Title
FDA Guidelines on Toy and Childcare Products
Law
Fda Circular No. 2015-002
Decision Date
Feb 20, 2015
FDA Circular No. 002-15 simplifies the regulatory process for toys and childcare articles in the Philippines, placing responsibility on companies to ensure safety and quality, while the FDA strengthens post-market surveillance.

Scope and Coverage

  • Products covered include:
    • Toys for children under 14 years old.
    • Exempt toys such as:
      • Toys for children 14 years and above.
      • Toys for display or exhibits, not marketed in the Philippines.
      • Toys for personal or adult collector use.
      • Toys for donation or charitable missions.
    • Swings, slides, and similar indoor/outdoor family activity toys.
    • Childcare articles like feeding bottles, sippy cups, pacifiers, teething aids, bottle nipples, baby toothbrushes, and feeding sets.

License to Operate (LTO) Requirements

  • Companies must have a valid FDA LTO as Human Use Household Substance (HUHS) Manufacturer, Trader, or Distributor before e-notification.
  • Expired LTOs cause automatic disapproval of applications.
  • LTO renewal applications must be filed 3 months prior to expiration.
  • Documents required for toy exemption applications vary per category but generally include a Letter of Intent, laboratory test reports, notarized affidavits of undertaking, bills of lading, invoices, packing lists, and pictures showing compliance with labeling and packaging requirements.
  • Applicants for certain exemptions (e.g., display or donation toys) must obtain a Certificate of Exemption for LTO.
  • Exemption fees depend on the net worth of the shipment, ranging from PHP 1,000 to PHP 3,000.

Marketing Authorization

  • Valid FDA LTO and acknowledged notification serve as proof of product registration; clearance from the FDA CCRR is no longer required.
  • These documents are necessary for Customs release and to legally market TCCAs.
  • Post-marketing surveillance includes audits, laboratory testing, market sampling, recalls, and product seizures.
  • Non-compliant products are removed from the FDA website and market.

Applicability and Notification Procedure

  • Companies must notify FDA by securing an e-notification account and submitting complete product details online.
  • Notification includes product info (brand, model, age grading), product source, and declarations of responsibility.
  • Up to 5 SKUs per notification, from the same category and source, allowed.
  • Different product categories require separate notifications.
  • Non-functional or unsanitary donated TCCAs are banned from entry and must be re-exported.

Grounds for Disapproval or Cancellation

  • Companies with non-compliance history or failure to submit required documents.
  • Failure to provide compliant labeling and packaging pictures within 30 days.
  • Submission of incomplete or altered lab reports.
  • Mixing product categories in one application.
  • Product poses health risks based on advisories and warnings.

Changes of Information

  • Any amendments or changes require a new notification application.

Laboratory Test Reports

  • Must be complete, specific to each SKU, and from accredited laboratories.
  • Reports must be in PDF/PNG format and properly named.
  • Testing standards include PNS/ISO 8124 parts and phthalate testing where applicable.

Labeling and Packaging Requirements

  • Mandatory submission of pictures of packaging and labeling.
  • Compliance with RA 10620 (Toy and Game Safety Labeling Act) and its IRR required.
  • Labeling must include LTO number, age grading, warnings, instructions, and manufacturer information.
  • For small items, include leaflets/tags, cartons, or other labeling aids.
  • Non-compliance leads to penalties.

Transitory Provisions

  • Manual notifications no longer accepted from March 2, 2015.
  • Pending manual applications before this date will be processed under previous rules.

Required Documents

  • Authorization letter for account request.
  • TCCAs E-Notification Account Assessment Slip.
  • Official receipt or payment slip.
  • Laboratory test reports specific to product category.

Application Procedure

  • Request e-notification account via email with required details and authorization.
  • Use FDA website to fill online notification form with complete and correct data.
  • Upload scanned documents and pictures in appropriate formats and sizes.
  • Payment made at FDA cashier or Landbank using issued assessment slips.
  • Acknowledged notifications or disapprovals sent via e-notification account.
  • 30-day period to submit labeling and packaging pictures after acknowledgment; failure leads to cancellation.

Fees and Payment

  • PHP 100 plus PHP 10 legal research fund per notification.
  • Payments accepted via FDA Cashier or Landbank.
  • Fees subject to FDA guideline changes.
  • Assessment slips valid for 14 days.

Processing Time

  • Application processing period is 14 calendar days from payment verification.

Notification Validity and Cancellation

  • Valid for one year from acknowledgment.
  • New notification required after expiration for continued market sales.
  • Notifications cancelled if any item fails compliance, affecting all items within the same notification.

Separability Clause

  • Invalid provisions shall not affect the rest of the order which remains in effect.

Effectivity

  • Guidelines effective March 2, 2015.

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