This document summarizes responses to toxic chemicals found in toys and children's products, and provides recommendations. It discusses how recalls in 2007 and 2010 brought attention to this issue, though existing regulations only address a small number of chemicals. A variety of government, nonprofit, and industry initiatives have sought to address the problem, but in an isolated manner. The document recommends more comprehensive action is still needed to ensure children's products are truly safe, given limitations in current regulations and oversight of global supply chains.

1. Toxic Chemicals in Toys and
Children’s Products: Limitations of
Current Responses and
Recommendations for Government
and Industry
M O N I C A B E C K E R
Monica Becker & Associates Sustainability Consultants,
Rochester, New York
S A L L Y E D W A R D S
Lowell Center for Sustainable Production, University of
Massachusetts, Lowell, Massachusetts
R A C H E L I . M A S S E Y
Massachusetts Toxics Use Reduction Institute, University of
Massachusetts, Lowell, Massachusetts
Introduction
In June 2007, RC2 Corporation, manufacturer of a popular
line of brightly painted wooden trains, recalled more than
1.5 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) warned
parents that children should stop using the toys immediately
(1). This was not an isolated incident; in 2007, over 17 million
toys were recalled because they violated the federal Pb paint
standard (2). In January 2010, the CPSC recalled 55,000 units
of children’s costume jewelry that contained high levels of
cadmium (Cd) (3). In June 2010, 12 million promotional
drinking glasses sold at McDonald’s were recalled because
the painted coating contained Cd (4). Again, consumers were
advised to stop using the product immediately.
The 2007 recalls brought attention to the problem of toxic
chemicals in toys and other children’s products and the 2010
recalls have been a reminder that this problem is yet to be
solved. While violations of existing regulatory standards may
have garnered the most press attention, they are merely the
tip of the iceberg: for many other toxic chemicals, no
regulatory standards are in place.
Since 2007, a variety of activities have been undertaken
to address the problem of toxic chemicals in toys and
children’s products. Government responses include regula-
tory measures to increase companies’ accountability, re-
strictionsontheuseofcertaintoxicchemicals,anddisclosure
requirements. Nonprofit sector efforts are aimed at providing
information to consumers, advocacy to support broad
legislative reform, and development of an eco-label certi-
fication program for toys. The toy industry in the U.S. has
focused primarily on developing a conformity assessment
system to ensure that toys comply with existing U.S.
regulations and standards.
While these initiatives are positive developments, much
of the response to the “toxic toys” crisis has been reactive
and piecemeal. Taken as a whole, these responses have not
been sufficient to ensure that toys and children’s products
are safe. This article reviews recent efforts to address toxic
chemicals in toys and offers recommendations for further
action by government and industry.
Why toxic chemicals in toys are a serious concern
Toxic exposures in children are a significant concern because
of a number of factors, including a higher metabolic rate and
greater surface area to weight ratio than adults, immaturity
of organ systems, and rapid growth and development of
organs and tissues such as bone and brain. Children’s
exposure also differs from that of adults because children
drink more fluids, eat more food, and breathe more air per
kilogramofbodyweight.Childrenalsohavemanyyearsahead
to develop diseases with long latency periods (5). Young
children’s frequent hand to mouth activity creates a pathway
for toxic chemicals in toys and other products to enter the
body. Children receive multiple low dose exposures daily
from a variety of products with which they come into contact,
in addition to chemicals in household dust and the outdoor
environment.
Table 1 lists some of the toxic chemicals found in toys
and children’s products, describes exposure pathways, and
includes the current status of U.S. federal regulations.
Toys and other products intended specifically for children
are one category of a much larger set of consumer products
that expose infants and children to toxic chemicals, such as
personal care products, furniture, and food containers. This
article focuses on toys and other children’s products because
they are specifically intended for this vulnerable population.
Why are there toxic chemicals in toys?
Therearetwomajorreasonswhytoyscontaintoxicchemicals:
lack of regulation and violation of existing regulations. This
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2. latter problem results in part from the complexity of global
production systems.
Regulatory gaps. The U.S. Environmental Protection
Agency (EPA) lists over 80,000 chemicals in its Toxic
Substances Control Act (TSCA) inventory, but few have been
adequately tested for safety (10). Under TSCA, extensive
hazard and exposure data are needed before EPA can act to
restrict the use of chemicals. Historically, even when the link
between exposure to a chemical and illness or injury is well
documented, EPA has done little to restrict its use (11). It is
widely recognized that TSCA is outdated and EPA and
advocacygroupsarepressingforlegislativereform(12).Other
federal agencies are also increasingly concerned about toxic
chemicals in the environment (13).
In principle, the CPSC has the authority to regulate
toxic chemicals in products, but in practice the CPSC’s
reach has been limited (14). Under the Federal Hazardous
Substances Act (FHSA), the presence of a toxic substance
in a product is not a sufficient condition for labeling or
banning the substance. FHSA requires application of a
risk-based determination of “substantial personal injury
or substantial illness” resulting from exposure (15).
Companies are responsible for making this determination,
using general guidelines provided by CPSC but are not
compelled to generate the relevant exposure and dose-
response information that would form the basis for such
a determination.
With regard to toys specifically, safety requirements in
the U.S. and other industrialized countries have focused
primarily on mechanical safety such as preventing choking,
laceration, or other injuries. As choking hazards remain a
leading cause of toy-related injuries, this is an important
area of continued focus (16). Until recently, there has been
little focus on chemicals in toys. Under current regulations,
the CPSC restricts just fourteen chemicals in toys, including
eight heavy metals and six phthalates (17).
TABLE 1. Examples of Toxic Substances in Toys and Other Children’s Products
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3. Why is cadmium in children’s jewelry?
In early 2010, researchers found high levels of Cd in popular
costume jewelry intended for children. The CPSC issued a
strong message advising parents to remove the product from
children to prevent harm (18). When the news became public,
some large retailers reacted quickly and removed these items
from their inventories.
Both changes in international markets and regulatory gaps
contributed to this situation. Until 2008, 75% of Cd produced in
China had been used for manufacturing nickel-cadmium
(NiCd) batteries (19). In September 2008, EU legislation
restricting the use of Cd in batteries came into force. The
Chinese government eliminated tax rebates for Cd batteries,
causing financial difficulties for exporters (20). As demand for
NiCd 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. There
are no U.S. federal regulations that that limit the use of this
toxic metal in children’s jewelry or require labeling of products
containing Cd. The CPSC currently limits cadmium in children’s
toys to 75 ppm and is working on new rules to limit the metal’s
presence in all children’s products, including jewelry.
Complex global supply chains. Toy production and
consumption occur in a global system characterized by large,
complex supply chains with constant downward pressure
onprices.Inmanycases,productdesignandmarketingoccur
primarily in developed countries, with manufacturing out-
sourced overseas. Demand for low cost products creates
pressure for companies to externalize environmental and
social costs, resulting in unsafe working conditions, envi-
ronmental pollution, and a drive toward using the cheapest
and often toxic materials.
Even when regulations are in place, a lapse in supply
chain 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 discovered
that several contractors had purchased leaded paint from
suppliers that had not been certified by Mattel (22). Leaded
paint, used widely in China for industrial applications, is up
to one-third less expensive than nonleaded paint (23).
Responses to toxic chemicals in children’s products
1. Regulatory responses. Following the well-publicized
recalls of 2007, public demand for stronger assurance of toy
safety led to the enactment of the 2008 U.S. Consumer
Product Safety Improvement Act (CPSIA). The law amended
theoutdatedConsumerProductSafetyActof1972.TheCPSIA
significantly increases CPSC funding and enforcement
authority. It requires manufacturers to put tracking labels
on children’s products including information about the
manufacturer, production date, and batch to make it easier
to track unsafe products to their sources; makes mandatory
the requirements of the American Society for Testing and
Materials toy safety standard (ASTM F963) (24) and requires
thattestingofchildren’sproductsbeconductedbyaccredited
third-party laboratories (25).
Yet the CPSIA authority to address toxic chemicals in toys
is still quite limited. While it sets stricter standards for Pb
and restricts six phthalates in children’s products, it does
not 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 the
problem of toxic chemicals in commerce and some of these
effortsmayhaveimplicationsfortoxicchemicalsinchildren’s
products. Among other activities, the agency has developed
action plans for a number of chemicals, outlining future
regulatory action (27). For example, EPA’s Phthalates Action
Plan notes concern about children’s exposure and identifies
this as an area for further study and regulatory action (28).
The EU recently overhauled its 20-year-old Toy Safety
Directive. In contrast to the CPSIA, the Directive takes a more
comprehensive approach to addressing toxic chemicals in
toys, prohibiting carcinogens, mutagens, and reproductive
toxicants (CMRs) in toys. It also sets new limits for 19
substances, some of which were not previously regulated,
and limits the use of allergenic fragrances. The EU Directive
requires manufacturers to conduct a safety assessment for
each toy before it is placed on the market, including an
analysis of chemical hazards that the toy may present and
an assessment of potential exposure to such hazards. Every
toy must bear a marking indicating that it meets these
requirements (29).
European consumer advocates are concerned that certain
provisions in the law will allow manufacturers to continue
to use toxic materials in toys (30). The revised Directive allows
manufacturers to self-certify, rather than requiring third-
party certification of toys. In addition, while the law prohibits
CMRs in toys, exemptions will be granted if these substances
are inaccessible to children; no suitable alternative exists; or
a scientific committee determines that the use is safe.
Companies manufacturing and selling toys in Europe are
also subject to the EU’s comprehensive chemicals policy
knownasREACH(Registration,Evaluation,andAuthorization
of Chemicals). Under REACH, companies must disclose the
presence of chemicals in their products if the European
Chemicals Agency has identified and included the chemicals
on its “Candidate List” of “Substances of Very High Concern”
and if the chemicals are present in a product at a level above
0.1 wt % (31). To date, 38 chemicals are on this list, with
more expected to be added over time (32).
In the U.S., a number of state governments have adopted
legislation 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 toxic
chemicals in these products. For example, Maine and
Washington adopted legislation in 2008 that, among other
provisions, requires companies to submit data to the state
on toxic chemicals in children’s products (33, 34). These laws
requireeachstatetocreatealistofchemicalsofhighconcern.
Maine has listed 1700 chemicals of high concern based on
their inherent hazard; this list will be narrowed to identify
priority chemicals based on potential exposure. Manufactur-
ers will be required to disclose to the state their use of priority
chemicals. In June 2010, Maine proposed designating BPA
as a priority chemical. Washington recently issued a draft list
of 66 priority chemicals (35).
In addition, some state governments are beginning to
require industry to conduct assessments to identify safer
alternatives to chemicals of concern for specific applications.
Under Maine’s legislation, a manufacturer or distributor of
a children’s product that contains a priority chemical may
be required to conduct an alternatives assessment. Draft
regulations being developed by California’s Department of
Toxic Substances Control Authority would also require
companies using a chemical of concern in certain product
categories to conduct an alternatives assessment (36). To
support these and related efforts, the Toxics Use Reduction
Institute at the University of Massachusetts Lowell is leading
a multistate initiative to develop consistent methodologies
for assessing alternatives to toxic chemicals (37).
Prior to this new wave of legislative efforts, some states
alreadyhadprogramsinplacetoincreasetransparencyabout
toxic chemicals in consumer products, including toys.
California’s Safe Drinking Water and Toxic Enforcement Act
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4. of 1986, more commonly known as Proposition 65, requires
businesses to notify consumers when a product contains
any chemical that is “known to the state of California to
cause cancer or reproductive toxicity (38).” Eight states
require companies selling mercury (Hg)-added products to
submitdetailedproductinformationtoacentralizeddatabase
(39).
Finally, efforts to gain more information about toxic
chemicals in toys may benefit from a new project, led by the
United Nations Environment Program (UNEP) under the
Strategic Approach to International Chemicals Management
(SAICM), to form a harmonized international information
system on chemicals in products. In 2009, UNEP conducted
a global survey of stakeholders and identified toys and
children’s products as a high priority sector for UNEP’s
continued work (40).
2. Nongovernmental responses. Since 2007, two U.S.
organizationshaveworkedtofillinformationgapsbycreating
web-based systems to give consumers information on
chemicals in toys and other products. The Michigan-based
Ecology Center (41) tests toys and other consumer products
for the presence of six chemicals that can be detected with
an X-ray fluorescence (XRF) sensor: Pb, Cd, chlorine (Cl),
arsenic (As), bromine (Br), and Hg. The database provides
a rating (high, medium, or low concern) for each product.
GoodGuide provides information on the environmental,
social, and health performance of products and companies
by integrating information from a variety of data sources.
GoodGuide provides information on more than 65,000
products, including toys, food, and household and personal
care products. It provides both a summary score for health/
social/environmental attributes and individual scores so that
consumers can focus on a particular attribute (42).
In 2009, EcoLogo, an environmental certification orga-
nization, launched a public stakeholder process to develop
an eco-label for toys (43). This standard, to be finalized by
December 2010, will consider the entire product life cycle in
determining criteria for safe, healthy, and environmentally
sustainable toys. These criteria will provide valuable design
guidance for manufacturers that choose to lead in this arena.
3. Industry responses. The leading U.S. trade group for
toy manufacturers, the Toy Industry Association, has created
the Toy Safety Certification Program, designed to ensure that
toys sold in the U.S. conform to the requirements of the
CPSIA and the toy safety standard, ASTM F963. This program
is valuable to manufacturers as it provides a consistent
evaluation method and is designed to minimize testing costs.
It requires a hazard/risk analysis in the design stage, factory
audits, and production sample testing. However, it does not
go beyond ensuring compliance with existing safety standards.
Some small and medium-sized toy companies are taking
leadership in developing environmentally sustainable toys.
The Eco-Toy Alliance, a partnership of four small toy
companies, has created a Web site to educate consumers
about the attributes of eco-friendly toys and market their
products (44). This may signify a trend among smaller and
start-up companies to use green product features to their
strategic advantage. In February 2010, the New York Toy
Fair, 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 the
GreenWERCS Chemical Screening Tool that evaluates chemi-
cal products such as paints and cleaning products for human
and environmental health risks and scores products on this
basis. The WERCS keeps formulation data confidential but
provides retailers with information on chemical hazards. In
principle, retailers can use this information to compare
competing products and encourage suppliers to substitute
safer ingredients for harmful ones (45). Although the Green-
WERCS tool is not currently used for toys, this approach
couldbeappliedtochildren’sproducts.Business-to-business
transparency initiatives may prove to be powerful drivers of
change if retailers use this information to select greener
products and motivate their suppliers to redesign products.
Some large retailers are working with suppliers to define
design elements for eco-friendly toys and in some cases to
create private label products that meet these criteria. For
example, in March 2008 Toys R Us announced a new line of
eco-friendly toys, including those made with FSC certified
wood and organic cotton (46). While it is not clear how
retailers enforce requirements, these actions signal the
potential power of the retail sector to drive market changes.
Recommendations for government and industry
WhatdoestheU.S.governmentneedtodo?Newregulations
on individual chemicals have had some effect on toys sold
in the U.S. CPSC recalls for Pb in toys have decreased
significantly, from over 17 million units in 2007, to 1.3 million
in 2008, to approximately 110,000 in 2009 (47). However,
eliminating toxic chemicals in children’s products is still a
distant goal.
With over 80,000 chemicals in commerce, it is clear that
a chemical-by-chemical regulatory approach cannot solve
theproblem.Asolutionwillrequiresignificantpolicychanges
(48).Fourkeyelementsshouldbepartoftheseimprovements.
1. Ban or restrict the use of chemicals with well-
documented toxicity in toys and other children’s products. At
a minimum, these include persistent, bioaccumulative, and
toxic chemicals (PBTs), carcinogens, mutagens, and repro-
ductive toxicants (CMRs), neurotoxicants, and endocrine
disruptors. To be effective and avoid unintended conse-
quences, such restrictions must delineate categories of
chemicals rather than simply regulating individual toxic
chemicals. The EU’s approach to CMRs in the Toy Safety
Directive may provide a model.
2. Ensureconsumers’“righttoknow”abouttoxicchemicals
inchildren’sproducts.Thefederalgovernmentshoulddevelop
requirements for labeling products with information about
toxicconstituents,aswellassubmissionofdatatocentralized
databases.
In addition to empowering consumers to protect them-
selves, transparency changes the marketplace. Transparency
requirements can motivate manufacturers to change their
practices to avoid embarrassing disclosures and maintain
market share (49). For example, California’s Proposition 65
has motivated many companies to reformulate or redesign
products to eliminate or reduce the presence of a toxic
chemical (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 rest
with chemical manufacturers, rather than government.
Application of this principle is needed to improve the safety
of children’s products and consumer products in general
and is at the core of the EU’s REACH legislation. Current
work to implement these new requirements in the EU can
serve as a head start for industry and regulators in the U.S.
The Toxic Chemicals Safety Act, introduced in Congress in
July 2010, includes a requirement for disclosure of chemical
ingredients, with protection of confidential business infor-
mation (52).
4. Promote the design and development of safer children’s
products. The federal government should provide incentives
to encourage manufacturers to develop safer chemicals,
materials, and products, by increasing its support of green
chemistry and green design research and development in
industry and academia. The EPA’s Green Chemistry and
Design for Environment programs should be expanded. In
addition, the federal government should actively support
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5. the work of states that are working to develop consistent
methodologies for alternatives assessment of chemicals.
What does the toy industry need to do? In parallel with
efforts by government to improve regulation of chemicals in
toys, there are significant opportunities for the toy industry
to take proactive measures.
1. Identify chemicals of concern and establish robust
systemstotestforthesechemicals.Oneimportantstepforward
for the toy industry would be to develop a list of chemicals
of concern that are found in children’s products. This
information would enable the toy sector to be proactive in
eliminating these chemicals where safer alternatives are
available, and jointly to pursue research on safer substitutes
where alternatives do not yet exist. Many other sectors,
including electronics, apparel (53), and automotive (54), have
worked together to develop lists of substances of concern,
and have created systems for improving information flow
about chemicals throughout their large and complex global
supply chains.
2. Engage openly with stakeholders. It would be useful
for the industry to interact more directly with all of its
stakeholders, including children’s environmental health
advocates, to address concerns about toxic chemicals. One
avenue for this engagement would be participation in the
Business-NGO Working Group, a collaboration of business
leaders from leading companies and nongovernmental
organizations that are working together to encourage the
use of safer chemicals in consumer products (55). This group
is convened by the nonprofit organization Clean Production
Action. The Green Chemistry and Commerce Council, a
network of some 100 firms and other organizations com-
mittedtodevelopingsaferchemicalsandmaterials,convened
by the Lowell Center for Sustainable Production at the
University of Massachusetts Lowell, is another valuable
resource (56).
3. Develop a sustainability roadmap. The toy industry
shoulddeveloparoadmapforthedevelopmentofsustainable
children’s products. Eliminating hazardous chemicals from
children’s products, while a critical goal, does not ensure
that these products are safe, healthy, and environmentally
sound throughout their life cycles. Numerous reports pub-
lished over the past decade by advocacy groups and industry
auditing organizations have documented unhealthy and
hazardous working conditions in toy factories (57, 58).
As a place to start, the toy industry can use the criteria
beingdevelopedbyenvironmentalcertificationorganizations
to encourage companies to design and manufacture safer
and greener products. Additional tools and resources are
also available (59). For example, the Lowell Center for
Sustainable Production has developed a tool for product
designersandmanufacturerstohelpevaluateenvironmental,
social, and economic impacts of existing products and to
design new products that minimize these impacts (60). This
framework can be used to redesign products and production
systems in advance of new regulations.
The road ahead
Concern over the problem of toxic chemicals in toys is
growing. Although significant action has been taken by
government, industry, and the advocacy community, new
revelationsmakeitclearthattheproblemhasyettobesolved.
The recent findings on Cd in children’s jewelry and other
children’s products have again ignited passions and are
triggering new, narrowly focused federal and state legislative
proposals in the U.S. (61).
New efforts to solve this problem would benefit from a
better understanding of the root causes, a clear view of the
roles of government, manufacturers, and retailers, and an
awareness of the constructive role that the nonprofit sector
can play. Effective regulation is an essential precondition,
necessary to establish an acceptable baseline level of safety
for product manufacturers, as well as for the government
agencies that are responsible for enforcing safety standards.
The road ahead will certainly be challenging. However, until
significant changes in policy and practice occur, consumers
cannot be confident that products they purchase for children
are safe, healthy, and environmentally sustainable.
Monica Becker has been an independent consultant for the past 2
years, working with government, industry, and academic organiza-
tions. Consulting contracts during this time were with: the Green
Chemistry 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; the
New York Industrial Retention Network and the Rochester Institute
of Technology. Prior to that Ms. Becker held management positions
at the Rochester Institute of Technology, Golisano Institute for
Sustainability for 10 years. Sally Edwards is a Research Associate at
the Lowell Center for Sustainable Production at the University of
Massachusetts Lowell. Her work is currently funded by the New York
Community Trust and the Merck Family Fund. She is also serving as
an advisor to EcoLogo, an environmental certification organization
that is developing an eco-label for toys. She receives an honorarium
for this work from TerraChoice, the company that administers the
EcoLogo program. In her work to promote the development of
sustainable children’s products, Dr. Edwards interacts with many
manufacturers and retailers. In 2009, as a contractor to the Blu Skye
sustainability consulting firm she prepared slide presentations on toy
sustainability issues and design priorities for Walmart toy merchan-
disers to present to their major toy suppliers in China.Rachel Massey
is Policy Analyst and Policy Program Manager at the Massachusetts
Toxics Use Reduction Institute at the University of Massachusetts
Lowell. The Institute’s work is funded by the Commonwealth of
Massachusetts under the Toxics Use Reduction Act. Ms. Massey has
also received project funding from the Swedish Chemicals Agency and
the United Nations Environment Programme. Please address cor-
respondence regarding this article to monica@monicabecker.com.
Acknowledgments
The authors thank Janet Hutchins for significant contribu-
tions to researching and drafting this article; Ken Geiser, Joel
Tickner, Yve Torrie, and Cathy Crumbley for detailed
comments; and Ann Blake for the photo.
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