Analysis on the Technical Standardization System of Juvenile Product in Europe and the United States of America and Strategies of Technical Measures of Trade ()
1. Introduction
International technical measures of trade become the primary means of trade protection in various countries because of their significant controlling effect and hidden implementation means [1]. Juvenile product is the international consumer goods with high sensitivity, whose quality and safety are related to the healthy development of children with great social attention. The standardization of the international juvenile product led by the European Union and the United States of America is very active, and a perfect and mature juvenile product standardization committee and Technical Standardization System have been established. China leads the world in the development of the juvenile product industry, but the standardization is still at the initial stage, and the standard system is still unformed. As a result, the technical indicators of domestic products are difficult to attain international standards, and the products exported to Europe and the United States of America (two most important export destinations of the Chinese juvenile product) are seriously recalled.
This paper compares and analyzes the Technical Standardization Systems of the juvenile product in Europe and the United States of America to find out the relative technology gap and comparative advantages and explore the situation of the recall of the juvenile product exported to Europe and the United States of America in recent years, thereby analyzing the reasons and proposing relevant strategies of technical measures of trade.
2. Research on Technical Standardization System
2.1. Europe
The standardization of the juvenile product in the EU region is formulated by CEN/TC 252 “Child care articles” Technical Committee. The responsibilities of CEN/TC 252 standardization committee include developing standards for product safety requirements in child use and care articles industry. Such products include all designed or obviously intended to safely ensure and facilitate seating, bathing, changing and general body care, feeding, sleeping, transportation and protection for young children [2]. They are included in the following 7 working groups, and the organizational framework of CEN/TC 252 is shown in Figure 1.
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Figure 1. Organizational framework of CEN/TC 252 standard system.
According to the research directions of these 7 standards, CEN/TC 252 has developed 31 EU standards, as shown in Table 1 below.
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Table 1. Developing list of the CEN/TC 252 standard.
It can be seen from the standard system and standard list that CEN/TC 252 standard system is around two aspects of “general basis and safety of general products” and “safety of specific products”, and focuses on the study of user behavior and physiological characteristics of infants and children to develop “General safety guidelines—Part 1: Safety philosophy and safety assessment” and other standards for child injury risk assessment, risk safety guidelines, risk prevention and control, and the items of standard account for 16% of the total. This part of the standards provides the research basis and guidance for the development of specific product safety standards. This is also the key reason that the technical committee is leading the world in standard development technology.
2.2. The United States of America
As the biggest international juvenile product market, the United States of America has mature juvenile Technical Standardization System, and Consumer Product Safety Commission (CPSC) and American Society for Testing and Materials (ASTM) jointly develop voluntary product standards, and take part of voluntary standards as mandatory regulations in order to realize the supervision of consumer goods in circulation. F15 “Consumer Products” technical committee of ASTM is responsible for juvenile product standards of the United States of America [3]. The technical committee has formulated consumer safety and performance criteria including specifications, guidelines, test methods, classification, application and terminology. It has 15 sub technical committees for the juvenile product, which can be classified into 6 product standard systems: wheel bearing and crib, recreation facilities, auxiliary seat, General and common specifications, feeding, clothing. The framework of ASTM F15 standard system for juvenile product is shown in Figure 2, and in Table 2 is for the standard list.
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Table 2. ASTM juvenile product standard list of the United States of America.
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Figure 2. Juvenile product standard system of the United States of America.
In the United States of America, the technical regulations related to children’s products are more dispersed, including the written bill made by Congress, the rules, requirements and specifications made by federal government departments, and relevant regulations related to children’s products made by the states. The Consumer Product Safety Improvement Act (CPSIA/HR4040), which came into effect in 2008, has been revised based on the Consumer Product Safety Act. It formulated more rigorous safety standards and safety requirements for children’s products (children’s products, clothing, etc.), and further severely punished violations of product quality and safety regulations. The bill also requires to establish consumer product safety bulletin data, and manufacturers must affix permanently clear and striking standards on their products and packaging to facilitate consumers to identify and determine the manufacturer’s name, production date, place of origin and other relevant production information to ensure the traceability of production.
3. Product Recall and Cause Analysis
3.1. Europe
As important and sensitive export trade goods in China, juvenile product frequently becomes the focus of trade frictions. The EU is the largest export area of juvenile product in China, but China never provides any basic research data when dealing with the implementation of technical trade barriers of developed countries in Europe to the Chinese export juvenile product, which leads to a passive position in the international response. The recall of juvenile product issued by EU through Rapid Alert System for Non-food Consumer Products (RAPEX) in 2011-2020 is shown in Figure 3, and it’s revealed that China had always been the most seriously affected by the recall for all time, which has caused severe economic losses to Chinese export of juvenile product, and also badly affected the reputation of Chinese export products [4].
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Figure 3. Percentages of RAPEX recall cases of China juvenile product in 2011-2020.
From 2016 to 2020, there were about 30 kinds of recall of Chinese juvenile product involved in EU non-compliance standards or regulations, among which 19 cases did not mention any standards or regulations, mainly including 14 times of EN 12586, 12 times of EN 14988, 11 times of EN 1888 and REACH regulation, 9 times of EN 1930, 6 times of EN 8098 and EN 1273. The main reasons for the blocked recall of the juvenile product in China focus largely on mechanical and physical safety and chemical safety, among which the mechanical and physical safety mainly involves: instability problem, failure of constraint system, injury caused by gap/hole/opening or protruding/sharp part, widget flaking off and long drawstring; chemical safety mainly involves the following chemicals: phthalate DEHP, short-chain chlorinated paraffins (SCCPs), flame retardants TCEP and TCPP. The EU directives 2009/48/EC and 76/769/EEC, POP, REACH regulation and EN 71 series standards, all present requirements on chemical safety of juvenile product [5].
3.2. The United States of America
The United States of America is an important importer of Chinese juvenile product. Customs statistics show Chinese exports of juvenile product to the United States of America was $8.57 billion, accounting for 25.59% of the total export of juvenile product in 2020 [6]. The United States of America sets up a strict technical regulation system on the quality and safety of children’s products with complex and numerous provisions. At different times, the United States of America Congress supplements the original technical regulations through amendments according to public reflection and political needs.
The United States of America is an important importer of Chinese juvenile product [7]. Moreover, the United States of America sets up a strict technical regulation system on the quality and safety of children’s products with complex and numerous provisions. At different times, the United States of America Congress supplements the original technical regulations through amendments according to public reflection and political needs. In 2020, the CPSC of the United States of America released a total of 257 recall notifications, with 135 consumer goods from China, including 21 cases of juvenile product, ranking second in the category of recalled products in China (see Figure 4).
Among the multiple types of injuries in the recall cases in the United States of America, choking (34.4%), falling (13.1%) and burn (10.6%) are the most frequent types of injuries, and the main products causing the three kinds of injuries are children’s furniture and clothing. The falling injuries caused by children’s furniture (46.8%) breaches the requirements of Code of Federal Regulations 16 CFR 1219, 1220 and 1222 for the support system and warning label of crib, 16 CFR 1218 for the stability, constraint system and height of baby basket, 16 CFR 1224 for provisions the space of portable bed rail and other provisions for protection in the event of falling; Burn injuries caused by children’s clothing (71.1%) breaches flammability standards for garment textile production of Code of Federal Regulations 16 CFR 1610 and tougher flammability requirements for children’s pajamas (16 CFR 1615, 1616).
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Figure 4. Statistics of recall of Chinese juvenile product by CPSC in 2019.
4. Conclusions: Strategies of Technical Measures and Responses of Trade
1) Because the children are curious and naughty, but fragile and vulnerable, Europe and America developed a very strict standard system for the juvenile product with wide coverage. From information collection and notification during product usage and sales to the safe consumption demand of widgets on children’s clothing, the technical indicators are constantly updated with the improvement of actual requirements. The relevant exporters should learn carefully the standard system of export target market, pay close attention to the introduction and update of technical measures of trade, actively adopt international advanced standards or formulate higher enterprise standards, and fully consider the safety performance of the juvenile product in the phase of product design and development to lead the quality market of the juvenile product.
2) As for the unreasonable technical measures of trade, the juvenile product exporters should timely cooperate with the government agencies and industry associations to scope reviews for the full exercise of initiative, thereby having the opportunity to delay, reduce and even eliminate the economic losses caused by the technical measures of trade formulated by other WTO members to the foreign trade of Chinese juvenile product industry, and escort the export of the juvenile product. At present, China has established Shantou toys, Hangzhou baby and child products, Yunhe wooden toys, Ninghai stationery, Cixi buggies and child car seats, and other review bases of technical measures of trade, which provide a good platform for enterprises to participate in report review.
3) Focus on avoiding the risk of a product recall. From 2011 to 2019, the high-risk recalled products of Chinese children’s products exported to the United States of America were children’s strollers and cribs. The types of injuries were focusing on choking caused by toys, falling caused by children’s furniture, and burn caused by children’s clothing, and the refund was always taken as the primary remedial measure. Therefore, we should focus on the risk of a product recall, assist enterprises to track the recent recall of similar exported products of the enterprise by CPSC recall system, pay attention to the main authorization of CPSC supervision on all kinds of products (for example, children’s clothing focuses on the flammability), and rectify the high-risk quality and safety projects to avoid the loss of similar product export recall.
4) Accelerate the improvement of the standardization mechanism and standard system construction of the juvenile product in China. The standard system of the juvenile product in China is more dispersed with a large number but low level. Currently, there are no legal regulations and standards for the juvenile product, and the specification of this area is to formulate special product standards based on the framework of general legal regulations. Therefore, we should closely follow the development trend of quality and safety factors of juvenile product and technical measures of trade of main export target markets, accelerate the development of corresponding mandatory national standards, simplify and integrate current standards, eliminate cross-industry and cross-regional technical differences, and establish a fully covered, high-level and high-quality national standard system for the juvenile product.
Acknowledgements
The authors are grateful for the support of the research projects of General Administration of Customs of China (No.2020HK104).