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enforcement of CE regulations is causing problems for boardgames in EU

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This topic contains 24 replies, has 6 voices, and was last updated by  blinky465 4 months ago.

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  • #1379997

    tankkommander
    Participant
    2325xp

    ” So, the EU continues in its quest to suppress all the fun? Wonderful! ”

    Or an attempt to stop dangerous goods being sold to consumers. Toxic paint coatings, illegally logged wood being used for game pieces, that sort of thing.

    CE (or what used to be Kite Marked) based on the old British Standards on the whole. Why should KS toys and games be treated any differently to a game produced by any other Publisher?

    #1380001

    limburger
    Participant
    7407xp

    Certification only works if enforcing the standard is a bit more than checking the package for the CE stamp … and given the volume of imported goods I seriously doubt they actually check for toxic chemicals (unless it stinks like a sewer … ).

    Goods sold directly to consumers were never checked for CE certification (or at best only random spot checks).
    This has allowed companies that weren’t planning to sell their product in the EU to skip this step (thereby saving money and paperwork).

    Never mind that the entire CE system is for complaints *after* shit has gone wrong, not before.
    If it was meant to be (consumer) safety then there would not be any self cerficication and we’d have the Chinese modus operandi.

    #1380082

    danlee
    Participant
    5808xp

    @limburger – it would never be possible to check every single good or even one of every product. Random checks are the only practical way to do it. If there is reason to suspect a given product the manufacturer or importer would be approached and expected to provide evidence all standards have been met to earn the CE mark. This could for example be a list of all chemicals used. If there is reason to doubt the list then the products might be tested.

     

    I feel I should stress I have no direct knowledge of toy safety standards, but I do know about electrical and explosion protection standards and how they are enforced. I’m extrapolating.

     

    A company selling a product outside the EU was never obliged to use the CE mark. The CE mark is only required for goods entering the EU common market (either manufactured within or imported from outside). The CE mark is a cornerstone of the single market as it is how the EU ensures everyone plays by the same rules and doesn’t have an unfair advantage (e.g. using cheap but toxic materials).

     

    The EU’s principle on safety is that standards are established to prevent incidents. By designing a product to meet CE mark requirements a manufacturer will have taken all reasonable steps to make the product safe, as that is how the standards are designed. Standards are reviewed and updated every decade or so to incorporate any industry changes or improved science/technology.

     

    This compares starkly to the Chinese system – which appears to be to have safety regulations but ignore them as long as you have the correct connections or don’t get caught. The recent massive chemical warehouse explosions spring to mind where rules existed about storing chemicals but were ignored to squeeze more stuff into a warehouse. The resulting explosions took out entire city blocks.

     

    I believe the US approach is that a company can (generally) release a product but must only prove it’s safe after an incident occurs. E.g. a push chair was sold but only after it was found it could cut fingers of was it tested and subsequently withdrawn from the market for being dangerous. I say “generally” because safety critical devices like those going into explosive atmospheres are still tested and certified before going on the market – the US system isn’t suicidal.

     

     

     

     

    #1380115

    blinky465
    Participant
    5541xp

    Like @danlee I’m only extrapolating from my own personal experience of CE marking (for electronics B2B and to end user consumer electronics). The CE mark isn’t supposed to just be a bit of admin that you “need to get around”. Which is what the original post seemed to suggest – that simply manufacturing inside the EU means you “don’t need to bother with CE since it’s only checked at external borders”.

    The whole point of the CE system is that

    1. a) you should only sell goods into the EU (whether from outside or in) with the CE mark
    2. b) the CE mark tells the consumer that the contents have met strict manufacturing and safety guidelines (where necessary)
    3. c) a manufacturer, being obliged to put the CE mark on packaging, should make sure that the product being sold meets the necessary requirements to be sold within the EU *before* taking the product to market.

    It’s not so much “here we’ve stuck a CE mark on a box, you can buy this now” but more a prompt to manufacturers, to make them aware of their obligations, ensure that they’ve met them, and on doing so, conferring to the purchaser that their goods are up to European standard.

    Anyone can stick broken glass and razor blades in a box and write on it “toy, safe for children” just as anyone can simply print a white C and a white curly E on a box. The point is it’s supposed to ensure manufacturers meet requirements *before* publishing/selling to the consumer. Far from being a complaints system for “after something has gone wrong” it’s supposed to be a regulatory system ensuring everyone is “doing things properly”.

    The response by Columbia Games suggests they’ve taken absolutely no interest in their obligations and, as such, wouldn’t give me much confidence in their due diligence. Maybe if this thread was originally titled “enforcement of CE regulations is causing problems for boardgames in EU – but it really shouldn’t” the thread wouldn’t have attracted such attention!

    @danlee gives a pretty good summary of CE marking – it’s not meddling bureaucrats, it’s actually a pretty rigorous safey and compliance system – rather than bemoaning it, we should celebrate that at least some companies take their obligations seriously 😉

    #1380118

    limburger
    Participant
    7407xp

    @blinky465 I’d argue that you shouldn’t need those regulations as it is supposed to be ‘common sense’ … then again companies have proven that they’d rather pick profit over safety too many times.

    I do agree that CG at the very least isn’t making itself look good with this (and that’s putting it mildly). Heck, it was enough for me to not back their ‘hammer of the scotts’ project.

    OTOH … the EU isn’t doing anything to make consumers aware of this part of the legislation, so to us it is easy to misinterpret it as more red tape. Especially for something as boring (and ‘safe’) as a boardgame with bits of painted wood. Add to this that it is a re-print that had already been shipped to the EU it is odd to say the least.

    Anyways … I think we’re all on the same page here, right ?
    The CE logo should be on every product here in the EU (and EER).
    It might help if the website wasn’t written for lawyers with all that legalese that makes it hard to decypher the actual requirements, because it ought to be easy especially for boxes filled with printed cardboard & meeples.

    #1380242

    blinky465
    Participant
    5541xp

    @limburger – personally, I’d take regulation over “common sense” any day. A boardgame and bits of painted wood isn’t “safe” at all; sourcing the wood for the meeples is important – whether virgin wood or recycled, where the wood comes from is important and needs to be regulated (so we don’t destroy fragile ecosystems or use endangered hardwoods, for example, or send cheap wood filled with bugs and mites that could cause woodworm/termite infestations in people’s homes, for example).

    When I first joined the workforce, many years ago, it was in a mental institute where two of the residents had been committed after chewing their headboards (over a number of years) as children. The white paint used on their beds as children contained a high level of lead. It might seem like “common sense” for us not to chew on a lead pipe, but how could we be sure that a painted meeple isn’t going to be chewed (or swallowed) by a small child? In which case, we need to be absolutely certain – not simply rely on “common sense” – that it painted using lead-free paint.

    If there is just one single company in the industry that would choose profit over safety then, sadly, every company needs to be subject to regulation. Just because they got away with it before is no justification for not complying for the second print!

    I’d like to think that we’re all on the same page in that CE marking and regulations are important. You’re right that the CE logo should be on every product; what’s more important than that is that every product should meet all of the requirements as set out by the CE marking regulations. I’d rather a product met the requirements and didn’t have a logo than simply slap a logo on a box without performing the necessary due diligence (which is what Columbia suggest they’re trying to do).

    Hopefully, anyone reading this who previously thought it was all a load of unnecessary bunkum might at least understand now why we should abide by CE marking regulations 😉

    #1380274

    limburger
    Participant
    7407xp

    @blinky465 you’re right … it’s the one rotten apple that spoils the lot.
    However sometimes these regulations read like there should be x amount of poison in stuff or there are other loopholes that could be exploited by the less scrupulous companies who follow the letter and not the intent of the law.

    At the same time I’d argue that it is impossible to child proof everything, so in the end it is also down to the parents to watch their kids.

    We should be careful not to associate toys with kids every single time either …

    #1380365

    tankkommander
    Participant
    2325xp

    It is down to parents to check the lead content in the painted parts of toys?

    CE regulations exist because business seldom has the best interests of consumers at heart. Profit is king.

     

     

    #1380398

    limburger
    Participant
    7407xp

    It’s down to parents to make sure kids don’t start licking games that aren’t targetted at their age group.

    #1380423

    blinky465
    Participant
    5541xp

    I think we’ve gone down the rabbit hole on this one. The same argument could be used against childproof caps on bottles of bleach. CE isn’t just about protecting kids; it’s just one element of what it covers. If it’s possible to produce gaming pieces that are not hazardous, I’d rather there were regulations in place to say “you must not use toxins for board game playing pieces” than “we trust you won’t let your kids near these”.

    CE is also about things like ensuring the wood is responsibly sourced and doesn’t do things like introduce mites or spores into your home (or even another country – the whole issue about Brexit and WTO rules was particularly enlightening, as there are regulations concerning the *containers* that goods are shipped in, let alone the contents of those containers – and it became obvious that very few people are actually aware of the many regulations for importing/exporting internationally.)

    I’d have to disagree that it’s not *solely* down to parents to stop their kids doing stupid stuff. Because they’re, well, kids and that’s sort of what they do.

    I think I’m exhausted on this issue – for me, although they can sometimes be a bother as a manufacturer, as a consumer, I’m rather glad there are CE regulations (which, remember, are *minimum* requirements we should expect of manufacturers). I think anyone trying to find loopholes to side-step, them instead of addressing the issues in their manufacturing chain, or putting the responsibilities entirely on the consumer to keep others safe, is behaving irresponsibly.

    </rant>

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