The content of heavy metals, such as lead, is currently regulated by the EU toy safety Directive, and the company made a voluntary decision in 1999 to avoid phthalate plasticisers altogether. They are now banned in the EU for use in toys that could be chewed or sucked by children under three years. Mr Trillingsgaard says LEGO tests its products - including monomers and additives - against specific migration limits set out in the EU food contact plastic Regulation. It also observes other staandards set for consumer products set by the German Federal Institute for Risk Assessment and the US Food and Drug Administration.
"We have had a policy not to use phthalates for a number of years," says Mr Trillingsgaard. "Sometimes in the past it was difficult to source components, such as external wiring…and we had to compromise our own policy by using ordinary wires because phthalate-free plastic wire coating was not available on the market." But the EU phthalates ban has helped, he says, and now alternatives are available on the market.
All raw materials are approved by LEGO’s chemical product safety team based on recipe evaluation and migration tests of chemical substances. Suppliers must ensure that any raw materials delivered are on the company’s approved list of raw materials. For purchased parts, suppliers are asked to sign a contract with LEGO as a guarantee for chemical compliance but the company then tests the finished product for content of heavy metals, phthalates, etc.
Much attention has focused on toys manufactured in China - a major centre for outsourced toy production - and where many of the products recalled last summer were made CW Search. LEGO only outsources three percent of its product volume to China. Nevertheless, Mr Trillingsgaard says: "We are more careful when we select suppliers in China and carry out more frequent audits. For our outsourced production, we do not allow suppliers to use materials other than those we have approved." The company carries out unannounced audits - some suppliers are audited once every three months, others once a year.
"We check this through random tests and audits and have our own quality control people in our suppliers’ factories. We have 50 people in China, nearly half of whom work in quality control covering LEGO production and inspecting outgoing products."
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