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eu commission, transparency and toy safety June 5, 2008

Posted by Bradley in : Uncategorized , comments closed

The Commission has published the final report of an expert group on Evaluating Business Safety Measures in the Toy Supply Chain. The fact finding exercise which led to the report was announced in a press release on what the Commission was doing about toy safety issued in November 2007. It’s an interesting report which raises some good questions, and makes a list of recommendations, including a focus on harmonisation of toy standards at the international level. There’s an issue about the need to make it easier for manufacturers of toys outside the EU to know what rules they need to comply with (this is, of course, a general issue about the limits to the usefulness of harmonisation initiatives):

Chinese manufacturers claim that it is difficult for them to fully understand the legislative approach in the EU whereby conformity with a certain harmonised safety standard does not necessarily mean the product is in compliance with all applicable safety requirements as set out in the legislation. Although efforts from the EU and the Chinese authorities, as well as the European toy industry, to inform the Chinese toy manufacturers about the applicable regulations and harmonised safety standards for toys in the EU have resulted in greater awareness, there is still a need to improve in particular the understanding of requirements that are regulated in nontoy specific legislation such as for certain phthalates and azo colorants.

On the other hand, the whole exercise doesn’t seem to be a model of transparency. The report does not identify an author, nor does it list the members of the expert group. It states:

This report reflects the results of an evaluation project undertaken under the direction of an independent expert group with the support and technical assistance of the European Commission. The contents of this document do not necessarily reflect the views of the European Commission and are in no way an indication of the Commission’s future position in this area. Neither the Commission nor any person acting on its behalf can be held responsible for any use that may be made of the following information.


An ad hoc expert group was established providing independent advice and consisting of representatives of the main stakeholders including manufacturers, importers, retailers, test laboratories, consumers and Member States. The Commission provided support and technical assistance to this group.

The Commission published one press release about Commissioner Kuneva presenting the report, and another press release which gives some information about the members of the expert group which states:

The group included following experts:

* Helen Amundsen (ANEC/BEUC)
* Wim Berkel (Dutch Food and Product Safety Authority)
* Jerome Billot (Carrefour)
* Alf Cash (Mattel)
* Natale Consonni (Istituto Italiano Sicurezza dei Giocattoli)
* Linda Crane (British Retail Consortium)
* Brian Ellis (Toy Industries of Europe)
* Ton de Koning (Dutch Food and Product Safety Authority)
* Daryl Scrivens (HASBRO)
* Sanda Stefanovic (SGS)

It’s not clear whether the “the group included” language is just eurospeak, or whether there were other experts also included who are not listed. And why make it anything other than really easy to find out who the experts were?

more weird uk government youtube videos June 5, 2008

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A couple of weeks ago the UK Government invited comments on its draft legislative programme for the next session, including via a youtube video with the title “The Prime Minister Launches “Your Voice””. The Prime Minister barely appears here:

consultation in the eu June 4, 2008

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In order to respond to the EU Commission’s consultation on an EU consumer safety mark it is necessary to specify whether you are “A consumer, professional user (e.g. hair-dresser, carpenter, doctor, etc.) or professional in the supply chain”, “An enterprise / enterprise association” or “A market surveillance or customs authority”. Presumably the distinction between the first two categories is meant to be between individuals and firms, even though enterprises could be enterprises comprising users of products as well as producers. If you pick the consumer etc route, identifying yourself with greater detail is optional. You have to say how much attention you pay to a range of issues when purchasing products, including safety, price, place of origin, and brand. And then there’s a question about which of these issues matter in the context of a strange set of products: mobile phones, ladders, light bulbs, teddy bears, computer game consoles, bicycle helmets, saucepans, carpets, t shirts, office chairs, shampoo, cheese, electric kettles, drilling machines, and cars. Perhaps I am missing something, but safety isn’t an issue I worry about when buying t shirts, and with respect to other products in the list I care quite a bit about environmental and ethical/social issues that the survey isn’t concerned with. So I didn’t submit a response.

british citizenship consultation a figleaf? June 3, 2008

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The other day the Law Society of England and Wales responded to the UK Home Office’s consultation on British Citizenship, The Path to Citizenship. The introduction to the response is quite disturbing:

The Law Society welcomes this opportunity to comment on the Government’s proposals regarding reforming the immigration system. However the Society is concerned that this consultation does not represent a genuine attempt to consult the public on the proposed changes to British citizenship, as we understand from recent correspondence that UKBA is already preparing to implement the proposals notwithstanding the fact that the consultation is still open. This calls into question the genuine nature of the consultation process.

Generally it’s a pretty critical response (with wording like “fundamentally flawed” cropping up as in “the proposed route to citizenship is fundamentally flawed”). And there are more criticisms relevant to the question of how Government manages consultations:

The Law Society responded in substantial detail to the Home Office’s initial consultation on ‘Simplifying Immigration Law’ in August 2007. The Home Office had suggested that, by the end of 2007, more concrete proposals relating to the simplification of immigration law would be published for further consultation. The Law Society, therefore, is disappointed that the proposals now published so belatedly in the consultation document are very general in nature and non-specific with respect to the details of their content. Since it is the Law Society’s understanding that the proposals of this chapter are to be included in a draft bill to be published in the summer, it is disappointed that the general nature of the proposals in the consultation document makes it impossible to provide meaningful comment which would constructively inform the preparation of a draft bill.

ask gordon brown June 3, 2008

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There’s still time to respond to Gordon Brown’s invitation to UK residents to ask him questions via youtube:

As usual, they have disabled the comments feature on youtube – although, of course, people have posted text comments online anyway, as well as their video questions, which aren’t all friendly. The Downing Street youtube page states that only UK residents may ask questions, although the terms and conditions suggest that if they get helpful questions from elsewhere Brown may choose to answer them. Here are the (patronising) terms and conditions:

Ask the PM” Rules of Engagement
Please ensure that your video is less than 30 seconds long.
You must be 13 years or above and submit your questions in English. We’d like to hear primarily from UK residents, but we reserve the right to consider questions from all over the world.
Your video must be uploaded to www.youtube.com/downingst before midnight on Saturday 21 June 2008.
Videos should broadly meet the same conditions as e-petitions as set out at http://petitions.pm.gov.uk/terms. Unlike e-petitions, however, we will accept lighter questions not necessarily linked to Government policy.
They should not contain any references to political parties or commercial endorsements, be aggressive or offensive, and are subject to the YouTube Terms of Use http://uk.youtube.com/t/terms and associated policies, including the Community Guidelines. Videos that do not comply will be discounted.
The Prime Minister will tape and upload video responses to a selection of the questions we receive. Questions will be selected based on their popularity with YouTube users, but we reserve the right to select any other questions at our discretion.
The Prime Minister will respond to the questions selected within a reasonable timeframe after voting closes.
The quality of the videos will be taken in account. Try to keep your camera, mobile or webcam steady, and speak slowly, loudly and clearly.
It’s good to provide context – please indicate who you are – tell us your name, and the town you live in.
Be original, use your creativity and your imagination. Make your video a success. Think outside the box!
By submitting a video, you also grant 10 Downing Street a licence to reproduce and communicate the video to the public at its discretion.
If you do not want to submit a question you can also participate by voting for the questions you think should be used. You can do this by viewing the questions here www.youtube.com/downingst and voting for your favourite ones.
Any personal data contained in the video or associated information supplied by you will be processed by YouTube in accordance with YouTube’s privacy policy, which you can find here: http://uk.youtube.com/t/privacy, and 10 Downing Street’s privacy policy, which can be found here: http://www.number-10.gov.uk/output/Page52.asp.

There’s a certain amount of scepticism about all this – increased, surely, by Brown’s lack of popularity. There’s a video response here, which Brown likely won’t answer. The videos tend to be longer than 30 seconds. Many, but not all, of them ask serious questions which Borown is nlikely to answer. There’s criticism from Called to Account, and more from Under Strict Embargo:

In my mind the YouTube channel, the Twitter feed and whatever online gimmick is announced next, is primarily about metaphor, the hope that some shiny digital zeitgeist will rub off on an increasingly lacklustre Prime Minister. Equally, it’s a clumsy attempt by the new Downing St communications team to ‘get with it’ and reduce the gaping void between their digital approach and that of the Opposition.

the cookie makes the deal June 2, 2008

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The BBC reports on a study by Holiday Inn:

About four out of five UK businesses believe the type of biscuit they serve to potential clients could clinch the deal or make it crumble, a survey says.
The outcome of a meeting could be influenced by the range and quality of biscuits, according to 1,000 business professionals quizzed by Holiday Inn.
The chocolate digestive was deemed to make the best impression followed by shortbread and Hob Nobs.

Is this just a British thing? I once knew someone who had been a VAT inspector who said that they treated businesses differently depending on what sort of biscuits they were served. And it always used to be important to give plumbers tea and biscuits. In Miami offering refreshment to people who come to do work in the house seems to be a bit unusual.