• Toy Safety Standards in the European Union: A Complete Guide

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    Toy Safety Standards in the European Union
    Planning to import and sell toys in the European Union? In this guide, we provide the basics of toy safety standards, documentation and labeling requirements, including EN 71, CE marking, REACH, RoHS Directive, and electronic toys’ standards.

    Mentioned Products

    • Wooden toys
    • Plastic toys
    • Soft toys
    • Educational toys
    • Electronic toys

    EN 71 Toy Safety Directive

    EN 71 specifies safety requirements for toys, and it might also cover other children’s products sold in the European Union.

    EN 71 standards include 13 parts covering various aspects of toys and children’s products, which include flammability, physical properties, finger paints, and more.

    Further, EN 71 also regulates graphical symbols and other labels for toys.

    EN 71 Parts

    Here is an overview of the 13 EN 71 standards:

    • EN 71-1: Mechanical and physical properties
    • EN 71-2: Flammability
    • EN 71-3: Specification for migration of certain elements
    • EN 71-4: Experimental sets for chemistry and related activities
    • EN 71-5: Chemical toys (sets) other than experimental sets
    • EN 71-6: Graphical symbols for age warning labeling
    • EN 71-7: Finger paints
    • EN 71-8: Swings, slides and similar activity toys for indoor and outdoor family domestic use
    • EN 71-9: Organic chemical compounds – Requirement
    • EN 71-10: Organic chemical compounds – Sample preparation and extraction
    • EN 71-11: Organic chemical compounds – Methods of analysis
    • EN 71-12: N-nitrosamines and N-Nitrosatable Substances
    • EN 71-13: Olfactory board games, cosmetic kits, and gustative games

    It’s often the case that more than one EN 71 part is applicable to a certain product. We recommend that you contact a testing company to provide their assessment, to confirm which exact EN 71 applies to your product. This is often provided free of charge when asking for an EN 71 lab testing quotation.

    EN 71 Lab Testing

    Third-party lab testing is mandatory in most cases when you are importing and selling toys in the European Union. Therefore, we recommend that you contact and book EN 71 testing via accredited testing companies such as QIMA, TUV, Bureau Veritas or others.

    Note that the EN 71 test report is critical when you are importing toys, such as educational toys or wooden toys, to the European Union. Market surveillance authorities in the EU member states often request EN 71 test reports from importers and manufacturers. Without a valid and verifiable test report, your products will likely be subject to a forced recall and sales ban,

    EN 71 testing costs

    EN 71 lab testing costs depend on the product type, number of materials, colors, and type of materials. Products consisting of numerous materials, components and colors are therefore more expensive to test, as compared to more basic toys made of only one or two materials. As such, EN 71 lab testing can cost anything from a few hundred dollars to several thousand, per product.

    Risks

    Far from all toy manufacturers can ensure product compliance with EN 71. As such, it’s essential to get your products lab tested before being imported to the EU.

    CE Mark

    EN 71 covered products must be CE marked. Also, importers and manufacturers need to issue a Declaration of Conformity (DoC), a user manual, and a technical file. More details follow in this guide.

    CE Marking

    CE mark

    As mentioned above, toy products must carry the CE mark to indicate conformity. The CE mark must be permanently affixed to the product, packaging, and user manual.

    CE label file

    You should expect your supplier to create the CE label file for your toy products, even if they are fully aware that the product is set to be exported to the European Union. Instead, you should provide a digital CE label file in .ai or .eps format with the information below:

    • Dimensions
    • Position
    • Color
    • Print type

    It is possible that you must include the CE mark in the user manual files and products’ packaging as well.

    Risks

    Toy manufacturers in China and other countries outside the EU are not compliance experts. Assuming that your supplier is aware of the CE marking requirement is risky.

    CE Documentation

    Besides the CE mark, you will also need to issue other documents, including user manual, technical file, and declaration of conformity.

    Declaration of Conformity (DoC)

    Importers or manufacturers need to issue the DoC with the information below:

    • Produce identification/SKU (e.g. Teddy Bear A)
    • List of EN 71 standards or directives
    • Product features
    • Location
    • Name and address of the manufacturer/importer
    • Responsible individual

    The DoC is the main document that is often required by customs authorities, national market surveillance authorities, retailers or distributors. The DoC must also be supported by a valid test report, corresponding to the list o EN 71 standards and directives.

    User Manual

    A user manual is also required for toy products sold in the European Union. The user manual should include items such as:

    1. Instructions on how to install the product

    2. An overview of the relevant parts and part names of the product

    3. Safety instructions

    4. Instructions on how to use the product

    5. Instructions on how to recharge and/or refill the product

    6. Instructions on how to dispose of the product in an environmentally friendly manner

    There might not be enough space to place the CE mark or other symbols on your products. In this case, it is common to include the CE mark in the user manual instead.

    Technical File

    Additionally, you should cover all relevant designs, materials, labels, packaging, and other files in a technical file. Here is an overview of the information that must be included in your technical file:

    • Bill of materials
    • Design drawings
    • Label files
    • Packaging files
    • List of applied standards and directives (e.g. RoHS)
    • Test reports
    • QC reports
    • Risk assessment

    Test Report

    The technical file must also attach with relevant test reports correspond to applicable EN standards as stated on the DoC.

    REACH

    REACH applies to all consumer products including toys sold in the European Union. REACH sets limits, and addresses the use of hazardous substances in all consumer products, such as chemicals, heavy metals, and pollutants.

    It is illegal to import and sell toys and other products in the European Union that do not comply with REACH.

    Here are a few examples of regulated substances:

    • Lead
    • Cadmium
    • Mercury
    • Hydrazine
    • Acrylamide

    Substances of Very High Concern (SVHC)

    The European Chemicals Agency (ECHA) adds new substances to the list of SVHC without a fixed schedule. Importers don’t necessarily need to review the list on a regular basis. Instead, third-party testing companies can confirm that your product is compliant with up-to-date substance requirements.

    Lab testing

    There are several companies that offer REACH testing for toys, such as QIMA, Bureau Veritas, and SGS. We recommend that you book a REACH compliance test before your products are shipped to the European Union. It is the only way to verify that your toy products are REACH compliant.

    Testing companies

    Here are some companies offering REACH compliance testing:

    • TUV
    • Intertek
    • SGS
    • QIMA

    You can find more companies in this guide.

    Costs

    REACH testing starts from $200 per material. The cost can increase due to different items and colors. You can always request a free quotation from testing companies for your toys.

    Learn more

    You can learn more about REACH lab testing in this guide.

    Electronic Toys

    If you are planning to import electronic toys such as remote control cars, there are more safety standards that might apply, including LVD, EMC, RoHS, and RED. Notice that these requirements apply in addition to EN 71 and the other regulations mentioned in this article.

    Low Voltage Directive (LVD)

    The LVD applies to electronics product including electronic toys. If your electronic toys are equipped with an input, or output, voltage ranging between 50 to 1000 volts AC, and 75 to 1500 volts DC, you need to comply with LVD.

    AC Adapters

    For AC adapters with an input voltage ranging between 110 to 240 V, and an output voltage of 5 V, for example, you will need to comply with the AC adapters requirements specified in the LVD. AC adapters are often used for video game consoles, RC toys, and other related products.

    LVD Test Reports

    Your supplier needs to provide a verifiable LVD test reports issued by accredited testing companies for electronic toys. Otherwise, we recommend that you book third-party testing when importing to the European Union.

    Some leading testing companies including Bureau Veritas, Intertek, TUV, and SGS, provide LVD testing for electronic products.

    Importing electronic toys without verifiable LVD test reports may result in a heavy fine and even forced-recall on your products. The national market surveillance authorities in the EU country you sell the toys may request test reports and DoC at any time to ensure product safety in the European Union.

    LVD Testing Costs

    LVD testing cost starts from a few hundred to several thousands of dollars. It can also increase due to the complexity of the product.

    CE Mark

    LVD covered products, including certain types of electronic toys, must carry the CE mark. In addition, you must also need to issue a DoC, user manual and technical file for your toy products. For more information, have a look at the relevant sections above concerning CE mark and CE documentation.

    EMC Directive

    The Electromagnetic Compatibility (EMC) Directive limits electromagnetic emissions from equipment to ensure that your electronic toy does not disturb other electronics or electrical items. This may apply to the battery, AC adapters or other parts of your toy products.

    EMC Test Reports

    Most suppliers cannot provide EMC test reports. However, you must try to request an EMC test report from your supplier, or you should book third-party testing when importing electronic toys to the European Union.

    EMC Directive Testing Costs

    EMC testing cost starts from a few hundred to several thousands of dollars. It can also be higher, usually due to the complexity of the product.

    CE Mark

    EMC directive covered products must be CE marked. Also, importers and manufacturers need to issue the Declaration of Conformity (DoC), user manual, and technical file.

    RoHS Directive

    The Restriction of Hazardous Substances Directive (RoHS) limits the usage of certain substances such as heavy metals in all electronic products. The restricted substances include:

    • Lead (Pb)
    • Mercury (Hg)
    • Cadmium (Cd)
    • Hexavalent chromium (Cr6+)
    • Polybrominated biphenyls (PBB)
    • Polybrominated diphenyl ether (PBDE)
    • Bis(2-Ethylhexyl) phthalate (DEHP)
    • Butyl benzyl phthalate (BBP)
    • Dibutyl phthalate (DBP)
    • Diisobutyl phthalate (DIBP)

    These restricted substances can be found in paint, batteries, and metallic parts of toy products.

    RoHS Components

    You must mention RoHS compliance to your supplier prior to the manufacturing process. The main reason is that they can only use RoHS compliant components for your product.

    RoHS Lab Testing

    If your supplier cannot provide RoHS test reports, you can book a third-party lab testing for RoHS compliance. RoHS testing is on a per-component basis (often starting from $10). However, the total cost could add up to thousands of dollars, depending on the complexity of the overall product.

    Here are some accredited companies offering RoHS testing:

    • QIMA
    • Bureau Veritas
    • SGS
    • Intertek
    • TUV

    CE Marking

    This is also a CE marking directive, those toys covered under the RoHS directive must carry the CE mark.

    RoHS Symbol

    RoHS is not an official compliance mark. It is used to separate RoHS compliant components from non-RoHS components. Therefore, the RoHS symbol has no legal meaning or standing.

    Radio Equipment Directive (RED)

    The Radio Equipment Directive (RED) regulates all radio-enabled devices, which can in some cases include certain types of electronic toys. If your toy products include features such as asl Wi-Fi, RFID, Bluetooth, 3G, LTE, and 5G enabled devices, then they are also covered under the Radio Equipment Directive.

    Devices

    • Wi-Fi enabled toys
    • Bluetooth enabled toys
    • 3G enabled toys
    • 4G/LTE enabled toys
    • 5G enabled toys
    • Toys with RFID devices

    RED Test Reports

    Only a few electronic manufacturers can provide RED test reports. Therefore, third-party testing is the only way to verify RED compliance when importing electronic toys. Some testing companies such as TUV, Intertek, SGS, provides RED testing for electronic toys.

    RED Testing Costs

    RED testing starts from $200 per material. It can increase due to different items and colors. You can always request a free quotation from testing companies for your products.

    CE Mark

    RED covered products must be CE marked. Also, importers and manufacturers need to issue the Declaration of Conformity (DoC), user manual, and technical file.

    WEEE Symbol

    WEEE mark

    The WEEE symbol indicates that Waste of Electrical and Electronic Equipment (WEEE) shall be collected separately. The symbol is required for regulated products under the WEEE Directive including electronic toys. You can place the WEEE symbol on the product, the packaging, and the user manual.

    WEEE label file

    You must provide a standard-sized WEEE symbol to your supplier. The file can be provided in .ai or .eps format. You should also include the symbol in packaging artwork and user manual files.

    Directive 94/62/EC: Packaging Regulations

    When importing toys to European Union, importers and manufacturers must also meet the requirements concerning packaging materials. Here we provide a brief summary of packaging materials and waste requirements in the European Union.

    Heavy Metals Restrictions

    Directive 94/62/EC sets limits to heavy metals, including lead, mercury, chromium, and cadmium in packaging materials in the EU. Note that the heavy metals restrictions also apply to toy packaging Third-party lab testing is the only way to verify if your packaging materials are compliant.

    Intertek, SGS, TUV, QIMA and other toys testing companies provide packaging materials testing services.

    Additional Packaging Information

    1. Provide collection, reuse, and material recycling information on the packaging to inform customers.

    2. Any other compliance marks or labeling requirements should be also printed on the product packaging.

    Amazon Europe Toy Safety Requirements

    You toy products must comply with all mandatory product directives, certification, and labeling requirements to sell on Amazon.

    We recommend that you read the requirements of the relevant toy in the Amazon Seller Central before importing them to the European Union.

    How does Amazon check toys compliance?

    Amazon may request EN 71 test reports, Declaration of Conformity, or even photos for review. Without valid EN 71 test reports and DoC, it’s likely that Amazon may suspend your existing listings or reject a new one. Further, Amazon generally also requires that the test reports and DoC are held by the same company selling on their marketplace – not a supplier or a different importer.

    What can happen if we sell non-compliant toys on Amazon?

    Amazon has the right to remove your toy listings from Amazon if you canot prove compliance (e.g. by submitting an EN 71 test report and DoC). They can even suspend your account if they deem the action necessary.


  • Important Notice: Articles, videos and other content on this website are provided for educational purposes only. The content contains only general information about product safety, labeling, documentation, testing, risks, and other product compliance-related topics. It is not legal advice, and should not be treated as such. Further, we don't guarantee that the information provided in this article is up to date, all-encompassing or accurate. Also, we generally don't cover European national and US state standards/regulations/requirements.

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