BTHA Guidance



Promoting environmental sustainability is a core part of our work at the BTHA. Our members make an annual commitment to reduce their environmental impact across product and packaging design, production and distribution wherever possible. To help our members achieve environmental best practice we provide comprehensive guidance and advice across a variety of environmental issues.

Sustainability in Toys

We recognise the need for toy manufacturers to work to reduce their environmental impact. Our members are committed to having a positive impact on the planet and show this ongoing commitment through initiatives to reduce waste by recycling and reusing, but also to build more sustainable materials into packaging and products.

We commissioned a study in 2012 to investigate the levels of toy and hobby packaging. Approximately 0.7% of retail packaging that enters the home comes from toy and hobby products and it is estimated that 90% of toy packaging could be recycled, of which 72-73% presently is. Toy packaging has a critical function as primarily it is there to protect toys and ensure that children have undamaged, safe toys to play with when they receive them. Toy packaging must also carry important safety information, a legal requirement of all EU toy companies.

When we look into the impact of toys on the environment, we also look into the life of a toy. Toys are a relatively unique consumer good as they are often reused, passed on or stored away compared to other product categories due to their considerable emotional and sentimental value. A study we undertook in 2012 to understand this behaviour showed that 70% of people pass toys on when they finish playing with them, with 62% giving them to family or friends, and 39% giving them to a charity. We found that the main barrier to passing on toys was people not knowing how to pass them on safely.

An updated study we undertook in 2019 suggested that 75% of people now passed on toys to family and friends when they finished playing with them, 64% gave them to charity (particularly among middle aged parents with more than one child) and 32% now sold them online (compared to 21% in 2012).  Parents were more likely to pass on toys so that other children could enjoy them and to clear space. As in 2012, parents said they would pass on more toys if there was easy access to places that accepted them, if toys were more durable and if they had more information about where and how to pass on toys safely.

Extending the life of toys through reuse enables toys to circulate for longer which has a positive impact on the environment. To help consumers pass on more toys, we have created our top tips to help consumers pass toys on safely.

        Top tips when passing on reused toys

Top tips on receiving reused toys

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Getting to grips with sustainability

We want to help all businesses, large and small, to reduce any negative environmental impacts of their business. To do this we have created guidance to illustrate the importance of sustainable business practices as well as creating a practical guide for small and medium sized companies to help them start the journey to minimise their environmental footprint.

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Sustainability Directives

Toy companies have to comply with various sustainability directives and regulations in the European Union. The requirements cover issues such as sourcing sustainable materials, as well as producer responsibility obligations for preparing batteries, electrical and electronic goods for recycling and reuse. We have produced a number of guidance documents to help our members understand and comply with these regulations.

Energy Related Products

WEEE Regulation

WEEE Open Scope – A change to the regulations from 2019

‘Open Scope’ means a change to the WEEE legislation to make all electrical items in scope of the regulations from January 2019 if they meet the published criteria and are not covered by a specific exemption. All WEEE producers need to review the products they declare under the regulations to ensure they remain compliant in 2019 and others may become obligated for the first time.

The UK has kept the current 14 EEE categories and from January 2019, although fitting into one of the 14 categories will no longer be used as a determiner for whether an electrical item is in scope or not, electrical products will still have to be placed in the category of closest relevance for reporting purposes.You can access a list of the products coming into scope for the first time from 2019 and which category they should be declared under HERE

For WEEE producers placing over 5 tonnes of B2C EEE products coming into scope from 2019, they will not have to begin financing the recycling of these items until 2020. 

You can access the Environment Agency scope guidance incorporating Open Scope HERE. This will help you to determine if your products are in scope. If you believe your products maybe in scope please don’t hesitate to contact the Comply Direct team of WEEE experts and they can confirm for definite – call 01756 794 951 or email

WEEE Open Scope

WEEE scope decision tree

Guidance Categories for WEEE Reporting

EU Timber Regulations

EU Timber Regulations

Batteries & Accumulators

Safety - Battery and Accumulators Guide

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UK Sustainability Requirements

In addition to European regulations, there are a number of UK-only requirements which toy companies have to comply with. Rather than product and packaging, these rules cover companies’ energy use. We have produced a number of guidance documents to help our members understand and comply with these regulations.

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The regulations governing the recycling and recovery of used packaging will be radically revised in the immediate future. These changes will have an impact on the choice of packaging systems used for goods, and on the costs imposed on producers and importers.

As set out in the government’s Waste and Resources Strategy, a suite of 4 consultation papers were issued in early 2019:

Revision of the Packaging Regulations
A tax on plastics containing less than 30% recycled material
Consistent collections by local authorities
A deposit-return system for some beverage containers.

  1. Producer Responsibility for Packaging Waste.
               The government has built on the EU Circular Economy package that was approved in 2018. The main aspects of the DEFRA consultation that will affect toy businesses are:
    – Major cost increase, to cover local authorities ‘full net cost’ for collection, sorting and processing of packaging waste.
    – Modulated fees, so that harder-to-recycle packaging bears extra costs.
    – Possible reduction or removal of the threshold, bringing smaller businesses into the regulations.
    – Possible change from the current sharing of responsibilities along the supply chain, to placing all responsibilities and costs at one point.
    – Separate approach for packaging that does not enter households
    – Increase in complexity of data to be reported.
    – Possible mandatory labelling to inform consumers about pack recyclability.
  2. Plastics tax
               This is a ‘Treasury’ consultation, looking to impose a tax on plastic packaging that does not meet a 30% recycled content. The size of the tax is not suggested, but it is intended to drive the choice of materials, so would be significant. The tax would be applied to empty packaging filled in the UK.  As most toys are packed abroad, the effect on most businesses will be slight.
  3. Consistent Local Authority collections.
    At present, each local authority decides what it will collect for recycling, and the method it uses. This not only introduces inefficiencies into the whole process, but also makes any national communication difficult. This DEFRA consultation aims to impose limited choice for authorities. However, the timescales to revise existing contracts means that any changes will take time.
  4. Deposit-return system
    This is not applicable to Toy products.

The results of the consultations will be published mid 2019, and further consultations will take place as the draft legislations are formulated. There is considerable political pressure on these issues.

These matters are devolved, and industry is strongly making the point the differing approaches by the four nations would introduce huge difficulties.

The BTHA is involved in representing our members’ interests.

Minimising the Costs of Producer Responsibility Compliance - Packaging, Electricals/electronics and batteries

Packaging changes 2019/2020

Quick reference guide to toy packaging

Design tips for sustainable packaging

Dealing with special packaging requests

Packaging essential requirements

RECOUP – Recyclability by design for plastic packaging

UK On-Pack Recycling Label

TRIMAN Labelling

The Green Dot Model

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BTHA Environmental Studies

To support our sustainability work and ongoing commitment to reduce our industry’s environmental impact we commission independent research.

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