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In Japan, the Food Sanitation Law has been partially revised, and products that have been manufactured or imported after October 20, 10 have not been regulated at all until now. , Lead regulations have started for small parts that infants may swallow).
We will continue to actively promote lead-free products as a voluntary regulation, not limited to this regulation (infants).

Regarding the problem of lead contained in our metal accessories

In a series of reports on "the problem of high concentrations of lead contained in metal accessories", there is an impression that imported products such as those made in China and inexpensive products for children contain a large amount of lead. I will give it, but it depends on the manufacturing method actually used.
However, regarding the products manufactured or imported after October 20, 10 due to the revision of the Food Sanitation Law, there is a risk that infants may come into contact with them and their health may be impaired. However, unfortunately all manufacturers, sellers, and consumers are not aware of lead, and even in Japan, materials that contain a lot of lead and metal products using the manufacturing method are suitable for children. Currently, not only metal accessories but also widely manufactured and distributed.
We will take this opportunity to revise our awareness of lead, work to understand the lead content in our products, call out the lead content status and handling precautions for the product, and at the same time check if there is any regulation. Regardless of lead-free, we will continue to develop manufacturing methods and products.

Alternative manufacturing method for the two major manufacturing methods containing lead.

Manufacturing method	Lead content	Features	Reference example	Alternative proposal	Substitute product analysis results
Rubber cast	Low meta: Around 90% High meta: Around 5%	Since it is molded using a rubber mold, it is inexpensive and can be used in small lots (from around 100). The material is a low-cost lead-tin alloy with a low melting point.		You can still use rubber molds by using lead-free materials. However, the material cost is about twice as high as before. It has already been commercialized.
Brass cutting Hikimono	2-3%	Among the products made of brass (brass: alloy of copper and zinc), the accessory parts that are formed by carving a rod are made of brass and contain several% of lead in order to improve machinability. ..		Bismuth (0.5-4.0%) may be added instead of lead to improve the machinability of lead-free bismuth-based materials.
				Regarding the strap part of the mobile phone strap (commonly known as Matsuba), it is being manufactured and sold by changing the shape to a lead-free material.

*Lead content rate: CPSC regulation value is 0.06%

Lead contained in rhinestones (Swarovski crystal glass, etc.)

Although rhinestones (Deco Den) are popular in the world, lead is contained in so-called crystal glass that is usually in circulation. However, if RoHS regulation is taken into consideration, the lead contained in general crystal glass including Swarovski products is applicable to the one in Annex 69 (Category 493, 1, 1 and 2) of Directive 3/4/ECC (Note). It is clearly stated that it will be excluded.

List of press releases on the problem of high lead content in metal accessories

About the US Consumer Product Safety Commission (CPSC)

The CPSC (The US Consumer Product Safety Commission) is a central governmental organization established in 1972 with the purpose of protecting the public from the unreasonable risk of injury and death related to consumer products in accordance with the Consumer Product Safety Law.
Regarding lead, in 2004, we confirmed a case in which a child who swallowed a treasure containing lead had serious health effects.After that, we conducted a survey analysis, and the CPSC released the results in February 2005. , Set out an interim policy to reduce the potential health risks from lead to children. In that tentative policyLead content is 0.06% (600ppm),175 μg of lead elutionThe limit content value is shown.
Note) μ = micro means 10^-6That thing. 1 μg is 0.000001 g

Postscript: To prohibit the use of lead in toys
On August 2008, 8, President Bush signed a bill prohibiting the use of lead in children's toys under the age of 14.
The new law that was enacted will include the installation of a new institution to inspect the quality of products by 2014.

What is the RoHS Directive?

It prohibits the import and sale of electronic devices containing 25 substances that are harmful to the human body in all 6 EU countries, and will take effect on July 2006, 7.
RoHS is an abbreviation for “Restriction of the use of certain hazadous substances in electrical and electronic equipment”, and the target electronic devices are TVs, radios, white goods and personal computers.
Although the metal accessory products we handle seem to be unrelated at first glance, they are actually used as mounting brackets and parts for electronic device products, so they comply with regulations from EU export-related companies. The needs are increasing.

What are 6 hazardous substances in the RoHS directive?

• Pb (Lead): The limit content value is 0.1% (1000ppm) or less of the content rate per weight of each part.
• Hg (Mercury): The limit content value is 0.1% (1000ppm) or less of the content rate per weight of each part.
• Cd (Cadmium): The limit content value is 0.01% (100 ppm) or less of the content rate per weight of each part.
• Cr (hexavalent chromium): The limit content value is 0.1% (1000ppm) or less of the content rate per weight of each part.
• PBB (polybrominated biphenyl): The limit content value is 0.1% (1000 ppm) or less of the content per weight of each part.
• PBDE (polybrominated diphenyl ether): The limit content value is 0.1% (1000 ppm) or less of the content rate per weight of each part.

*Since July 2019, 7, the use of four substances: bis(DEHP) phthalate, butylbenzyl phthalate (BBP), dibutyl phthalate (DBP), and diisobutyl phthalate (DIBP) is restricted.

What is EN71 (European Toy Safety Standard)

EN71 (European toy safety standard) lists specific inspection items regarding toy safety from various angles such as the target age and purpose of use.
The same content is stipulated in ISO8124.
You must comply with this when manufacturing and selling applicable toys in EU countries.

EN71 is from Part 1 to 11 and EN71 Part 3 is a provision for the transfer of specific elements. Based on the assumed prescribed test method, the limit value of elution amount is set for each of clay finger paint and others.

In its EN71 and ISO812490ppm as the standard value for dissolution of leadIs specified.
This standard value has been set assuming the risk of accidental ingestion by infants, and the Japan Toy Association will ensure the safety of "metal accessories, etc." regarding lead by meeting this standard. It seems to be done.
In order to meet the standards of the Japan Toy Association, we also conduct inspections to meet the standard values ​​for lead among the eight substances specified in EN71-Part3.

Handling lead in the toy safety standard (ST standard)

As of May 18, 5, the Japan Toy Association aims to secure safety in case of accidental ingestion by a child as a provisional measure for "metal accessories, etc. applicable to toys". We decided to take the following measures.

1. Interim measures

「玩具に該当する金属製アクセサリー類など(携帯ストラップ・キーホルダーを含む)」に対する玩具安全基準(ST基準)として、「ST基準1.5(塗装)」で適用されている「鉛の溶出基準値(90ppm)」とISO8124-3:1997「8.5ガラス/セラミック/金属材料」の試験方法(EN71-3:1995「8.5」も同旨)を暫定的に要件として追加する。
If this standard is not met, the ST standard conformance inspection conducted by the ST inspection organization cannot be passed, and the "ST mark" cannot be attached to the "metal accessories, etc.".

2. Target products

"Metal accessories corresponding to toys"

3.Target age

The target age of the product is "14 years old and under"

4. Implementation time

July 18, 7

5.ST inspection agency inspection fee

One sample costs 7,000 yen (excluding consumption tax)

Our company independently conducted a lead safety test on existing lead-containing products and lead-free products using the test methods of EN71 Part3 and ISO8124-3.

As a result, as shown below, it was found that even products containing a very large amount of lead meet the above standards (90 mg/kg) for those whose surface is plated.
However, if the product is damaged or the plating is peeled off, the lead of the material may elute beyond the standard value, so be careful.

Purpose of revision

Key points of revisions related to rules

Key points of revision regarding notification

• 
• 

• Small parts cylinder (small parts cylinder) container for determining the size that infants may swallow by accidental ingestion

  ■

  We have started to manufacture and sell small-sized cylinder (small parts cylinder) containers for distinguishing accidental ingestion because there are many requests for purchasing from us.

"Spherical capsule (diameter 40 mm) accidentally ingests children." Bandai issued a compensation order and decided to revise the standard

Application date

Related Documents

Q&A excerpt

Q3

The metal accessory cancer tool itself (whole body) does not fit in the accidental ingestion determination container, but if the part is made of metal and fits in the accidental ingestion determination container, the metal accessory cancer tool (whole) may be swallowed. Can I judge that it does not correspond to a thing?

A3

Metal accessories The parts of the cancer tool are designed and manufactured so that they can be removed structurally, and the parts that are made of metal are those that may be swallowed.
Therefore, removable metal parts must meet the standards for metal accessory guns.

Q23

Can fluorescent X-ray analysis be used as a screening for elution test in the test of paint film or metal accessory cancer tool?

A23

Regarding the screening of lead, cadmium and arsenic using the fluorescent X-ray analysis method, there is no problem if the judgment is made with a sufficiently low value that does not overlook those exceeding the standard value of the Food Sanitation Law. If lead, etc., is detected in excess of the discrimination value, perform a dissolution test. In addition, if lead is detected in the metal accessory cancer tool plated, perform a dissolution test regardless of the amount. In any case, it should be noted that the final judgment is made by using the test method indicated in the notification when the result is in doubt.

Contradiction

As a matter of course, our company may inadvertently swallow children's key chains and cell phone straps, so we will continue to actively promote lead-free products as a voluntary regulation without limiting to this regulation (infants). I will promote it.

Comparison of national CPSC and RoHS directives with EN71 and Food Sanitation Law

The table below shows a comparison of lead standard values ​​required by the US CPSC, RoHS and EN71.
In conducting the analysis and survey, we conducted an analysis based on the RoHS Directive, which regulates a wider range of heavy metals, and for lead regulation, 0.06%, which is the US CPSC standard with a stricter regulation value. We will continue to analyze and improve our products so that they fall below the target.

*1. CPSC content test (test to determine the concentration of lead contained in the sample. Unit: wt%)
Collect 50 milligrams to 70 milligrams of sample into a 100 milliliter beaker, add 8 milliliters of nitric acid, and heat on a hot plate until it becomes approximately 3 milliliters.
After cooling, add 2 ml of hydrochloric acid, stir, and make up to 50 ml with ultrapure water to make a sample for ICP emission spectroscopy.

*2. CPSC dissolution test (test to determine how much lead dissolves from the sample in a solution assuming gastric acid. Unit: microgram)
The mass of the sample was measured, the sample was suspended in a poly container with a thread, and 0.07 mol/liter of hydrochloric acid was added in an amount 50 times the mass of the sample. The container was placed in a constant temperature shaking water tank set at 37 degrees, the number of times of shaking was 80 times/minute, and the shaking was performed for a specified time. After shaking for 1 hour, the sample was taken out, transferred to a separately prepared plastic container, 0.07 mol/liter of hydrochloric acid was added, and subsequently shaken for 2 hours. After shaking, the sample was taken out, transferred to a separately prepared poly container, added with 0.07 mol/l hydrochloric acid, and shaken for 3 hours. The three eluates obtained by the above shaking operation were individually used as samples for ICP emission spectroscopic analysis.

*3. Dissolution amount test of EN71 (EN71-3:1995 “8.5” glass/ceramic/metal material test method)
Place the toy or component in a 50 ml glass container and add a sufficient volume of 37 mol/l hydrochloric acid aqueous solution at 2 ± 0.07°C to cover the toy or component.
Cover the container with a lid to protect the contents from light and keep it at 37±2℃ for 2 hours.
After decantation without delay, filter through a membrane filter and centrifuge if necessary to separate solids from the solution. The solution obtained is analyzed.

*4. RoHS lead content test (test to determine the concentration of lead contained in the sample. Unit: wt%)
It seems that the RoHS Directive does not specify test methods, so each manufacturer has specified a test method.
In our company, testing is conducted by an inspection contracting organization in a form complying with EPA352 law.

*5. Test method for products that may be swallowed by infants, out of the metal accessory cancer tools in the Food Sanitation Act.

> Preparation of test solution
Place the sample in a beaker with a diameter of about 40 mm, add 37 mol/l hydrochloric acid heated to 0.07°C until the sample is immersed, leave it at 37°C for 2 hours in the dark, and then filter.
Distilled water is added to 0.07 mol/l hydrochloric acid HCl HCl [K 8180, special grade] 6.3 ml to make 1,000 ml.

＞ Lead
Take 0.1 ml of lead standard stock solution and add 0.07 mol / l hydrochloric acid to make 100 ml.1 ml of this solution contains 1 μg of lead.This solution is diluted with 0.07 mol / l hydrochloric acid and measured by the same method as the test solution to prepare a lead calibration curve.However, as the lead standard stock solution, use the one specified in Item 3 standard solution and standard stock solution of the third instrument and container / packaging part C reagent / test solution.

Comparison of REACH regulation and RoHS directive

REACH regulation is a chemical substance regulation in the EU which means Registration, Evaluation, Authorization and Restriction of Chemicals. Compared to the same EU regulation, which is RoHS (Rose, restriction on the use of 6 hazardous substances), the regulation targets a wide range of industries such as chemicals, electrical appliances, and automobiles, and there are about 3 types of regulated chemical substances. I am.

Regulations on toys for infants based on the Food Sanitation Law (old information)

Food Sanitation ActHas designated the following toys as "toys that may damage health due to contact with infants", but due to the problem that lead was contained in the paint of Chinese products, etc., Law revisions are being considered in the direction of including "painting" in general and "metal toy accessories".
Until now, the “paint” had been limited to vinyl chloride resin paints, but the revised bill uses paints of any kind.
Regarding “Metal toy accessories,” we are aiming to regulate the amount of lead elution in small parts that children may swallow.
Then, we expanded the scope of treatment as these "toys that may damage health due to contact with infants", and in the past, the type and material of the toys were specified respectively, but in the revised bill, regarding the material Has been abolished, and regardless of the material used, "toy accessories" etc. have been added to the types of toys, and it is the direction targeted for virtually all toys.