News Our Feedback to EC 18 August 2022

Have your say - Child's products

You can also get involved in forming EU laws. The European Commission would like to hear your views on laws and policies currently in development. They offer a platform "Have your say" with the list of all new EU initiatives open for public consultation. You need to register to write your feedback.

There are always 5 stages of each EU initiative, each stage is open for public consultation for a specific time frame:

  1. In preparation

  2. Call for evidence

  3. Public consultation

  4. Draft act

  5. Commission adoption

Safety of children’s products (excluding toys) - requirements to be met by European standards

About this initiative: The current standards for childcare articles other than toys are based on a 1997 mandate that is outdated, and the Commission intends to update these safety requirements.

Feedback period: for stage 4 it is 05 August 2022 - 02 September 2022


Feedback from Europeans for Safe Connections

We "The Europeans for Safe Connections" welcome this initiative and we would like to improve Annex, chapter 25, RADIATION HAZARDS, point (c) "Non-visible radiation hazards shall be limited as much as possible (including electric, magnetic, electromagnetic fields and other types of radiation)" as folows:

(c) Non-visible radiation hazards shall be limited as much as possible (including electric, magnetic, electromagnetic fields and other types of radiation). All products emitting any non-visible radiation must be labeled visibly - CAUTION: ELECTROMAGNETIC RADIATION, WARNING: POSSIBLY DANGEROUS TO CHILDREN.

Maximum radiation emissions as peak exposure levels (µW/m2) and also Specific Absorption Rate (W/kg) must be measured 0mm, 10cm and 50cm far from source and in contact (0mm) with body and head. These values must be written visibly and in bold font in manual and on the box together with warning label.

Customers should always be informed that non-ionizing radiation from wireless products is harmful to health and effects are cumulative in time.

Customers should be informed to use these products as far as possible from body/head/belly in order to decrease adverse effects on human health.

All wireless products must have manual button to switch off all wireless functions.

All advertising of wireless devices must include warnings on radiation risks.

Manufacturers should provide alternative solution of child products, which does not contain wireless transmitters.


Parents are not aware of huge amount of sources - smart diapers, wireless baby monitors and cameras, bluetooth smart toothbrushes, smart watches, smart lamps, mobile phones and tablets, close to microwave ovens, close to induction ovens and much more. Parents have to be informed and make informed decisions.

This request is in line with WHO labeling - electromagnetic radiation is in group 2B (possibly carcinogenic to humans) and is expected to change into just ”cancer causing” (it is planned by IARC to review the classification in 2022-24)

This request is in line with our ECI, proposal 9: In order to protect human health and bio-integrity, ask EU citizens for informed consent before exposing them to RF EMF.

Jurisdiction for labeling can be affirmed on the basis of Art. 114 TFEU.

In the future we will welcome an update of this Directive 2009/48/EC on the safety of toys in respect of toys emitting RF EMF (microwaves).

Moreover, ensure all wireless product comply with Ecodesign Directive 2009/125/EC in order to save energy to radiate as low amount of RF EMF as possible.

Best regards
Petra Bertová and Kamil Bartošák
on behalf of the Europeans for Safe Connections

childs products
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