In the wake of the recent vote by the European Parliament’s Environment Committee (ENVI), the European Balloon & Party Council (EBPC) voices its profound concern over the future of the balloon and party manufacturing industry. The proposed revision of the Toy Safety Regulation, while undoubtedly well-intentioned, threatens the very fabric of an industry emblematic of joy and celebration.

 

The ENVI Committee's decision to implement unrealistically stringent nitrosamine limits (0,1 mg/kg ) poses an existential threat to the production of latex balloons. These iconic symbols of festivity are not just products but are interwoven with the cultural fabric of celebrations across Europe. 

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The current standard, EN 71.12, is a testament to the industry's commitment to safety. It sets scientifically validated limits for nitrosamines, which are not an additive but an unavoidable by-product that occurs during the balloon manufacturing process. The proposed limits disregard this scientific evidence, placing an unrealistic burden on reputable manufacturers and risking the disappearance of balloons from the European market.

 

Moreover, the stringent restrictions on naturally occurring elements, such as the safe presence of nickel in outdoor toys like trampolines and go-carts, ignore the balance between safety and practicality. The absence of viable alternative materials that match the safety and durability of stainless-steel highlights a gap in the proposed regulation – a gap that widens when considering the undetectable level requirements for elements in products like crayons and paints.

 

This over-regulation does not translate to increased safety. Instead, it penalizes manufacturers dedicated to safety and quality, potentially paving the way for non-compliant products to flood the market. As history has shown, rogue traders, often operating online, are the primary sources of unsafe toys. These proposed changes risk exacerbating this issue, tarnishing the industry's reputation and endangering consumer trust.

 

The European Balloon & Party Council acknowledges the necessity of revising limits based on scientific advancements and the importance of robust enforcement to enhance toy safety. However, imposing limits that are not only unfeasible but also detrimental to an entire industry is counterproductive. It is imperative that the proposed Toy Safety Regulation undergoes crucial adjustments. These adjustments must ensure that the safety measures are practical, evidence-based, and foster an environment where quality and compliance are the industry standards.

 

We urge IMCO to consider the potential impact of restrictive measures during their discussions. It is not just the future of balloons and toys at stake but the preservation of an industry integral to the European economy and culture. Furthermore, this is about preserving the rich mosaic of children's imagination and play, elements that are delicately woven through the sensory engagement and secure experiences our products provide. Beyond mere entertainment, toys and balloons are pivotal in the developmental narrative of a child. They ignite creativity, introduce the nuances of color, and lay the groundwork for essential values from the earliest stages of life, shaping not just moments of joy but the very foundation of our future society.

 

We are dedicated to maintaining a constructive engagement to support policy-makers in the opinion development process to ensure they can make the informed decision of preserving an EU industry with valued traditions, which is committed to ensuring the safety and well-being of its consumers, as well as environmental stewardship.