Warning labels are mandatory for a wide range of toys and other children’s products in the European Union. In this guide, we explain what importers and manufacturers must know about age warnings, choking hazard warnings, adult supervision warnings, and other warning labeling requirements.
Further, keep in mind that the examples in this guide might already be outdated, so you should not use this guide as anything but an introduction to the concept of warning labels for toys and other children’s products.
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Which children’s products require a warning label in the EU?
The Toy Safety Directive requires children’s products that pose potential dangers and injuries to children must bear warning labels on the products or their packaging indicating the type of hazards and instruction of use. It also mandates that warnings shall be preceded by the words “Warning” or “Warnings”.
EN 71 toy safety standards, which are harmonized under the Toy Safety Directive, also provide guidance on warnings for specific toys.
Other EN standards, concerning non-toys children’s products, might also cover warning labels – either on the product or product packaging, such as:
a. EN 13209-1 – Child use and care articles – Baby carriers – Safety requirements and test methods – Framed back carriers
b. EN 13209-2 – Child use and care articles – Baby carriers – Safety requirements and test methods – Soft carrier
c. EN 1130-1 – Crib and Cradles for Domestic Use
Which children’s products may require warning labeling?
Warning label requirements are applicable to a wide range of toys and other children’s products, including but not limited to the following:
- Toys that might be dangerous for children younger than 3 years, for instance, because of small parts
- Activity toys
- Chemical toys
- Roller skates, skateboards, and toy bicycles
- Aquatic toys
- Latex balloons
- Percussion toys
- Toys in food
- Imitations of protective masks and helmets
- Toys intended to be placed across a cradle
- Packaging for fragrances in olfactory or gustative games, and cosmetic kits
- Baby carriers
- Baby slings
- Cots, cribs, and bassinets
Age warnings: Toys not suitable for young children
The Toy Safety Directive requires that certain children’s products must bear age warning statements to inform the caregiver of the age limit for these products. For example, some toys or children’s products are not intended to be used by children under 36 months because they contain detachable or breakable small parts that could cause choking or suffocation hazards to young children.
Another example is products that are designed to be used by older children with different play behaviors than children of younger age groups, for the former ones have a more sophisticated mentality and better muscular ability than the latter ones.
Quote from Annex V: Warnings, Toy Safety Directive:
“Toys which might be dangerous for children under 36 months of age shall bear a warning such as ‘Not suitable for children under 36 months’ or ‘Not suitable for children under three years or a warning in the form of the following graphic:
These warnings shall be accompanied by a brief indication, which may appear in the instructions for use, of the specific hazard calling for this precaution.
This point shall not apply to toys which, on account of their function, dimensions, characteristics or properties, or on other cogent grounds, are manifestly unsuitable for children under 36 month”
Choking and ingestion hazards: Small parts
The Toy Safety Directive requires that children’s toys or products containing small parts shall bear a small part hazard warning statement, accompanying the indication of hazards such as choking, suffocation, or ingestion.
- Aquatic toys and inflatable toys
- Toys contained in food – for instance inside a cereals package
- Soft-filled toys and soft-filled parts of a toy
Strangulation hazard: Long cords
Toys and children’s products that have built-in cords that are long enough to form loops or chains to cause strangulation hazards to young children are required to carry a strangulation hazard warning.
- Karaoke with long cords
Adult supervision warnings
These types of warnings apply to toys that could cause injuries to children without the supervision of adults. Below, we list some classes of toys that need to bear adult supervision warnings.
The Toy Safety Directive requires that children’s toys with practical functions and can be used by adults as products should bear the adult supervision warning statement, and other relevant hazard warning statements.
In addition, these toys shall also accompany instructions for use to guide the users to the proper way to use the products.
- Kitchen sink toys
- Easy bake oven toys
- Cleaning tool set toys
- Woodworking tool set toys
“Warning: To be used under the direct supervision of an adult.”
Toys that are used in the water should also bear safety warnings and adult supervision warning statements.
- Pool floaties for kids
- Beach balls
“Warning: Only to be used in water in which the child is within its depth and under adult supervision.”
Toys in food
Small toys contained in food or co-mingled with food could pose choking and suffocation hazards to children. These products shall bear the hazard warning statement to inform the users that toys are inside the food packaging.
- Toys in cereal boxes
- Kinder Joy Surprise Eggs
- McDonald Happy Meal Toys
“Warning: Toy inside. Adult supervision recommended.”
Chemistry sets, plastic embedding sets, miniature workshops for ceramics, and similar toys that lead to a chemical reaction or similar substance alteration during use are classified as chemical toys.
- Science experiment kits
- Miniature workshops for ceramics, enameling, or photography
“Warning: Not suitable for children under 8 years. For use under adult supervision.”
Domestic use warnings
The Toy Safety Directive defines activity toys as toys intended for domestic use and their supportive structure shall remain stationary when involving the use by a child of activities like climbing, jumping, or similar.
- Paddling pools
“Warning: Only for domestic use.”
Protective equipment warnings
The Toy Safety Directive requires that products such as roller skates and toy bikes shall bear a warning on the product to remind the users of the dangers of falls or collisions caused during the use of products.
The warning mainly focuses on the fact that users shall wear protective equipment such as helmets, gloves, or knee pads.
- Roller skates
- Toy bicycles
“Warning: Protective equipment should be worn. Not to be used in traffic.”
Toys with cords longer than 220 mm and that are designed to be strung across a cradle or cot shall carry an entanglement warning to the product and the packaging to warn the parents of the potential hazard caused by such products.
- Ceiling light projectors
- Hanging rattle learning toys
- Teething rings
“Warning: To prevent possible injury by entanglement, remove this toy when the child starts trying to get up on its hands and knees in a crawling position.”
The Toy Safety Directive requires that children’s toys that contain substances that can produce fragrances shall bear an allergenic warning.
- Cosmetic kits
- Scented slimes
“Warning: Contains fragrances that may cause allergies.”
The Toy Safety Directive requires that toys that can generate high impulse sound levels should have an acoustic warning on the products or their packaging to warn the parent that such toys could hurt the hearing of the children.
- Toys using headphones or earphones
- Squeeze toys
- Percussion toys
- Cap-firing toys
- Voice toys
Warnings for other children products
The General Product Safety Directive (GPSD) states that consumer products that all products sold in the EU should be safe to use. This also includes children’s products that are not covered by any specific directive or EN standard.
Article 5 of the GPSD explains that importers and manufacturers should include relevant information to allow consumers to prevent risks. As such, warnings might be required also for children’s products that aren’t covered by the Toy Safety Directive, for example:
- Baby carriers
Importers and manufacturers of children’s products should confirm whether there relevant EN standards for their products exist, and comply with their warning requirements. If not, they shall consider the functions of the products, the foreseeable behavior of the children and address the product-related hazards to the consumers by providing warning statements or signs, if necessary.
Quote from Article 5, General Product Safety Directive:
“1. Within the limits of their respective activities, producers shall provide consumers with the relevant information to enable them to assess the risks inherent in a product throughout the normal or reasonably foreseeable period of its use, where such risks are not immediately obvious without adequate warnings, and to take precautions against those risks.”
Cribs and Cradles
EN 1130-1 is a standard that specifies the safety requirements for cribs and bedside sleepers with a maximum internal length of crib base of 900 mm. This product is intended to provide sleeping accommodation for infants until they are able to sit unaided or pull or push themselves up on their hands and knees.
This standard requires that the warning label of regulated products shall include the warning notice to remind the users of the types of danger that could occur when using the product, such as strangulation or suffocation hazards.
Framed back carriers
EN 13209-1 is a standard that publishes the safety requirements and test methods for child back carriers with frames that are intended to be used by children of weight below 18 kg. It also covers user instructions information.
EN 13209-2 specifies the safety requirements and test methods for baby soft carriers without an integrated supportive frame. This standard applies to soft carriers that are intended to support infants of weight less than 15 kg. It also covers user instructions information.
Should the warning text be printed on the product or the packaging?
Article 11 of the Toy Safety Directive states that you should place the warning text either on the product or packaging in a clearly visible, legible way. If appropriate, the warning statement should also be displayed on the user manual.
Quote from Article 11.2, Toy Safety Directive:
“The manufacturer shall mark the warnings in a clearly visible, easily legible and understandable and accurate manner on the toy, on an affixed label or on the packaging, and, if appropriate, on the instructions for use which accompany the toy. Small toys which are sold without packaging shall have appropriate warnings affixed to them.”
It’s important to not assume that manufacturers outside the EU are even remotely aware of EU warning labeling requirements. In fact, even some of the larger toys and children’s products manufacturers expect their customers to provide ready-made warning label files and clear instructions on the placement.
Instead, it’s always best to consult an expert to confirm all applicable and up-to-date warning labeling requirements and send an .ai or .eps file to your supplier before you enter production.