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Dangerous goods in the children's room. Why toys are increasingly appearing on dangerous goods lists.

Increasingly, not only consumer advocates but also safety experts in the logistics industry are warning against dangerous toys. This often concerns cheap toys made in China. The vast majority of goods manufactured in China are no worse than products from other regions of the world. But since around 80 percent of toys sold in the USA and Europe today come from China, most dangerous toys also come from this country.

Dangerous toys are those that contain dangerous electronic components, batteries in an unsafe state of charge or even toxic chemicals. The toys are shipped directly from China to Europe or the USA, even though they do not comply with the regulations for safe toys in the recipient countries. Declaration regulations for transportation and import are often violated.

The gateway for dangerous toys is the de minimis rules

Products that are purchased directly online are often not checked on their way from the manufacturer to the consumer, at least not if their value is below the threshold that requires an inspection. Such inexpensive products are subject to special rules by customs and border authorities. For imports into the USA, these are the so-called “de minimis” rules; for imports into the European Union, the rules for “low-value consignments” in accordance with Articles 23 and 24 of the Customs Duty Exemption Regulation. These rules stipulate that goods with a value below a certain limit may be traded duty-free. These packages of goods are then generally not checked on import.

For the USA, the limit for goods that fall under the de minimis rule is currently 800 US dollars. Any package whose contents are declared as cheaper is generally imported without controls. A value limit of 150 euros applies to the European Union. Goods with a lower value are generally not checked and can be imported duty-free, but are still subject to VAT. The only exceptions to this are alcohol, tobacco products and perfumes.

Year after year, trade in duty-free goods is increasing internationally. This is due to the growing popularity of online shopping, aggressive marketing by international sellers and, last but not least, the incomplete laws in the countries of destination.

For the USA alone, the number of international shipments that are exempt from customs controls due to their low value has risen from 140 million a year to almost one and a half billion a year in the last ten years. Today, around four million low-value parcels reach the USA every day, largely without customs control, including numerous toys. (Source: compactmag)

Fraudsters like to bypass customs

These generous import rules are of course also exploited by fraudsters. Products are often imported under the de minimis rules that do not comply with the legal regulations in the destination countries. Time and again, false statements are also made about the contents of consignments. For example, senders state that a consignment contains household goods, although it actually contains toys. In many regions, customs clearance for low-value household goods is even simpler than for toys. To avoid being checked, the value of the individual goods is understated by the manufacturer.

From January to July 2024, the US Consumer Product Safety Commission (CPSC) counted 1,020 violations of import regulations by US customs authorities. Around 800 of these related to toys. The toys for which violation notices were issued included games, baby activity boards, educational toys, children’s jewelry, building blocks, plastic riding toys, teething rings for babies and stuffed animals. (Source: U.S.PIRG Education Fund)

Fraud attempts also occur at the external borders of the European Union. An example from Belgium was investigated by journalists from the German television station SWR last spring:

“The Belgian regional airport in Liège is now one of the largest air freight hubs in Europe. More than one million small parcels arrive here from China every day. A large proportion of these go on to Germany. (…) Customs officer Murielle Mathieu checks a large square parcel from China. It is destined for a recipient in Bavaria. It was declared with a value of 54 euros, as ‘technical equipment’. When it is opened, a 4K projector costing 1,270 euros is revealed. An attempt at fraud, as is documented daily at Liège Airport. ‘This should not be registered as a package. The aim here is to save VAT and customs duties,’ says the customs officer. This is because parcels with a value of less than 150 euros do not have to pay customs duty on import in Europe.”

However, customs staff only carry out spot checks on duty-free imports. In 2023, the EU Commission counted two billion duty-free parcels imported into the EU. The EU authorities assume that 65% were false in order to save customs duties.

The random checks also give shippers the opportunity to place potentially unsafe products on the market. This often involves electronic goods and toys.

A well-known problem: lithium batteries are a fire hazard

We also encounter a well-known problem in toys: lithium batteries, which are a fire hazard. As long as batteries are handled with care, little can happen, but especially in cheap products, there is a great danger that savings have been made in the wrong place:

a) If a battery is damaged, air can enter the battery. If the electrolyte reacts with oxygen, this causes a short circuit and possibly a fire in the beautiful model car, perhaps during transportation or perhaps in the children’s room.

b) A lithium-ion battery should neither be fully discharged nor fully charged before transportation. Overcharging as well as excessive discharging of the battery can lead to decomposition of the electrolyte on the surface of the cathode, which leads to an increase in temperature in the battery. Overcharging releases too many lithium ions, which destabilizes the cathode. These excess ions form dendrites on the anode, which in the worst case can cause a short circuit. In the event of an over-discharge, copper ions can accumulate on the cathode surface, which can also cause a short circuit. This occurs when the copper conductors oxidize, as lithium ions are constantly being released from the anode.

c) Goods containing a lithium-ion battery must be transported on southern shipping routes protected from the effects of heat. If they heat up over several days at excessively high outside temperatures, spontaneous combustion may occur. However, if the shipper has misdeclared the goods simply to save on customs duties, the result is incorrect storage on the ship and ultimately a catastrophe – not in the nursery, but during transportation.

The manufacturers responsible are hard to pin down

Today. Logistics companies and online platforms such as Amazon, AliExpress and Temu are de facto importers of goods that are imported duty-free. However, they are hardly aware of the composition and potential risks that their goods may pose, especially as the large platforms often only serve as a marketplace for manufacturers that they themselves cannot control. In the event of damage, no one has access to the manufacturers – if they are known at all.

Following test purchases, Business Insider magazine pointed out that electronic toys distributed by Temu in Europe were being sold without the required CE marking. Various EU directives stipulate safety and health requirements for numerous products as minimum requirements that must not be undercut. The CE mark indicates that a product complies with these regulations and only with such a mark may it be sold within the European Union.

In 2023, the Swiss Toy Association tested toys purchased via the Chinese online platforms Temu and Shein. Fifteen out of 18 products failed the test. The test results for children’s finger rings, 3D stickers, cosmetics cases and silicone molds were more reminiscent of the contents description of chemistry lab kits than the toys mentioned here.

What to do?

The problem is not so much the lack of specifications for the production of safe toys and electronic products. The problem is the lack of controls on the import of low-value products at the borders. Combined with deliberate misdeclarations by criminal low-cost suppliers, this leads to the market being flooded with dangerous goods, including toys that belong in hazardous waste dumps and not in children’s bedrooms.

The EU is planning to abolish the €150 duty-free limit by 2028, which is expected to generate additional revenue of around €750 million per year, money that could be used to expand border controls. The US administration and the campaign team of the newly elected future US President Donald Trump are planning something similar with regard to the de minimis rules for imports into the USA. This would then also increase security in the logistics chains – and in children’s bedrooms.


© Illustrations Michael Kausch with AI for Leschaco.com

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