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The Food Sanitation Act has finally been partially revised in Japan, and restrictions on lead have been put in place for products manufactured or imported after October 20, 10, including products that previously had no restrictions (metal toys containing small parts that may be swallowed by infants).

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

A series of reports about the problem of high levels of lead in metal accessories give the impression that lead is mostly found in imported products, especially those made in China, and cheap products for children, but in reality it depends on the manufacturing process used.

However, due to revisions to the Food Sanitation Act, only "toys used as accessories by infants" that may be harmful to the health of infants if they come into contact with them, have become subject to regulation for items manufactured or imported after October 20st, 10.Unfortunately, awareness of lead is lacking among manufacturers, sellers, and consumers, and even in Japan metal products that use materials and manufacturing processes that contain a lot of lead are still widely manufactured and distributed, and this is not limited to metal accessories for children.

We will take this opportunity to change our perception of lead, strive to understand the amount of lead contained in our products, and raise awareness of the lead content of these products and how they should be handled. At the same time, we will continue to develop manufacturing methods and products aimed at making lead-free, regardless of whether they are subject to regulation or not.

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 metal: 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.		By using lead-free materials, rubber molds can be used as usual. However, the cost of materials will be about twice as much as before. It has already been commercialized.
Brass cutting Hikimono	2-3%	Among our products made from brass (an alloy of copper and zinc), accessory parts that are formed by cutting out rods contain a few percent of lead to improve machinability.		We can provide lead-free bismuth-based materials with improved machinability by adding bismuth (0.5-4.0%) instead of lead.
				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: CPSC limit is 0.06%

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

Rhinestones (deco phones) are popular these days, but the so-called crystal glass rhinestones that are commonly sold contain lead.
However, if you are aware of the RoHS regulations, it is clearly stated that lead contained in general crystal glass, including that made by Swarovski, is exempt from the application of Annex 69 (Categories 493, 1, 1 and 2) of Directive 3/4/ECC (Note).

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. It came into effect on July 2006, 7, and has been enforced until now after the revision in June 1. It has been.

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 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 has Part 1 to 13, and EN71 Part 3 is a clause on the transfer of specific elements, such as aluminum, antimony, arsenic, barium, boron, cadmium, trivalent chromium, hexavalent chromium, cobalt, copper, lead, manganese, mercury, and nickel. , Selene, strontium, tin, organic tin, and zinc, 17 elements and 19 components, regulate the amount of harmful metals dissolved by stomach acid when part or all of the toy material is swallowed.

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 are also inspecting to meet the standard values ​​for lead among the 71 elements and 3 components specified in EN17-Part19.

Handling lead in the toy safety standard (ST standard)

On May 18, 5, the Japan Toy Association decided to implement the following measures as a temporary measure for "metal accessories and other items that fall under the category of toys" in order to ensure safety in the event that a child swallows them.

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.

Regulations on toys for toddlers based on the Food Sanitation Law (latest information)

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

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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

Screening for lead, cadmium, and arsenic using X-ray fluorescence analysis is acceptable as long as it is done at sufficiently low levels that it does not overlook anything exceeding the standards set forth in the Food Sanitation Act.
If lead or other substances are detected above the discrimination limit, an elution test must be conducted.
In addition, if lead is detected in plated metal accessories, an elution test must be conducted regardless of the amount. In any case, please note that if any doubts arise regarding the results, a final judgment will be made using the test method specified in the notification.

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.

Additional regulations on toys (toys) based on revisions to the Consumer Product Safety Act (latest information)

Purpose of revision

On May 5, 5, the “Cabinet Order to Partially Revise the Consumer Product Safety Law Enforcement Order” was approved by the Cabinet, and on June 16, 5, it was newly designated as a specified product under the Consumer Product Safety Law. "Amusement goods made of magnets (magnets)" and "Toys made of water-absorbing synthetic resin" will be specified in the above, and the sale of products that do not comply with the technical standards will be regulated.If an accident were to occur with these two products, there is a high risk of an accident and serious damage, so they are designated as specific products and subject to regulation. I decided to do it.
Examples of regulated products: magnet sets, magnet balls, water-absorbing synthetic resin toys

Key points of regulatory reforms

The following two products have been added to Appended Table 2 of the Consumer Product Safety Law Enforcement Ordinance, which designates specific products under the Consumer Product Safety Law.

[Regulated products]

• A product used as a toy or entertainment by sticking magnets together.
  (Those that do not fit in the small parts cylinder specified in ISO8124-1, which is the standard for the size that infants can swallow, magnetic flux index, which is the level of magnetic force that is naturally discharged outside the body even if swallowed by mistake. (The product of the square of the maximum magnetic flux density and the area of ​​the pole) is less than 50kG2mm2 is not subject to regulation.)
• Synthetic resin that swells when it absorbs water
  (Those that do not fit in the small parts cylinder stipulated in ISO8124-1, which is the standard for the size that infants can swallow.) (Those that do not swell more than 50% from

[Products not subject to regulation]

• This product is not intended for playing with magnets by sticking them together.
• Items that are too large to fit into the small part cylinder specified in ISO 8124-1, which is the standard for the size of items that can be swallowed by infants
• The technical standard for magnetic entertainment products is that they must have a magnetic force of less than 50kG2・mm2, which is the level at which magnetic force is naturally expelled from the body if accidentally ingested.
• The technical standard for water-absorbent synthetic resin toys is that they do not swell by more than 50% from their original state before absorbing water, which is a level that allows the water to be naturally excreted from the body even if it is accidentally swallowed.

■

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.

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.
As we proceed with our analysis, we will be conducting analysis based on the RoHS Directive, which places a wider range of restrictions on heavy metals, and with regard to lead restrictions, we intend to analyze and improve our products so that the lead content falls below the stricter US CPSC standard of 0.06%.

*1. CPSC content test (a test to determine the lead concentration in a sample. Unit: weight %)
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 leaching test (measures how much lead dissolves from a sample in a solution that simulates stomach acid. Unit: micrograms)
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. EN71 elution test (EN71-3:1995 "8.5" Test method for glass/ceramic/metal materials)
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: weight %)
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. Testing methods for metal toy accessories that may be swallowed by infants under 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 and RoHS

REACH regulation stands for Registration, Evaluation, Authorization and Restriction of Chemicals, and is a chemical substance regulation in the EU. Compared to the same EU regulation, RoHS (Restriction of Six Hazardous Substances), the scope of the regulation covers a wide range of industries, such as chemicals, electrical equipment, and automobiles, and the number of regulated chemical substances is approximately 6.

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.

About Electrical Appliance and Material Safety Law (PSE mark)

Electrical Appliance and Material Safety Law (PSE mark)Is a mark that is attached to the one that meets the safety standard, which is provided to prevent the danger and the trouble caused by the electric products.
Electrical appliances used in ordinary homes, shops, offices, etc., and are specified by government ordinance (electrical appliances), cannot be sold unless they display the PSE mark, the business name, rated voltage, and rated power consumption, which are standards set by the government.

Our products are equipped with lithium-ion batteries.Portable fanWe have obtained the PSE certification mark.