As mentioned in our previous legal alert dated October 6, 2016, the Toy Safety Regulation was published in the Official Gazette on October 4, 2016 and will enter into force on April 4, 2017, following the six-month transition period. As of April 4, 2017, toy manufacturers, importers and sellers will be subject to the requirements under the Toy Safety Regulation. The Toy Safety Regulation and its annexes are available at here (in Turkish).
Background
The new Toy Safety Regulation replaces the existing Toy Regulation, imposes new restrictions on the composition of toys and prohibits the use of certain components in toys. As the single piece of comprehensive regulation under Turkish law on toys, the Toy Safety Regulation carries a significant importance for toy manufacturers, importers and sellers. The Toy Safety Regulation introduces new restrictions, including the following:
- The prohibition of 55 types of allergenic scents, including fig leaf, ethyl acrylate, benzyl cyanide and cyclamen alcohol;
- 11 allergenic scents (farnesol, lilial, and anisyl alcohol, etc.) should be explicitly mentioned on the label or packaging of the toy, or on a side brochure along with the toy, if one or more of these scents are contained in the composition of the toy in an amount exceeding 100 mg/kg; and
- The use of 19 types of metals, including chrome, mercury and manganese, is limited to certain amounts in the composition of toys.
Actions to Consider
Toy manufacturers, importers and sellers should carefully review the Toy Safety Regulation and take the necessary actions to ensure compliance with the new requirements by April 4, 2017.
