Toy Industries of Europe (TIE)

Toy Industries of Europe (TIE) welcomes the opportunity to contribute to the Call for Evidence on a Circular Economy Act. To fully exploit the potential of circular economy, TIE calls on the European Commission to develop a comprehensive Act that respects sectoral needs, guarantees harmonised rules in all Member States, consolidates rights and duties of all actors involved and corrects distortions.

This submission focuses on four areas where we consider the Commissions intervention to be both legally well-founded and practically necessary: The unauthorised use of toy IP in AI training data, and the transparency and remuneration gaps this creates; The risk of AI-enabled imitation of toy characters and designs at scale; The inadequacy of existing enforcement mechanisms against digital forms of IP infringement…

We are grateful for the opportunity to comment on the draft Implementing Act and have provided feedback in the attached. We hope that the Act can: -Ensure the regulation is properly adapted to the requirements of the Toy Safety Regulation. -Clarify the possibility of the bulk registration of DPPs. -Ensure that access rights for bad actors can be revoked.

We thank the Commission for the chance to provide feeedback on this document. We have one small suggestion for an inclusion that could help manufacturers with the rising cost of compliance. The regulation does not give a transition period for switching between the RED cybersecurity standards and the new standards created under the CRA.

Toy Industries of Europe (TIE) agrees with the Commissions assessment that there is a need to accelerate standard development while ensuring inclusiveness. We ask that the revision of the regulation concentrates on solving identified shortcomings in the standardisation process instead of turning to other mechanisms that may not offer the same level of inclusiveness, legal certainty, or stakeholder consensus.

Toy Industries of Europe (TIE) welcomes the opportunity to provide feedback to the Draft Implementing Regulation laying down rules for the application of Article 24.1 of Regulation (EU) 2024/1781, also known as Ecodesign for Sustainable Products Regulation (ESPR). Please find our comments in the enclosed document.

The Toy Industries of Europe (TIE), welcomes the chance to comment on the draft Implementing Regulation detailing the label required by Regulation (EU) 2023/1542 concerning batteries and waste batteries (EUBR). Unfortunately, we are concerned that this draft legislation lacks the necessary regulatory clarity, is not technically feasible and runs counter to the Commissions simplification efforts, resulting in new…

Toy Industries of Europe strongly believes there is a need to address the lack of enforceability of product rules on online platforms. To ensure there is an economic operator to enforce against, enhanced trader and responsible person verifications are important and need to go hand in hand with possibilities to hold online platforms accountable (in certain specific cases) as economic operators for illegal products…

Toy Industries of Europe (TIE) are grateful for the opportunity to comment on the Commissions proposed restriction on childcare articles under the REACH Regulation. Since toys are a product category that is adjacent to childcare articles, and in some cases, products may sit in a grey zone between the two, it is important to clarify that toys are entirely covered by requirements in specific legislation and are out of…