Importer Labels - Toys (Safety) Regs 1995

[Asholay]

Hi all, I have a quick question regarding the Toys (Safety) Regs 1995 and the requirements to put labels on any importer product into the community.

Basically, can you use just a web address instead of putting a full postal address, assuming the web address provides a postal address in a contact area.

The legislation states that any of the information in s(1) can be abbreviated providing the importer can still be identified, and clearly a web-site provides this ability.

I personally think this would be okay, but would like to seek clarity from someone who perhaps has real experience of importer labels, and the Regs.

Thanks in advance.


10.—(1) ...no person shall supply any toy to which these Regulations apply and which does not have affixed to it or to its packaging the CE marking together with the name or trade name or mark and the address of the manufacturer if he is established in the Community or his authorised representative if he is so established or if neither is so established the importer into the Community in a visible, easily legible and indelible form, provided that the trade name or mark may only appear as an alternative to the name if such trade name or mark enables such manufacturer, authorised representative or importer to be identified.

(6) Any of the information mentioned in paragraph (1) above, other than the CE marking, may be abbreviated provided that the abbreviation enables such manufacturer, authorised representative or importer as is mentioned in that paragraph to be identified.

 

[Billmccallum]

The legal experts might disagree, but my feeling is that the regs state "may be abbreviated", a web site address is not an abbreviation its alternative text.

XYZ Ltd - postcode could be seen as an abbreviation.

 

[Asholay]

Thanks Bill, I see what you mean by the web-site being different text, rather than an abbreviated version of something.

I was angling myself at the purpose of the Regs - which is to enable contact with the importer if required - and this can still be achieved with a web-address - but don't want to risk falling foul of the rules.

I want to avoid an address at present because I'm only just starting-up and don't have a new fixed business address yet and thus would have to use my residential one (which might have legal implications as it's rented accomodation).