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To: The Minister of Commerce and Consumer Affairs

Ban Lead From Kids’ Products

We are calling on the New Zealand government to ban lead from ALL children’s products. Many children’s items have fallen through the legislative cracks and can pose a danger to kids, including crockery, mugs, glassware, baby bottles and jewellery. We want these gaps and loopholes closed so that ANY product intended for kids under the age of 14 is safe from any lead in the total content of the product.

Why is this important?

There is NO SAFE LEVEL of lead exposure, and we think children's items should be 100% safe from this risk. Gaps in our legislative and regulatory regime allow toxic lead in many children’s items. It’s time we overhaul our outdated piecemeal laws and standards and, at a minimum, adopt the most stringent international standards on lead in children’s products. Our kids deserve the best protections too.

Lead exposure, even at low levels, can set children up for a lifetime of struggle. It can reduce IQ and cause speech delays, behavioural issues, impulsivity, aggression, ADHD and learning difficulties. It's linked to increased school dropouts, criminal activity and reduced earnings as an adult. In addition to brain damage, it also affects every organ system and can cause heart disease, kidney disease, cancer and is a contributing factor in most major health issues. Children are the most vulnerable to these effects due to their smaller size and still-developing brains.

This year, some NUK baby bottles were recalled in the USA and Canada due to lead paint on the surface of the bottle. They were not recalled in New Zealand because lead paint on baby bottles is not illegal here. This is unacceptable.

Also this year, Lead Awareness NZ coordinated a crowd-sourcing initiative where whanau across the country tested and found high lead levels on the surface of their mugs and glasses, including an alarming number of items clearly designed for children. Some of these are currently for sale in stores. This is unacceptable.

A Canadian environmental group has recently reported on the loopholes in their laws that allow high levels of lead inside toys' interior parts. We have the same loopholes in our laws. This is unacceptable.

Studies worldwide have found high levels of lead in painted playground equipment and play surfaces. We can’t find any laws limiting lead content in New Zealand playgrounds. This is unacceptable.

Australia recently joined the international movement promoted by the WHO to phase out lead from ALL paints, defined as allowing no more than 90 parts per million (ppm) lead. Although New Zealand limits lead in children’s paints and toys to this level, we still allow up to 1000 ppm lead in general use paints and we allow the sale of marine paints containing 800,000 ppm lead. While such general and marine paints aren’t technically children’s items, children live and play in painted environments and are vulnerable to harm from them. This is unacceptable.

New Zealand needs to do a better job of protecting children from lead, and we think children's products are a good place to start. Our legal controls are outdated and piecemeal, and unlike our international counterparts we don’t even monitor our young children for their lead exposure levels. There is much to be done in this area, but we need to start somewhere.

Let's allow our children to reach their full potential. Let's start by ensuring their products are safe for them.


Resources
- 2009 New Zealand Unsafe Goods Notice regarding lead in children’s toys (current):
https://gazette.govt.nz/notice/id/2009-go2660
(Limits the levels of lead that can “migrate” from a toy surface to 90 mg/kg. It’s understood this was based on the EU Toy Safety law from 1988. However, European lead limits have been updated twice since that time, with the current standard limiting lead migration to between 0.5 mg/kg and 23 mg/kg (depending on toy material). The US and Canada take a different approach and limit the total lead content of toys and children’s products, rather than migratable lead, to 90 mg/kg or 100 mg/kg lead in accessible parts (strictly defined), and a total concentration limit of 90 mg/kg for any surface coatings. New Zealand law has fallen behind. It is time for New Zealand to become a world leader by ensuring that our children’s toys and products are completely lead free.)

- ESR Report: Health Risk Assessment: Lead In Children’s Toys, May 2021
https://www.esr.cri.nz/assets/FW21014-Lead-in-Toys-FINAL-30-June-2021.pdf?fbclid=IwAR1uUKegI1pDssl4LQy1dJR_fIHjuFWp6NrrN5buS6Qa-Vm4ceqcOUio_H8

- Summary by Lead Awareness NZ on New Zealand’s ceramics standards
https://leadawarenz.blogspot.com/2022/08/regulations-on-leachable-lead-in.html

- NUK baby bottle recall
Leadsafe Mama summary: https://tamararubin.com/2022/07/july-28-2022-the-cpsc-finally-issued-a-recall-for-the-lead-painted-baby-bottles-that-we-reported-in-june-of-2021-but-they-only-recalled-one-of-at-least-six-lead-painted-designs-from-nuk/
United States recall: https://www.cpsc.gov/Recalls/2022/First-Choice-Glass-Baby-Bottles-Recalled-by-NUK-Due-to-Violation-of-the-Federal-Lead-Content-Ban-Sold-Exclusively-on-Amazon-com-Recall-Alert
Canada recall: https://recalls-rappels.canada.ca/en/alert-recall/nuk-first-choice-glass-baby-bottles-recalled-due-lead-excess-allowable-limit

- Report by Environmental Defence Canada https://environmentaldefence.ca/report/passing-the-buck/

- Studies on playgrounds
UK:
https://www.plymouth.ac.uk/news/playground-paints-should-be-closely-monitored-to-reduce-potential-danger-to-public-health
US:
https://www.cpsc.gov/Newsroom/News-Releases/1996/CPSC-Finds-Lead-Poisoning-Hazard-for-Young-Children-on-Public-Playground-Equipment
South Africa:
https://pubmed.ncbi.nlm.nih.gov/20218484/
Israel:
https://pubmed.ncbi.nlm.nih.gov/29754080/

- Australian Poisons Standard
https://www.legislation.gov.au/Details/F2022L01257
(Part 2, Section 7.1(2)(b) of the Poisons Standard provides that paints and tinters (other than anti-fouling or anti-corrosive paints) must meet a 90 ppm limit for lead. In addition, it is understood that anti-fouling and anti-corrosive paints (which currently have a 1000 ppm limit for lead) will be required to meet the 90 ppm limit by October 2023)

- Lead Awareness NZ
www.facebook.com/leadawarenessnz

Category

Updates

2022-10-26 16:50:17 +1300

100 signatures reached

2022-10-25 05:40:25 +1300

50 signatures reached

2022-10-24 21:03:59 +1300

25 signatures reached

2022-10-24 19:45:17 +1300

10 signatures reached