Toxic Chemicals in Toys andChildren’s Products: Limitations ofCurrent Responses andRecommendations for Governmentand IndustryM O N I C A B E C K E RMonica Becker & Associates Sustainability Consultants,Rochester, New York

S A L L Y E D W A R D SLowell Center for Sustainable Production, University ofMassachusetts, Lowell, Massachusetts

R A C H E L I . M A S S E YMassachusetts Toxics Use Reduction Institute, University ofMassachusetts, Lowell, Massachusetts

Introduction

In June 2007, RC2 Corporation, manufacturer of a popularline of brightly painted wooden trains, recalled more than1.5 million units after learning that they violated the U.S.government standard for lead (Pb) in paint. The U.S.Consumer Product Safety Commission (CPSC) warnedparents that children should stop using the toys immediately(1). This was not an isolated incident; in 2007, over 17 milliontoys were recalled because they violated the federal Pb paintstandard (2). In January 2010, the CPSC recalled 55,000 unitsof children’s costume jewelry that contained high levels ofcadmium (Cd) (3). In June 2010, 12 million promotionaldrinking glasses sold at McDonald’s were recalled because

the painted coating contained Cd (4). Again, consumers wereadvised to stop using the product immediately.

The 2007 recalls brought attention to the problem of toxicchemicals in toys and other children’s products and the 2010recalls have been a reminder that this problem is yet to besolved. While violations of existing regulatory standards mayhave garnered the most press attention, they are merely thetip of the iceberg: for many other toxic chemicals, noregulatory standards are in place.

Since 2007, a variety of activities have been undertakento address the problem of toxic chemicals in toys andchildren’s products. Government responses include regula-tory measures to increase companies’ accountability, re-strictions on the use of certain toxic chemicals, and disclosurerequirements. Nonprofit sector efforts are aimed at providinginformation to consumers, advocacy to support broadlegislative reform, and development of an eco-label certi-fication program for toys. The toy industry in the U.S. hasfocused primarily on developing a conformity assessmentsystem to ensure that toys comply with existing U.S.regulations and standards.

While these initiatives are positive developments, muchof the response to the “toxic toys” crisis has been reactiveand piecemeal. Taken as a whole, these responses have notbeen sufficient to ensure that toys and children’s productsare safe. This article reviews recent efforts to address toxicchemicals in toys and offers recommendations for furtheraction by government and industry.

Why toxic chemicals in toys are a serious concernToxic exposures in children are a significant concern becauseof a number of factors, including a higher metabolic rate andgreater surface area to weight ratio than adults, immaturityof organ systems, and rapid growth and development oforgans and tissues such as bone and brain. Children’sexposure also differs from that of adults because childrendrink more fluids, eat more food, and breathe more air perkilogram of body weight. Children also have many years aheadto develop diseases with long latency periods (5). Youngchildren’s frequent hand to mouth activity creates a pathwayfor toxic chemicals in toys and other products to enter thebody. Children receive multiple low dose exposures dailyfrom a variety of products with which they come into contact,in addition to chemicals in household dust and the outdoorenvironment.

Table 1 lists some of the toxic chemicals found in toysand children’s products, describes exposure pathways, andincludes the current status of U.S. federal regulations.

Toys and other products intended specifically for childrenare one category of a much larger set of consumer productsthat expose infants and children to toxic chemicals, such aspersonal care products, furniture, and food containers. Thisarticle focuses on toys and other children’s products becausethey are specifically intended for this vulnerable population.

Why are there toxic chemicals in toys?There are two major reasons why toys contain toxic chemicals:lack of regulation and violation of existing regulations. This

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latter problem results in part from the complexity of globalproduction systems.

Regulatory gaps. The U.S. Environmental ProtectionAgency (EPA) lists over 80,000 chemicals in its ToxicSubstances Control Act (TSCA) inventory, but few have beenadequately tested for safety (10). Under TSCA, extensivehazard and exposure data are needed before EPA can act torestrict the use of chemicals. Historically, even when the linkbetween exposure to a chemical and illness or injury is welldocumented, EPA has done little to restrict its use (11). It iswidely recognized that TSCA is outdated and EPA andadvocacy groups are pressing for legislative reform (12). Otherfederal agencies are also increasingly concerned about toxicchemicals in the environment (13).

In principle, the CPSC has the authority to regulatetoxic chemicals in products, but in practice the CPSC’sreach has been limited (14). Under the Federal HazardousSubstances Act (FHSA), the presence of a toxic substance

in a product is not a sufficient condition for labeling orbanning the substance. FHSA requires application of arisk-based determination of “substantial personal injuryor substantial illness” resulting from exposure (15).Companies are responsible for making this determination,using general guidelines provided by CPSC but are notcompelled to generate the relevant exposure and dose-response information that would form the basis for sucha determination.

With regard to toys specifically, safety requirements inthe U.S. and other industrialized countries have focusedprimarily on mechanical safety such as preventing choking,laceration, or other injuries. As choking hazards remain aleading cause of toy-related injuries, this is an importantarea of continued focus (16). Until recently, there has beenlittle focus on chemicals in toys. Under current regulations,the CPSC restricts just fourteen chemicals in toys, includingeight heavy metals and six phthalates (17).

TABLE 1. Examples of Toxic Substances in Toys and Other Children’s Products

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Why is cadmium in children’s jewelry?In early 2010, researchers found high levels of Cd in popularcostume jewelry intended for children. The CPSC issued astrong message advising parents to remove the product fromchildren to prevent harm (18). When the news became public,some large retailers reacted quickly and removed these itemsfrom their inventories.

Both changes in international markets and regulatory gapscontributed to this situation. Until 2008, 75% of Cd produced inChina had been used for manufacturing nickel-cadmium(NiCd) batteries (19). In September 2008, EU legislationrestricting the use of Cd in batteries came into force. TheChinese government eliminated tax rebates for Cd batteries,causing financial difficulties for exporters (20). As demand forNiCd batteries dropped, the price of Cd decreased.

With the regulatory spotlight on lead in children’s products,some manufacturers turned to cadmium as a substitute. Thereare no U.S. federal regulations that that limit the use of thistoxic metal in children’s jewelry or require labeling of productscontaining Cd. The CPSC currently limits cadmium in children’stoys to 75 ppm and is working on new rules to limit the metal’spresence in all children’s products, including jewelry.

Complex global supply chains. Toy production andconsumption occur in a global system characterized by large,complex supply chains with constant downward pressureon prices. In many cases, product design and marketing occurprimarily in developed countries, with manufacturing out-sourced overseas. Demand for low cost products createspressure for companies to externalize environmental andsocial costs, resulting in unsafe working conditions, envi-ronmental pollution, and a drive toward using the cheapestand often toxic materials.

Even when regulations are in place, a lapse in supplychain management can lead to problems on a large scale.For example, Mattel, the largest toy company in the world,recalled over 2 million toys in 2007 for violation of the U.S.Pb paint standard (21). In its investigation, Mattel discoveredthat several contractors had purchased leaded paint fromsuppliers that had not been certified by Mattel (22). Leadedpaint, used widely in China for industrial applications, is upto one-third less expensive than nonleaded paint (23).

Responses to toxic chemicals in children’s products1. Regulatory responses. Following the well-publicizedrecalls of 2007, public demand for stronger assurance of toysafety led to the enactment of the 2008 U.S. ConsumerProduct Safety Improvement Act (CPSIA). The law amendedthe outdated Consumer Product Safety Act of 1972. The CPSIAsignificantly increases CPSC funding and enforcementauthority. It requires manufacturers to put tracking labelson children’s products including information about themanufacturer, production date, and batch to make it easierto track unsafe products to their sources; makes mandatorythe requirements of the American Society for Testing andMaterials toy safety standard (ASTM F963) (24) and requiresthat testing of children’s products be conducted by accreditedthird-party laboratories (25).

Yet the CPSIA authority to address toxic chemicals in toysis still quite limited. While it sets stricter standards for Pband restricts six phthalates in children’s products, it doesnot address the larger universe of unregulated or under-regulated chemicals in children’s products (26).

The EPA has recently stepped up its efforts to address theproblem of toxic chemicals in commerce and some of theseefforts may have implications for toxic chemicals in children’s

products. Among other activities, the agency has developedaction plans for a number of chemicals, outlining futureregulatory action (27). For example, EPA’s Phthalates ActionPlan notes concern about children’s exposure and identifiesthis as an area for further study and regulatory action (28).

The EU recently overhauled its 20-year-old Toy SafetyDirective. In contrast to the CPSIA, the Directive takes a morecomprehensive approach to addressing toxic chemicals intoys, prohibiting carcinogens, mutagens, and reproductivetoxicants (CMRs) in toys. It also sets new limits for 19substances, some of which were not previously regulated,and limits the use of allergenic fragrances. The EU Directiverequires manufacturers to conduct a safety assessment foreach toy before it is placed on the market, including ananalysis of chemical hazards that the toy may present andan assessment of potential exposure to such hazards. Everytoy must bear a marking indicating that it meets theserequirements (29).

European consumer advocates are concerned that certainprovisions in the law will allow manufacturers to continueto use toxic materials in toys (30). The revised Directive allowsmanufacturers to self-certify, rather than requiring third-party certification of toys. In addition, while the law prohibitsCMRs in toys, exemptions will be granted if these substancesare inaccessible to children; no suitable alternative exists; ora scientific committee determines that the use is safe.

Companies manufacturing and selling toys in Europe arealso subject to the EU’s comprehensive chemicals policyknown as REACH (Registration, Evaluation, and Authorizationof Chemicals). Under REACH, companies must disclose thepresence of chemicals in their products if the EuropeanChemicals Agency has identified and included the chemicalson its “Candidate List” of “Substances of Very High Concern”and if the chemicals are present in a product at a level above0.1 wt % (31). To date, 38 chemicals are on this list, withmore expected to be added over time (32).

In the U.S., a number of state governments have adoptedlegislation to ban specific chemicals of concern, such as lead,phthalates, and bisphenol A (BPA), in children’s products,and to increase transparency about the presence of toxicchemicals in these products. For example, Maine andWashington adopted legislation in 2008 that, among otherprovisions, requires companies to submit data to the stateon toxic chemicals in children’s products (33, 34). These lawsrequire each state to create a list of chemicals of high concern.Maine has listed 1700 chemicals of high concern based ontheir inherent hazard; this list will be narrowed to identifypriority chemicals based on potential exposure. Manufactur-ers will be required to disclose to the state their use of prioritychemicals. In June 2010, Maine proposed designating BPAas a priority chemical. Washington recently issued a draft listof 66 priority chemicals (35).

In addition, some state governments are beginning torequire industry to conduct assessments to identify saferalternatives to chemicals of concern for specific applications.Under Maine’s legislation, a manufacturer or distributor ofa children’s product that contains a priority chemical maybe required to conduct an alternatives assessment. Draftregulations being developed by California’s Department ofToxic Substances Control Authority would also requirecompanies using a chemical of concern in certain productcategories to conduct an alternatives assessment (36). Tosupport these and related efforts, the Toxics Use ReductionInstitute at the University of Massachusetts Lowell is leadinga multistate initiative to develop consistent methodologiesfor assessing alternatives to toxic chemicals (37).

Prior to this new wave of legislative efforts, some statesalready had programs in place to increase transparency abouttoxic chemicals in consumer products, including toys.California’s Safe Drinking Water and Toxic Enforcement Act

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of 1986, more commonly known as Proposition 65, requiresbusinesses to notify consumers when a product containsany chemical that is “known to the state of California tocause cancer or reproductive toxicity (38).” Eight statesrequire companies selling mercury (Hg)-added products tosubmit detailed product information to a centralized database(39).

Finally, efforts to gain more information about toxicchemicals in toys may benefit from a new project, led by theUnited Nations Environment Program (UNEP) under theStrategic Approach to International Chemicals Management(SAICM), to form a harmonized international informationsystem on chemicals in products. In 2009, UNEP conducteda global survey of stakeholders and identified toys andchildren’s products as a high priority sector for UNEP’scontinued work (40).

2. Nongovernmental responses. Since 2007, two U.S.organizations have worked to fill information gaps by creatingweb-based systems to give consumers information onchemicals in toys and other products. The Michigan-basedEcology Center (41) tests toys and other consumer productsfor the presence of six chemicals that can be detected withan X-ray fluorescence (XRF) sensor: Pb, Cd, chlorine (Cl),arsenic (As), bromine (Br), and Hg. The database providesa rating (high, medium, or low concern) for each product.

GoodGuide provides information on the environmental,social, and health performance of products and companiesby integrating information from a variety of data sources.GoodGuide provides information on more than 65,000products, including toys, food, and household and personalcare products. It provides both a summary score for health/social/environmental attributes and individual scores so thatconsumers can focus on a particular attribute (42).

In 2009, EcoLogo, an environmental certification orga-nization, launched a public stakeholder process to developan eco-label for toys (43). This standard, to be finalized byDecember 2010, will consider the entire product life cycle indetermining criteria for safe, healthy, and environmentallysustainable toys. These criteria will provide valuable designguidance for manufacturers that choose to lead in this arena.

3. Industry responses. The leading U.S. trade group fortoy manufacturers, the Toy Industry Association, has createdthe Toy Safety Certification Program, designed to ensure thattoys sold in the U.S. conform to the requirements of theCPSIA and the toy safety standard, ASTM F963. This programis valuable to manufacturers as it provides a consistentevaluation method and is designed to minimize testing costs.It requires a hazard/risk analysis in the design stage, factoryaudits, and production sample testing. However, it does notgo beyond ensuring compliance with existing safety standards.

Some small and medium-sized toy companies are takingleadership in developing environmentally sustainable toys.The Eco-Toy Alliance, a partnership of four small toycompanies, has created a Web site to educate consumersabout the attributes of eco-friendly toys and market theirproducts (44). This may signify a trend among smaller andstart-up companies to use green product features to theirstrategic advantage. In February 2010, the New York ToyFair, one of the world’s largest toy trade shows, included an“earth-friendly product zone” for the first time.

The company World Environmental Regulatory Compli-ance Solutions (The WERCS) has developed a tool called theGreenWERCS Chemical Screening Tool that evaluates chemi-cal products such as paints and cleaning products for humanand environmental health risks and scores products on thisbasis. The WERCS keeps formulation data confidential butprovides retailers with information on chemical hazards. Inprinciple, retailers can use this information to comparecompeting products and encourage suppliers to substitutesafer ingredients for harmful ones (45). Although the Green-

WERCS tool is not currently used for toys, this approachcould be applied to children’s products. Business-to-businesstransparency initiatives may prove to be powerful drivers ofchange if retailers use this information to select greenerproducts and motivate their suppliers to redesign products.

Some large retailers are working with suppliers to definedesign elements for eco-friendly toys and in some cases tocreate private label products that meet these criteria. Forexample, in March 2008 Toys R Us announced a new line ofeco-friendly toys, including those made with FSC certifiedwood and organic cotton (46). While it is not clear howretailers enforce requirements, these actions signal thepotential power of the retail sector to drive market changes.

Recommendations for government and industryWhat does the U.S. government need to do? New regulationson individual chemicals have had some effect on toys soldin the U.S. CPSC recalls for Pb in toys have decreasedsignificantly, from over 17 million units in 2007, to 1.3 millionin 2008, to approximately 110,000 in 2009 (47). However,eliminating toxic chemicals in children’s products is still adistant goal.

With over 80,000 chemicals in commerce, it is clear thata chemical-by-chemical regulatory approach cannot solvethe problem. A solution will require significant policy changes(48). Four key elements should be part of these improvements.

1. Ban or restrict the use of chemicals with well-documented toxicity in toys and other children’s products. Ata minimum, these include persistent, bioaccumulative, andtoxic chemicals (PBTs), carcinogens, mutagens, and repro-ductive toxicants (CMRs), neurotoxicants, and endocrinedisruptors. To be effective and avoid unintended conse-quences, such restrictions must delineate categories ofchemicals rather than simply regulating individual toxicchemicals. The EU’s approach to CMRs in the Toy SafetyDirective may provide a model.

2. Ensure consumers’ “right to know” about toxic chemicalsin children’s products. The federal government should developrequirements for labeling products with information abouttoxic constituents, as well as submission of data to centralizeddatabases.

In addition to empowering consumers to protect them-selves, transparency changes the marketplace. Transparencyrequirements can motivate manufacturers to change theirpractices to avoid embarrassing disclosures and maintainmarket share (49). For example, California’s Proposition 65has motivated many companies to reformulate or redesignproducts to eliminate or reduce the presence of a toxicchemical (50, 51).

3. Require chemical manufacturers to generate and dis-close basic toxicity information for all chemicals. Responsi-bility for demonstrating the safety of chemicals should restwith chemical manufacturers, rather than government.Application of this principle is needed to improve the safetyof children’s products and consumer products in generaland is at the core of the EU’s REACH legislation. Currentwork to implement these new requirements in the EU canserve as a head start for industry and regulators in the U.S.The Toxic Chemicals Safety Act, introduced in Congress inJuly 2010, includes a requirement for disclosure of chemicalingredients, with protection of confidential business infor-mation (52).

4. Promote the design and development of safer children’sproducts. The federal government should provide incentivesto encourage manufacturers to develop safer chemicals,materials, and products, by increasing its support of greenchemistry and green design research and development inindustry and academia. The EPA’s Green Chemistry andDesign for Environment programs should be expanded. Inaddition, the federal government should actively support

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the work of states that are working to develop consistentmethodologies for alternatives assessment of chemicals.

What does the toy industry need to do? In parallel withefforts by government to improve regulation of chemicals intoys, there are significant opportunities for the toy industryto take proactive measures.

1. Identify chemicals of concern and establish robustsystems to test for these chemicals. One important step forwardfor the toy industry would be to develop a list of chemicalsof concern that are found in children’s products. Thisinformation would enable the toy sector to be proactive ineliminating these chemicals where safer alternatives areavailable, and jointly to pursue research on safer substituteswhere alternatives do not yet exist. Many other sectors,including electronics, apparel (53), and automotive (54), haveworked together to develop lists of substances of concern,and have created systems for improving information flowabout chemicals throughout their large and complex globalsupply chains.

2. Engage openly with stakeholders. It would be usefulfor the industry to interact more directly with all of itsstakeholders, including children’s environmental healthadvocates, to address concerns about toxic chemicals. Oneavenue for this engagement would be participation in theBusiness-NGO Working Group, a collaboration of businessleaders from leading companies and nongovernmentalorganizations that are working together to encourage theuse of safer chemicals in consumer products (55). This groupis convened by the nonprofit organization Clean ProductionAction. The Green Chemistry and Commerce Council, anetwork of some 100 firms and other organizations com-mitted to developing safer chemicals and materials, convenedby the Lowell Center for Sustainable Production at theUniversity of Massachusetts Lowell, is another valuableresource (56).

3. Develop a sustainability roadmap. The toy industryshould develop a roadmap for the development of sustainablechildren’s products. Eliminating hazardous chemicals fromchildren’s products, while a critical goal, does not ensurethat these products are safe, healthy, and environmentallysound throughout their life cycles. Numerous reports pub-lished over the past decade by advocacy groups and industryauditing organizations have documented unhealthy andhazardous working conditions in toy factories (57, 58).

As a place to start, the toy industry can use the criteriabeing developed by environmental certification organizationsto encourage companies to design and manufacture saferand greener products. Additional tools and resources arealso available (59). For example, the Lowell Center forSustainable Production has developed a tool for productdesigners and manufacturers to help evaluate environmental,social, and economic impacts of existing products and todesign new products that minimize these impacts (60). Thisframework can be used to redesign products and productionsystems in advance of new regulations.

The road aheadConcern over the problem of toxic chemicals in toys isgrowing. Although significant action has been taken bygovernment, industry, and the advocacy community, newrevelations make it clear that the problem has yet to be solved.The recent findings on Cd in children’s jewelry and otherchildren’s products have again ignited passions and aretriggering new, narrowly focused federal and state legislativeproposals in the U.S. (61).

New efforts to solve this problem would benefit from abetter understanding of the root causes, a clear view of theroles of government, manufacturers, and retailers, and anawareness of the constructive role that the nonprofit sector

can play. Effective regulation is an essential precondition,necessary to establish an acceptable baseline level of safetyfor product manufacturers, as well as for the governmentagencies that are responsible for enforcing safety standards.The road ahead will certainly be challenging. However, untilsignificant changes in policy and practice occur, consumerscannot be confident that products they purchase for childrenare safe, healthy, and environmentally sustainable.

Monica Becker has been an independent consultant for the past 2years, working with government, industry, and academic organiza-tions. Consulting contracts during this time were with: the GreenChemistry and Commerce Council based at the University of Mas-sachusetts Lowell; Green Depot (an on-line retailer of green products);Harris Corporation; United Nations Environment Programme; theNew York Industrial Retention Network and the Rochester Instituteof Technology. Prior to that Ms. Becker held management positionsat the Rochester Institute of Technology, Golisano Institute forSustainability for 10 years. Sally Edwards is a Research Associate atthe Lowell Center for Sustainable Production at the University ofMassachusetts Lowell. Her work is currently funded by the New YorkCommunity Trust and the Merck Family Fund. She is also serving asan advisor to EcoLogo, an environmental certification organizationthat is developing an eco-label for toys. She receives an honorariumfor this work from TerraChoice, the company that administers theEcoLogo program. In her work to promote the development ofsustainable children’s products, Dr. Edwards interacts with manymanufacturers and retailers. In 2009, as a contractor to the Blu Skyesustainability consulting firm she prepared slide presentations on toysustainability issues and design priorities for Walmart toy merchan-disers to present to their major toy suppliers in China.Rachel Masseyis Policy Analyst and Policy Program Manager at the MassachusettsToxics Use Reduction Institute at the University of MassachusettsLowell. The Institute’s work is funded by the Commonwealth ofMassachusetts under the Toxics Use Reduction Act. Ms. Massey hasalso received project funding from the Swedish Chemicals Agency andthe United Nations Environment Programme. Please address cor-respondence regarding this article to monica@monicabecker.com.

AcknowledgmentsThe authors thank Janet Hutchins for significant contribu-tions to researching and drafting this article; Ken Geiser, JoelTickner, Yve Torrie, and Cathy Crumbley for detailedcomments; and Ann Blake for the photo.

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