Buyer Beware Guide 2021

Buyer Beware:

A Consumer Guide to Spotting

Dangerous Kids Electronics on Amazon

A Consumer Guide to Spotting Dangerous Kids Electronics on Amazon

A new review of top selling kids electronics on Amazon finds millions of products entering households every year without basic safety certifications. In the surprisingly dangerous world of Amazon kids toys, here's what consumers need to know as holiday shopping begins.

Executive Summary

Kids electronics have experienced dramatic development over the last decade, becoming more advanced and less expensive than ever.
If you are a parent, odds are that you have purchased at least a few for your child. These electronics span a vast array of categories, from educational
tablets to kids games, and from music players to digital cameras.

This growth has been paralleled by the emergence of the internet as a leading platform for shopping, or what we call e-commerce. Consumers
can find just about any product. they can think of and frequently at a discounted price compared to big box retail. But there's another, dangerous
side to the story that consumers need to know.

What many consumers don't realize is that e-commerce platforms like Amazon are filled with unregistered, uncertified, and potentially unsafe products
that are cheaper because Amazon did not require their manufacturer to comply with regulations.

Platforms like Amazon have successfully defined themselves as marketplaces instead of as retailers. This makes it difficult for US government agencies
to enforce regulations that most brick and mortar retail has to comply with. Today, hundreds of thousands of independent sellers list products on
Amazon, often selling incredible quantities, without demonstrating any compliance with baseline U.S. safety standards.

This first-annual Buyer Beware report from COSMO Technologies, Inc. details an eye-opening new study conducted that demonstrates this reality all
too clearly. In a review of 250 top-selling kids electronics on Amazon, COSMO found that 50 percent of products listed had no claim or evidence of critical
safety certifications, with several products clearly in violation U.S. child data privacy regulations and Amazon's own policies for children's products.
Forty-seven percent of top selling kids electronics had no company website outside of Amazon, meaning no terms or conditions, policies,
or customer service, much less proof of safety certifications.

All told, these top-selling products account for roughly 400,000 unit sales per month and millions of untested, uncertified, non-compliant electronics in the hands of kids every year.

COSMO reached out to Amazon for comment on these findings and to ask how the platform plans to ensure compliance and safety for kids and families on its
platform going forward. An Amazon spokesperson initially responded, however ultimately declined to provide comment before publication of this report.

In recent years, parental concern about kids toy safety has grown. Yet this recent review suggests a need for continued awareness, as yearly reports of injury and
death from unsafe products remain high. Of all the kids' products that can pose harm, electronics stand out as both uniquely dangerous and deceptively innocuous
to consumers looking for low-cost fun or connection for kids.

In this guide, we will discuss what consumers need to know about Amazon and the kids device market.

1

We'll walk through why it matters and the
unsettling results of COSMO's review of top-
selling Amazon kids electronics products.

2

We'll cover which certifications parents should
look for on kids devices and what they mean.

3

And finally, we talk about how to find and
support family-safe products and brands.

While this may be a consumer guide aimed specifically at navigating the Amazon marketplace, you'll find this information relevant no matter where you do your
buying, especially as the holidays draw near. It's truly never been more important for consumers to shop smart when it comes to products for kids.

Table of Contents

1

The Scale of the Unregulated Kids Electronics Market

a. Regulation Roadblocks
b. What About Reviews?

2

The Problem of Non-Certified Kids Electronics

a. The Rise of Cheap Manufacturing and Third Party Sellers
b. Toxins, Data Breaches, and Why Kids are More Vulnerable Than Ever

c. Unsettling Findings From a Review of Top-Selling Kids Electronics on Amazon

3

The Power to Protect:
How to Pick the Good Products Among the Bad Apples

a. Overview of Certifications: What Consumers Need to Know
b. The 4-Step Consumer Check for Spotting Safe Kids Electronics

4

The Family-Safe Difference

5

Appendix

1

The Scale of the Unregulated Kids Electronics Market

Today, it's almost hard to recall a time when something you wanted online was more than a few days from being on your doorstep. Back in 1994 when Amazon
was founded by Jeff Bezos in a Bellevue, Washington garage, the concept of one-click shopping and same day shipping would have seemed outlandish. Google
wouldn't arrive for another four years and Facebook for ten.
Yet, in just the last 10 years, e-commerce has exploded at a staggering rate - led largely by the juggernaut Amazon. According to Statista, Amazon has held
45-50 percent of U.S. e-commerce market share from 2019 to 2021.

Infographic Source: Statista, 2021

Today, Amazon ships roughly 1.6 million packages per day and calls nearly one in three Americans (over 95 million) its Prime members. What's often forgotten is that 56% of sellers on the platform are third party sellers, which means an increasingly large percentage of Amazon’s core business is in the warehousing and delivery department, known as fulfillment.

While this exponential growth in Amazon-fueled e-commerce comes with many incredible benefits for consumers and sellers alike, there are consequences too.

"Big Tech" companies like Amazon and Facebook face a critical dilemma when it comes to growth. Their platforms have expanded at such a rate that they have become magnets for bad actors and so far have not taken the actions necessary to effectively regulate those bad actors

A stunning Wall Street Journal investigation from 2019 put a spotlight on this issue. The report's explosive findings can be summed up in this one except:

"A Wall Street Journal investigation found 4,152 items for sale on Amazon.com Inc.'s site that have been declared unsafe by federal agencies, are deceptively labeled or are banned by federal regulators—items that big-box retailers’ policies would bar from their shelves."

The prevalence of these products being sold on the world’s most trafficked consumer hub is concerning enough, but even more so given that the Wall Street Journal discovered 46% of these products shipped directly from an Amazon warehouse. Other concerning findings included: 157 items that had been officially banned by U.S. safety regulators 4 out of 10 children's products (a number of them labeled "Amazon's Choice") failed an independent safety review based on federal standards

These product failures have real world consequences. The Wall Street Journal report documents a tragic story of a motorcyclist's death following a crash while wearing an Amazon-purchased helmet which falsely claimed safety certification. The non-profit Kids in Danger reported in 2019 that 38 children died from defective products. This likely only captures a small portion of the actual magnitude of the problem.

As consumers, we may have more immediate access to the products we want, but there's a growing reality that it comes at a cost. Consumer education and awareness is a frontline safety concern, particularly for parents.

a. Regulation Roadblocks

How has this proliferation of dangerous products been allowed to happen in the U.S. on the largest e-commerce marketplace? You may be thinking to yourself - what about consumer protection agencies and regulators? This is what they do, right?

The problem is that while consumer protection regulations may be clear, actual regulatory enforcement is limited by Amazon's legal standing as a sales "platform" rather than an actual seller. In recent years there's been growing scrutiny of tech giants like Amazon, Facebook, Google and others as "Big Tech" struggles (or neglects) to regulate its own environment. The defense that continues to hold up in federal courts differentiates a seller, content producer, or other "owner" of goods or messages from the "platforms" that host them. It is extraordinarily easy to list any product on Amazon, and extraordinarily hard to hold bad actors, and Amazon itself, accountable.

Consumers need to know that federal regulation can only go so far. Without further laws or court precedents, Amazon as a platform can claim legal defense when dangerous, unregulated products on its site end up hurting consumers.

In a Brookings Center Report from February 2021, visiting fellow and former Federal Communication Commission (FCC) chairman Tom Wheeler writes,

"Taking advantage of policymakers' inaction, digital companies assumed a pseudo-government role to impose their own will on the digital marketplace. The result failed to adequately protect both the rights of consumers and the benefits of competition."

While further regulation is certainly possible, there's unlikely to be major changes in the near future, leaving consumers vulnerable and fending for themselves.

b. What About Reviews?

Data shows that consumers put quite a bit of faith in reviews. As the internet expanded with the dot-com bubble in the early 2000s, companies and consumers alike saw the remarkable crowd-sourced potential that transparent consumer reviews could bring.

The problem, like anything at scale, is that once the value of reviews was realized, they also became commercialized.

A study by BestSEOCompanies.com in 2019 found that a remarkable 39% of online reviews were unreliable. Of all categories ranked for unreliable reviews, electronics topped the list.

Source: Best SEO Companies / FakeSpot Analyzer

While reviews will continue to add some degree of value for consumers, it's important for buyers to realize how far companies will go to purchase favorable ones.
As documented by the Wall Street Journal, even being "Amazon's Choice" with a host of 4- and 5-star reviews is no guarantee of safety or quality.

For consumers, that means it's critical to be well informed and know what to look for.

2

The Problem of Non-Certified Kids Electronics

When it comes to unregulated Amazon products, electronics tend to be among the foremost offenders. Rapid advances in technology, from chip sets to
manufacturing, have brought what were once premium electronics within reach of everyday consumers. From music players to tablets, and from robotics to walkie-
talkies, these types of devices are novel, fun, and naturally enticing for kids and parents alike.

But these devices also carry particular and unique dangers. With electrical, material, and in some cases data components to consider, kids electronics may appear
simple, but understanding their actual safety is anything but.

a. The Rise of Cheap Manufacturing and Third Party Sellers

To understand the rise in unsafe kids electronics on sites like Amazon, it's essential to understand the backstory of low-cost manufacturing, China, and
the unprecedented access third party sellers now have to U.S. consumers.

A COSMO Technologies review of 250 top-selling Amazon kids electronics found the majority of products originating from China, based on Amazon listing details.

In 2010, after three decades of concerted central state effort and investment, China finally overtook the U.S. as the world's leading manufacturer, earning the title of "the world's factory." Kids toys in particular have become a staple export of China's manufacturing engine, with China accounting for almost 75% of the world's toys in 2020.

China's industrial rise has come with both concerted investment as well as concerns about product quality, compliance, human rights and environmental impacts. The growth in the counterfeit goods market may be the clearest example of how lower regulatory standards or weak enforcement can generate a multi-billion dollar industry. According to a 2017 report by the Commission on the Theft of American Intellectual Property, 87 percent of all counterfeit goods seized upon import into the U.S. came from China (including Hong Kong).

To be clear, the example of counterfeit product manufacturing is not characteristic of all Chinese manufacturing. Yet the massive expansion of access to
western markets via e-commerce platforms like Amazon and the Chinese equivalent Alibaba has created unprecedented demand for low quality, untested,
and counterfeit products coming from the world's leading manufacturing powerhouse.

As Amazon's strategy has shifted to third party sellers, the company's ability or willingness to police these kinds of stolen, unsafe, or uncertified products
has been questionable. A former Amazon employee quoted in the Wall Street Journal's 2019 report called Amazon's third party marketplace a "disaster
zone" and estimated that "80% of Amazon's third-party sellers didn't comply with federal, state or industry safety and labeling standards."

"Amazon doesn't require its third-party sellers to disclose their real-world locations or label the origins of their products," explained tech and
consumer goods specialist Leo Sun writing for the investment site Motley Fool. "In short, Amazon's third-party marketplace remains the Wild West,
and its growth matters more than its overall quality."

b. Toxins, Data Breaches, and Why Kids are More Vulnerable Than Ever

Every consumer knows the thrill of finding what appears to be a great deal. But to find the real costs on sites like Amazon, you often have to look beyond the price tag.

According to the annual 2020 Trouble in Toyland report by consumer watchdog group PIRG:

"For each of the last five years, the U.S. Consumer Product Safety Commission (CPSC) has documented that U.S. hospital emergency departments treated between 226,000 and 254,000 children with toy-related injuries every year. These numbers could rise in 2020, because kids are spending more time at home, and more of it with less supervision by work-at-home parents."

As consumers turn to unregulated digital marketplaces during the holidays, hovering mouses over Buy Now buttons, it's critical they understand the potential dangers of what they might be bringing into their homes. Leading concerns include:

Chemical dangers

Electrical dangers

Mechanical dangers

Data privacy dangers

Chemical Dangers

Kids toys in particular should be inspected for dangers related to materials and chemicals. There is a well-documented history of unsafe materials being used in kids toy manufacturing in order to reduce manufacturing costs. But it also has to do with children's vulnerability, as kids tend to lick or put things in their mouths and are more susceptible to health impacts of dangerous chemicals.

Leading chemical dangers in toys often involve substances like lead, carcinogenic materials such as Phthalats, and chemicals that can be harmful if swallowed, ingested, or come into contact with the skin.

Electrical Dangers

As electrical elements become staples of leading kids toys (think music players, wearable devices, robotics, and more), ensuring that your child’s toys are certified to be electrically safe is critical.

A 2020 CNN report highlighted the dangers that exist when this isn’t the case. The review found at least 1,500 examples, across more than 70 items (not only kids toys), of "products exploding, catching on fire, smoking, melting, causing electrical malfunctions or otherwise posing risks." The most shocking finding? These products were all a part of Amazon’s growing inventory of private label products called AmazonBasics.

Mechanical Dangers

For kids, small parts or sharp objects create safety concerns that would be less of an issue for adult devices. While all kids toys are required to have minimum size requirements for loose parts to prevent choking, this directive is not always followed by manufacturers. A Journal of Pediatrics study found that since the 1990s, emergency room visits for kids as a result of swallowing objects has more than doubled. Material dangers to look out for most commonly include things like choking hazards from small components, deceptively sharp toy edges, or unstable objects that could fall or collapse.

Data Privacy Dangers

Data privacy is an area of growing concern as the exploding market for IoT (internet of things) devices expands to kids electronics. As more inexpensive kids devices allow for location tracking, personal information storage, and more, it's critical for consumers to understand the implications.

In 1998, congress passed a landmark piece of legislation called the Child Online Privacy Protection Act - commonly referred to as COPPA. The law was designed to protect children’s data and prevent danger from predators online or companies seeking to target or profit from children’s data. However, compliance with and enforcement of COPPA has been spotty, even for large companies. The list of major companies that have been found in violation of COPPA over the years is troubling, including the likes of Matel and Hasbro, VTech, YouTube, and TikTok (formerly Music.ly).

While data privacy can seem abstract to consumers, the consequences - especially with kids’ data - are all too real. In a 2016 report for the Committee on Commerce, Science, and Transportation, Senator Bill Nelson outlined in stark terms the potential dangers that come from noncompliant connected kids toys:

"With respect to children's data, the improper disclosure of a child's personal information – including, for example, name, home address, online contact information, or actual location – could lead to inappropriate contact, sexual exploitation, or abduction."

c. Unsettling Findings From a Review of Top-Selling Kids Electronics on Amazon

With an understanding of the potential dangers across e-commerce marketplaces like Amazon, COSMO Technologies, a Denver-based design and
manufacturing company of family technology solutions, conducted a review of 250 top-selling kids electronic toys listed on Amazon's marketplace.

In order to provide consumers with a recent and highly relevant snapshot ahead of the holidays, the review aimed to identify the extent to which
leading Amazon kids electronics entering consumers' homes have any evidence of safety certifications or basic consumer-facing company
disclosures like websites, privacy policies or customer support. The review looked broadly at top-selling kids electronics products across all
markets, ranked by estimated monthly sales volume.

The review revealed a stunning lack of any evident safety measures or compliance across a majority of reviewed products, many of which carry the Amazon's Choice label. The review also revealed three bluetooth products in clear violation of COPPA compliance standards for kids connected devices.

50%

of products reviewed had zero mention or claim of any safety certifications or compliance.

28%

made some note or claim of certifications but provided no proof or detail of certification.

22%

of products had some level of proof or detail of safety certification.

47%

of reviewed products were from a company without any web presence outside of an Amazon listing.

Bluetooth data-transmitting devices were in clear violation of COPPA standards requiring consumer-facing data privacy policies.

Despite the products reviewed being among Amazon's top selling kids electronic toys, the majority of the companies represented were not big name brands.
The sellers representing most of the estimated monthly volume in kids electronics were often companies that had no website or consumer-facing
brand presence outside of Amazon.

This means, consumers will find no privacy policies, no customer service or contact information, and in most cases,
no evidence of any safety certifications.

Consumer-facing policies on websites are particularly relevant when it comes to compliance with COPPA. Products that store and transmit children's data must
provide consumers with clear policies around data storage and usage. This applies to the growing field of "smart toys" that enable connection via signals like
bluetooth and can potentially be hacked or misused if appropriate precautions are not taken.

In its review, COSMO identified three childrens' bluetooth products listed by sellers with no website or brand presence beyond an Amazon listing and no available
privacy policies. This finding represents a clear violation of COPPA standards.

To make the situation even more confusing, many of these top selling products carried the coveted "Amazon's Choice" badge in search results and on the product
listings. Many consumers take this to mean Amazon chose this product because they either stand behind it or approve of it in some way. In reality, the Amazon's
Choice badge is merely a label given to a product when Amazon's algorithm believes it is the best match for a specific keyword.

An article by SellerLabs from 2020 explained it this way, "...the eCommerce behemoth developed an algorithm to do the picking automatically. Their equation is based
on a series of inputs. The most important factor? The number of clicks and conversion rates on a given search term's results page." In short,

Amazon's Choice has no direct relationship with the quality, durability, and most importantly
the safety of a product - only how much it sells.

In total, COSMO found that the sales volume for products with no evidence of safety certification amounts to over 364,000 units every month. This stunning finding, alongside evidence of clear policy volition and non-COPPA compliant devices, suggests that widespread danger still exists across Amazon’s platform for kids and families.

COSMO contacted Amazon about these data-dangerous, non-compliant, and best-selling devices on its platform. A public relations spokesperson from

Amazon immediately responded when a summary of findings were presented. However, when asked by COSMO to provide on-the-record comment on the findings of the review, Amazon did not reply

Without any guidance from Amazon, and in many cases when there is not even a company website, consumers are left to guess whether a product meets any quality or safety standards. Based on this data it can be concluded that millions of untested and uncertified kids' electronic toys are being placed in children’s hands every year.

Note: See appendix for details on review methodology and full inventory of reviewed products.

3

The Power to Protect:
How to Pick the Good Products Among the Bad Apples

So far, you may be thinking that all the news is bad. Well fear not! Despite the many safety concerns that fill the kids electronics marketplace, there are steps
any consumer can take to spot the bad apples and keep kids and families safe with quality products.

a. Overview of Certifications: What Consumers Need to Know

When shopping for kids toys this holiday season, safety certifications are the gold standard. This proves a company has actually prioritized your and your
child's safety! To procure the certifications required by U.S. law, a company must submit products to credible third-party agencies for testing, pay substantial
fees, and pass rigorous testing covering material, mechanical, electrical, and chemical safety standards. In the U.S., this means complying with the standards
laid out in ASTM (F963), an internationally recognized, comprehensive set of toy safety standards that was adopted as the basis for U.S. regulation in 2009.

For companies to test and prove compliance with these standards requires significant investment, from increased time for product development to cost for
higher quality and safer materials. And it's exactly what consumers need to look for in products - especially if they come from third party sellers on
marketplaces like Amazon

But the world of safety certifications can also be confusing. What should you look for and what do certifications mean? Below is your one-stop shop for
everything a concerned parent or guardian needs to know about the leading safety requirements and certifications for kids toys

When shopping for toys or electronics for your kids, these certifications are the gold
standards to keep in mind for peace of mind:

1) Child Product Certificate (CPC)
Testing & Compliance (EN71 and ASTM
(F963) Compliance)

What it is: The Consumer Product Safety Commission (CPSC) in the U.S. requires CPC certification from third party testing for any children's products sold in the U.S. Testing standards required by law are based on EN71 and ASTM - these are essentially equivalent and internationally recognized toy safety standards that represent the true "gold standard" in safe children's products.

Why it matters: While CPC is not a seal that will appear on a children's product, any company looking to sell children's products in the U.S. or Europe must comply with these standards and undergo approved third party testing. Leading approved laboratories for this kind of comprehensive compliance testing include UL (Underwriter Laboratories) and SGS, which consumers can look for when shopping this holiday season.

2) SAR: Specific Absorption Rate

What it is: SAR is an important safety certification for any wireless toys emitting radio frequencies (RF), such as cell phones or walkie talkies. This test measures the rate at which radio frequency energy is absorbed by the human body.

Why it matters: This test is mandatory in the U.S. for applicable electronic devices and ensures compliance with FCC regulations to ensure your kid’s toy doesn’t emit dangerous radio waves that can harm the body’s cellular balance. For any signal-based kids toys like smartwatches, bluetooth devices, walkie talkies or etc., be sure to look for SAR certification.

3) FCC: Federal Communications Commission

What it is: The FCC certification mark is mandatory in the U.S. for electronic equipment and electronics that are manufactured or sold in the States. This important seal certifies that an electrical product complies with standards of the Federal Communications Commission regarding electromagnetic interference.

Why it matters: This certification is mandatory for most all kids electronics toys, meaning it's critical for consumers to be on the lookout for, especially when shopping online for low-cost electronics that may be manufactured overseas.

4) CEC: California Energy Commission

What it is: CEC certification is a test to ensure compliance with California Energy Commission Regulations. According to testing and certification provider TOBY, "The purpose of the implementation of the regulations is to improve the efficiency of electric products, saving energy, reducing emissions and greenhouse effect."

Why it matters: CEC certification shows a company has gone "above and beyond" to ensure that their product is not only safe for kids but safe for our world and environment.

5) RoHS: Restriction of Hazardous Substances Directive

What it is: ROHS is a mandatory European Directive aimed at reducing hazardous e-waste. According to the European Commission, "This Directive lays down rules on the restriction of the use of hazardous substances in electrical and electronic equipment (EEE) with a view to contributing to the protection of human health and the environment, including the environmentally sound recovery and disposal of waste EEE."

Why it matters: Once again, this certification goes a long way to showing a company's ethical and environmentally conscious practices - even if it is not required in the U.S. This gives consumers extra confidence in both the quality of the product and the company as well.

6) CB Scheme

What it is: The CB Scheme is an international program established and operated by the International Electrotechnical Commission for Electrical Equipment (IECEE) covering electrical and electronic equipment, mainly regarding battery standard and chemical content. This program provides proof of compliance across over 50 countries worldwide.

What it matters: CB Scheme certification is important to ensure the quality and safety of a toy's electrical circuit and the battery. It is yet another layer of confidence for consumers, knowing that the product in their child’s hands is certified safe in countries worldwide - not just the U.S.

7) CE:

What it is: CE marking is a legal requirement that allows for free trade of products within the EU/EEA. It is a mandatory marking that shows a manufacturer's product complies with the minimum product health, safety, and environmental requirements of all EU directives.

Why it matters: CE certification covers a wide range of electronics and material safety standards and certifications across countries in the EU. Seeing this certification once again shows a company selling in the U.S. has gone "above and beyond" to ensure consumer safety by global standards.

8) IP76

What it is: "IP" stands for "Ingress Protection" and is a certification that ensures a product is resistant to water and dust. For kids toys, this is particularly relevant from a durability and use standpoint.

Why it matters: If your kids are like most kids, they have a way of getting things dirty! Seeing IP67 gives consumers confidence that a kids product has been tested for basic durability and can stand up to a reasonable amount of exposure to water and other particles.

9) COPPA Compliance

What it is: COPPA compliance, while not a single specific certification, is critically important for consumers of connected kids devices. This U.S. regulatory law applies to devices such as kids smart watches, cell phones, apps, GPS trackers, or any other data-collecting, connected devices. In order to be COPPA compliant, a company must:

1 Give clear notice of their data collection practices (e.g. publicly available privacy policy)

2 Ensure parental consent for any resulting data collection

3 Protect the confidentiality, security, and integrity of personal information collected from children

Why it matters: In our connected world, data privacy matters more than ever. This is especially true when it comes to kids, as online hacking, predators, and other dangers grow more prevalent. Consumers looking for any connected kids devices this holiday season should look first for mention of COPPA compliance on the product listing or company website, as well as for a clear customer-facing privacy policy.

b. The 4-Step Consumer Check for Spotting Safe Kids Electronics

In the famous Sherlock Holmes detective stories, the inimitable sleuth is famous for saying "Elementary, my dear Watson" when asked how he solved the case. To some extent, solving the case of toy safety is the same.

Does the product listing claim or demonstrate certifications? Does the listing appear low quality with poor images or confusing descriptions? Can you find a company website related to the brand? How about any customer service contact information? These are the simple kinds of questions that are actually incredibly effective in weeding out the bad apples.

We’ve developed the following 4-step approach to help any consumer spot the devices to avoid and have confidence that they're bringing home family-safe products for their kids.

1. Know your Device

All kids' electronics will be different in one way or another. For example, while some devices will have moving parts, others may have batteries or radio communications. Knowing what type of device you have will help you understand what specific safety certifications are most important.

Some simple questions to ask include:

Power source: Is this device powered by AC power (wall plug), traditional battery, or some other power source?

Signal type: Does this device send or emit any signals or communication (e.g. radio waves for remote control cars, or bluetooth signal)?

Data transmitting: Is this a "connected" device that gathers or transmits data?

2. Find the Company Behind Your Device

As explained previously, Amazon’s marketplace is available to virtually anyone. While there’s no requirement that a company or brand have a web presence outside of Amazon, this is something consumers should look for when considering a kids toy. Jump out of Amazon and simply Google the name of the brand selling the product. You shouldn’t have a hard time finding their website. If they don't have a website, this should raise immediate questions about the company and the potential consumer experience. At minimum, the seller has not prioritized consumer-facing service, or worse, they have something to hide.

If a company lacks any basic web presence, this means they also lack a legal privacy policy or terms and conditions, which should cause any consumer to pause. Potentially even more problematic, the company lacks any form of customer service if you happen to have questions or concerns.

3. Look for the Safety Certifications

Priority Standards: When considering most common types of kids electronics, start with the below “gold-standard” certifications for consumers in the U.S. While the below regulatory compliance and certifications may not be applicable to every kids electronic toy, together they cover most types of devices and should be clearly stated on a company’s listing and website:

EN71 & ASMT (F963) Compliance(e.g. UL or SGS certified): gold standard certification of regulatory compliance and third party testing for kids toys in the US and Europe.

SAR: Mandatory certification for any toys electronics emitting frequencies (e.g. remote controlled toys).

COPPA Compliance: Mandatory requirement for any "connected" kids toy or app that saves or transmits data.

Above & Beyond Standards: For added peace of mind, the below certifications prove material durability, environmentally conscious practices, and international compliance against the regulations of other nations:

RoHS:A European directive proving compliance that reduces hazardous e-waste.

CE:A compliance seal demonstrating safety requirements for legal trade within EU countries (non-mandatory in the U.S.).

IP67: A test for durability and reliability of a product against basic water and dust particles.

CB Scheme:A compliance program covering over 50 countries’ regulations, especially in regard to battery and chemical safety.

CEC:A California-based certification that demonstrates additional environmental safety related to energy consumption and emissions.

When shopping for kids electronics, start with these "Priority Standards" as applicable to your specific device. If none of these certifications are claimed or proven, it’s a good idea to move on.

If you find a claim or proof of the applicable mandatory compliance/certifications, then check to see if any additional certifications are noted from the "Above & Beyond" category. This will help give additional peace of mind that the company has placed safety first as a priority for your family.

For consumers wanting to go the extra mile, there’s nothing that should stop you from contacting the company and asking for documentation related to acquired safety certifications. This should be documentation the company has readily available.

4. Conduct the "Family-Safe Sniff Test"

If you've gone through steps 1-3, congratulations! You likely have a good product on your hands. But there's one final step we recommend any consumer take in order to ensure safety for their family. We call it the "Family-Safe Sniff Test."

If you've reviewed the Amazon listing and found a website, simply ask yourself this: does it sound right? How does the company present itself? Is the wording and language clear? These five elements are particularly important:

Clear language

Customer service contact information

Privacy policy & terms and conditions

Realistic price

Robust selling history

We recommend this step because, simply put, there's nothing that stops a company from claiming safety certifications when in fact they have none. If a company both
claims and details specific safety certifications, has a legal privacy policy and/or terms and conditions, along with a quality website, contact information, market-
reasonable price, and a clear/robust selling history, these collectively provide a critical final layer of confidence for consumers.

Put together, the above four steps will help consumers safely and confidently navigate a wild and unpredictable marketplace of online kids electronics. This may mean a
bit of extra time or research before clicking the Buy Now button, but the safety of our kids is more than worth it.

4

The Family-Safe Difference

When it comes to your family this holiday season, anything short of truly "Family-Safe" is unacceptable. Throughout this report we’ve explored the sad reality that
consumers face when looking for kids electronics online, as well as what they can do to ensure that only safe products enter their household.

What does it really mean for a product or a company to commit to being "Family-Safe"? At COSMO Technologies, we think it comes down to a few simple, but
absolutely critical things. All are elements that prove a company has put your family FIRST - your well being, your safety, your happiness. We call it the COSMO Family-
Safe Promise and it's at the core of who we are:

1)Family First Mission: We are all about technology that puts family first.

2)Commitment to Quality: We're uncompromising about safety, quality, and reliability in our products. It’s what kids and families deserve.

3) Privacy as Primary: Your data should be yours. Period. That's why we hold ourselves to the highest data security standards and commit to never selling your information.

4) Environmentally Friendly: We're committed to protecting kids as well as the world we will leave them. That’s why we’re proud to offset 100% of the plastic we use.

5) Affordability for All: Safety, quality, and connection shouldn't be a premium. We believe in creating great products at a family-right price for all.

Learn more about COSMO Technologies and our best-selling JrTrack 2^™ Kids Smartwatch.

Click here to open the full Report (PDF)

View Full Report

5

Appendix:

1. Overview of Methodology

a. Data

COSMO's review of top-selling kids electronics on Amazon was conducted using Helium 10 data reports of Amazon category "Kids Electronics," as well as sub-categories "Electronic Pets, MP3 Players, Walkie Talkies."

Top 250 list reviewed by COSMO Technologies is reflective of estimated monthly sales volume as shown in Helium 10 reports for the above categories as pulled on October 5, 2021. Helium 10 lists are estimates of sales volume and may not be exact.

b. Review Methodology

COSMO reviewed each listing for:

Country of origin, as noted on the Amazon listing

Any individual external website/web presence beyond the Amazon listing

Any evidence of privacy policies or terms and conditions (if a site was found)

Any evidence on the Amazon listing (and if found, website) for mention or evidence of safety certifications, third-party testing, or compliance.

Any specific certifications: RoHS, CE, SGS., CEC, CB Scheme, SAR, IP67; Any U.S. approved third-party testing: UL, SGS, etc.; Any note of compliance: COPPA, ASTM (F963), or EN71.

COSMO also flagged any listings that were designated as Amazon’s Choice during the review process, conducted from October 5 - 12, 2021.

c. Categorization & Findings

Reviewed products were noted as one of three categories:

1)

Lacking claim or evidence of any compliance, testing, or safety certifications.

2)

Showing claim of compliance/certification/ testing, but lacking any clear detail or evidence/documentation

3)

Showing claim and/or evidence of clear safety certification/testing/compliance

Companies with products falling into categories 1 and 2 and with contact information available were contacted by COSMO Technologies for detail or evidence of required certifications. If any detail or evidence was provided within two weeks, the product(s) was/were reclassified as category 3.

COSMO identified three products that were clearly designated as bluetooth kids devices yet had no company/brand web presence beyond Amazon. By U.S. COPPA law, companies selling such data-storing and transmitting devices specifically for children are required to have consumer-facing policies available to the public, detailing the use of such data (i.e. "privacy policy"). These were noted in the research as clearly non-COPPA-compliant products being sold on the Amazon platform.

COSMO Technologies reached out to Amazon public relations on October 27, 2021. An Amazon public relations manager quickly responded to a summary of findings. However, when COSMO asked for any on the record comment from Amazon regarding the findings, the company declined to respond further.

2. Complete Inventory of Products Reviewed During 2021 Buyer Beware Study