How to CE mark a toy in 5 steps

This guide explains how the CE marking process for toys works in practice. We break down the requirements of the Toy Safety Directive into 5 actionable steps from the perspective of the manufacturer. Note that a manufacturer in this context also refers to brand owners.

Step 1: Find applicable directives

The CE marking requirement for toys is set by the EU Toy Safety Directive, which defines toys as follows:

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This Directive shall apply to products designed or intended, whether or not exclusively, for use in play by children under 14 years of age (hereinafter referred to as toys).

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As such, products for use in play for children between the ages of 0 to 14 are deemed to be toys, and must therefore be CE marked. That being said, children’s products that are not toys are not covered by the Toy Safety Directive.

Once this is established, you must also determine the age group of your toy. The reason is that the age group determines:

a. Small parts requirements

b. Labelling requirements

c. Testing requirements

This cannot necessarily be done arbitrarily. Instead, you should follow an EU guidance document and request assistance from an expert.

Note: The Toy Safety Directive will be replaced by the Toy Safety Regulation. The new regulation changes the process and requirements for CE marking toys.

Step 2: Find applicable harmonised standards

Harmonised standards provide technical guidance on how to practically ensure that your toy complies with the general safety requirements set by the Toy Safety Directive.

In this step, you must identify all applicable harmonised standards for your toy. Here is the list of harmonised standards under the Directive:

EN 71-1: Safety of toys – Part 1: Mechanical and physical properties

EN 71-2: Safety of toys – Part 2: Flammability

EN 71-3: Safety of toys – Part 3: Migration of certain elements

EN 71-4: Safety of toys – Part 4: Experimental sets for chemistry and related activities

EN 71-5: Safety of toys – Part 5: Chemical toys (sets) other than experimental sets

EN 71-7: Safety of toys – Part 7: Finger paints – Requirements and test methods

EN 71-8: Safety of toys – Part 8: Activity toys for domestic use

EN 71-12: Safety of toys – Part 12: N-Nitrosamines and N-nitrosatable substances

EN 71-13: Safety of toys – Part 13: Olfactory board games, cosmetic kits and gustative games

EN 71-14: Safety of toys – Part 14: Trampolines for domestic use

EN 62115: Electric toys – Safety

The first three parts are applicable to most toys, while the rest apply to specific types of toys. Ensuring compliance with these standards may involve the following actions:

1. Adjust your technical drawings to ensure mechanical safety

2. Procure materials that don’t contain restricted chemicals and heavy metals

3. Procure materials that comply with the flammability requirements

Step 3: Create label file

Now that we have ensured compliance with applicable harmonised standards, it’s time to prepare the labels that will be affixed to the toy and its packaging.

CE mark

The CE mark must be affixed to the product, packaging, or instructions.

Traceability information

The following information must also be affixed product, packaging, or instructions:

• Product name
• Model number, serial number or batch number
• Manufacturer name
• Manufacturer address

Warnings

Products containing small parts and certain other products require warning symbols. These can be found in Annex V of the Toy Safety Directive.

Note that warning symbols and texts cannot be used as a substitute for toy safety. These are only accepted in specific situations.

Step 4: Toy safety testing

Verifying compliance with harmonised standards and ensuring that your product is correctly labelled requires that your toy undergo third-party testing.

Here are some companies providing toy safety testing services:

• QIMA
• TUV Rheinland
• SGS
• Eurofins
• Bureau Veritas
• Intertek

You must submit product and packaging samples to the lab. Once received, these will undergo a testing process resulting in a test report. This test report is the basis for the Declaration of Conformity and part of the technical documentation described in the next step of the process.

Step 5: Create documentation

The Toy Safety Directive requires that manufacturers issue documentation prior to completing the CE marking process. An overview of the various documentation requirements is below.

Declaration of Conformity

The Declaration of Conformity is a self-issued document summarising information about the product, manufacturer, and the standards the product is compliant with. You must issue one Declaration of Conformity per toy.

Here is an overview of the information it must contain:

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1. No … (unique identification of the toy(s))

2. Name and address of the manufacturer or his authorised representative:

3. This declaration of conformity is issued under the sole responsibility of the manufacturer:

4. Object of the declaration (identification of toy allowing traceability). It shall include a colour image of sufficient clarity to enable the identification of the toy.

5. The object of the declaration described in point 4 is in conformity with the relevant Community harmonisation legislation:

6. References to the relevant harmonised standards used, or references to the specifications in relation to which conformity is declared:

7. Where applicable: the notified body … (name, number) … performed … (description of intervention) … and issued the certificate:

8. Additional information:

Signed for and on behalf of:

(place and date of issue)

(name, function)(signature)

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This document can be requested by the customs authorities, market surveillance authorities, and marketplaces like Amazon to verify that your product is compliant.

Technical Documentation

Technical documentation is a set of files that provide technical information about the product. It also contains test reports, label copies, packaging artwork, factory information, and other relevant details.

The following documents must be included:

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(a) a detailed description of the design and manufacture, including a list of components and materials used in the toy as well as the safety data sheets on chemicals used, to be obtained from the chemical suppliers;

(b) the safety assessment(s) carried out in accordance with Article 18;

(c) a description of the conformity assessment procedure followed;

(d) a copy of the EC declaration of conformity;

(e) the addresses of the places of manufacture and storage;

(f) copies of documents that the manufacturer has submitted to a notified body, if involved;

(g) test reports and description of the means whereby the manufacturer ensured conformity of production with the harmonised standards, if the manufacturer followed the internal production control procedure referred to in Article 19(2); and

(h) a copy of the EC-type examination certificate, a description of the means whereby the manufacturer ensured conformity of the production with the product type as described in the EC-type examination certificate, and copies of the documents that the manufacturer submitted to the notified body, if the manufacturer submitted the toy to EC-type examination and followed the conformity to type procedure referred to in Article 19(3).

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The technical documentation can be requested by market surveillance authorities to assess whether your product is compliant.

User instructions

Toys must be accompanied by instructions and safety information when necessary. Keep in mind that user instructions cannot be used as a substitute for ensuring compliance with applicable EN 71 standards.