On 7 May 2009, the Commission Directorate General for Consumer Affairs published project results of an external study which was commissioned to identify child care articles and equipment which can be dangerous. The study assessed an initial set of 20 articles commonly used to bathe, feed or clothe newborns and young children, and products that are present at home or in day nursery centres. These include duvets, baby bouncers, booster chairs and children's clothing items.
The study was commissioned due to concerns that there are no European safety standards for these products, or, if a standard does exist, it does not cover all possible risks. Given this state of affairs, the use of some of these products could lead to serious accidents, such as falling, suffocation or drowning.
The results of this study may well be of interest to Hong Kong traders and manufacturers who deal in the products concerned, as the Commission's findings may lead to the Commission mandating the European Standards Body, CEN, to prepare new safety standards. Indeed, each product file provides examples of products which shall be covered by a future standard; examples of products that shall be excluded from the scope of that standard; a description of the product concerned; a proposal for a definition of the product, the intended age or age-range of the child for the product; existing safety standards for the product; and existing national safety legislation outside the EU for the product.
Some selected products of interest to traders and manufacturers in Hong Kong and the mainland are as follows:
Children's clothing - i.e., clothes or garments for children which are textile fabrics and intended to be worn by children from birth to 5 years. Products which are excluded from the scope of the study were: shoes, boots and similar footwear, toy disguise costumes and sportswear generally worn for a limited period under supervision of sports trainers.
While a number of standards already exist for children's clothing, it was considered that there are hazards which relate to clothing or garments worn by children under 5 years of age which have not been addressed in these existing standards. Accordingly, the study found that a number of risks are associated with children's clothing, in particular: strangulation hazards due to drawstrings and protruding parts of the garment, snagging hazards due to toggles, cords, etc., choking hazards due to detachable parts on children's clothes, chemical hazards and flammability hazards.
Given the extensive existing standards, the study proposes that a standard should be mandated to ensure that "articles shall not jeopardize the safety or health of children and carers when they are used as intended or in a foreseeable way, bearing in mind the behaviour of children." More particularly, the standard shall ensure that labels on articles or on their packaging and the instructions for use which accompany them shall draw the attention of users or their carers to the inherent hazards and risks or harms involved in using the articles and the ways to avoid them.
The proposed specific safety requirements for children's clothes are as follows:
Chemical requirements - children's clothing shall comply with relevant Community legislation.
Fire and thermal properties - children's clothing must not constitute a dangerous flammable element. Therefore, they must be composed of materials which fulfil the following conditions:
they do not burn if directly exposed to a flame, spark or other potential seat of fire;
they are not readily flammable and the flame goes out as soon as the fire cause disappears and, if they do ignite, they shall burn slowly and present a low rate of spread of the flame; and
they do not release molten drips.
To prevent hyperthermia, material used in children's clothing shall be adapted to the conditions of use (outdoor use, indoor use and seasonal use) and design of clothing shall permit sufficient ventilations of the children's mouth and nose.
Children's seat boosters - i.e., devices designed to be placed on the seat base of regular chairs and which are intended to elevate the child to a table, to be seated with adults. The study provides pictorial examples of booster seats to be covered by a future standard. It also sets out examples of products that were excluded from the scope of the study, namely: children's seat boosters to be used for transport in cars (which are dealt with specifically under EU legislation), table chairs (also referred to as hook-on-seats which are designed to be attached to a table by a locking device and which are already the subject of standard "EN 1272 Table mounted chairs - Safety requirements and test methods"), seats designed for floor level use only, chair mounted seats designed to be attached to a regular chair, high chairs (which are already the subject of standard "EN 14988 Children's high chairs"), boosters to be placed under the legs of an infant chair to elevate, and textile pouches attached to the back of the adult chair designed to restrain children from sitting on a regular chair (as these are designed to seat children but not to elevate them to the dining table).
The study found that the main risks associated with children's seat boosters are: entrapment in folding products, entrapment of fingers and limbs in gaps, falls and strangulation. The study proceeds to set out specific safety requirements which any future standard should follow, including fire and thermal properties (e.g., children's seat boosters must not constitute a dangerous flammable element in the child environment), falling hazards (e.g., children's seat boosters shall provide sufficient restraint of the child to prevent falling from it) and entanglement hazards (e.g., there shall be no cord and ribbons on the booster seats that can entangle a child's head).
Suction cups - i.e., a device with one side having a partly spherical shape, made of flexible material that can be attached to a flat surface when pressed against it due to the creation of a vacuum. This study also provides pictorial examples of suction cups to be covered by a future standard. There are no specified exemptions from the study.
While requirements for suction cups belonging to toys were introduced some years ago following a fatal accident in France, where a detached suction cup from a car window shade caused suffocation, there are no standards specifying requirements for suction cups which are used in child use and care articles and other non-child products which may pose a threat to the safety of children. There are also no requirements for suction cups used in car window shades. Therefore, the study recommends a standardisation mandate (under the EU Directive on general product safety), concerning requirements for suction cups in child use and care articles, as well as in other products used by young children and in other non-child products containing suction cups.
The main risks associated with suction cups are choking when the child detaches the suction cups from the product and puts it into its mouth. The study sets out specific safety requirements including the following: suffocation hazards (e.g., design and dimensions of the suctions cups shall not permit the suction cups to create a suffocation hazard by obstruction of both nose and mouth, for children up to 18 months), structural integrity (e.g., material used for the manufacturing of suction cups shall have characteristics so that the suction cups keep their fitting performances during the lifetime of the product) and specific warnings for the article (e.g., if release of the suction cup can result in a hazardous situation such as for bath rings, adequate information shall be given for the fitting of the suction cups on appropriate surfaces). Suction cups that can develop a force sufficient to create injury on a child shall bear a warning that they shall not be used in play by children.
Hong Kong's manufacturers and traders may be interested in consulting the full project results, as they are clear indicators for future standard mandates. The full project results can be found via the following link, under the reference "The individual fiches of the 20 products are available here":
