't know that it's communicating something. That's the real drawback.
[00:30:40] Azhelle Wade: Thank you, Bill. Is there anything else that you want to share today? Where can, where can people find you?
[00:30:45] Bill Baxter: Sure. I have a website and I'm also around on LinkedIn.
[00:30:51] Azhelle Wade: Will put BRS compliance in the show notes so people can connect with you. Oh, you have a lot of good information here on your website. Oh, love it. Yeah. Okay if you need more insight into consumer product compliance issues, first page of BRS compliance.com has got you covered. So I'm definitely going to link to that in the show notes. Thanks so much for being here today.
[00:31:13] Bill Baxter: Oh my pleasure.
[00:31:13] Azhelle Wade: Take care,Bill.
[00:31:15] Well there, you have it. My interview with bill Baxter of Baxter regular toy solutions, and that conversation got deep toy people. We really got into the weeds of how the toy safety directive was constructed, who the cen is, who is deciding what E N 71 laws are and, and a whole bunch more. We even touched on U S law a little bit better.
[00:31:41] Now, right when our call ended, bill shared such a great example of a story that might happen to you, that he doesn't want you to be in the midst of. We got into a conversation on why a small manufacturer might choose to expand their product from the U S to the EU, considering how much more expensive toy safety testing is for the EU and the UK. Now. Bill shared an incredible example story, and I'm so mad I didn't get to record it, but I did take some notes that I could repeat it to you now. And this is really just kind of, you know, a warning of something that could happen to you. If you didn't understand the additional expense of testing and importing in the EU or other, any other country outside of, let's say the U S so maybe you're used to the testing fees and requirements, and you figured out the cost of your goods based on all of the history of selling your product in your home country. And now you're looking to sell in a different region, and it's important to keep in mind when you're selling in another region there are more expenses that are going to pop up. So here's a great example story that he gave. So imagine you're an American toy seller and you actually go to Nuremberg toy fair, and a toy buyer local to the area loves your toy. They love how cheap it is. And they're like, oh, we want to buy that and you get into business with them. You start producing product for them, and that's when you discover how expensive testing is.
[00:33:19] If you're trying to get into the EU of, you're trying to get into the UK, you discover how expensive the import process is, and eventually you get to the point where your wholesale price is no longer covering the cost of getting your product into that country.
[00:33:34] Now that is a downside, which hopefully will not happen to you anymore because now you know that you have to account for additional costs. If you're going to bring your product into another region. But what you also can think about is how you can possibly amortize that cost across various other countries.
[00:33:54] So, do you wanna sell your product in Italy? Do you want to sell your product in Spain? Where else? Within the entire region that covers that E N 71 and all of the tests that are required, all of the countries that accept and follow the Aeon 71.
[00:34:11] It's your job to think about how you can expand your toy business to those surrounding countries so that you can actually recoup your expense of bringing a product into Europe or into the UK.
[00:34:25] So for anyone of you that are thinking about taking your product international, be wary of just somebody who wants to take in a small amount of product into just one country and really try to build out a strategy where you are taking your product into multiple countries at the same time. So you can be sure that you're amortizing the cost of the additional toy safety costs of your product with full international growth, not just trying to get your products into one country for one small.
[00:35:02] so for today's listener spotlight, we have a review from uni oh, uni. Oh, says amazing podcast. So many gems on this pod. Very inspiring. Definitely recommend if you're trying to navigate the toy industry. Thank you so much for that review uni. Oh, if you are a fan of this podcast and you haven't already left a review, what are you waiting for? Wherever you're listening to this podcast. I want you to stop right now and leave us an awesome review.
[00:35:34] Well toy people. That's all I have for you today. I hope you head over to BRS compliance.com and reach out to bill Baxter with your toy compliance questions. It's important to be as detailed as possible to get the best results and to see if you are a great fit to work with him as a consultant.
[00:35:56] As always I appreciate you for spending your time with me today. I know there are a ton of podcasts out there, so it means the world to me that you tune into this one until next. I'll see you later toy people.
-
🎓Learn more about how you can develop and pitch your toy idea with Toy Creators Academy® by clicking here to visit toycreatorsacademy.com and join the waitlist.