Toy Safety Standards in the United States: A Complete Guide

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Toy Safety Standards in the United States

Ensuring compliance with toy safety standards is mandatory when importing, manufacturing, and selling children’s toys in the US. In this guide, we cover what toy safety standards are, and how you can ensure compliance. More specifically, we cover ASTM F963-17, UL 696, and test methods.


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What are toy safety standards?

Toy safety standards, in general, are established to help ensure the safety of children’s toys in the US. Importers and manufacturers should understand that, in most cases, they must send their products for testing to ensure that their products comply with the requirements set by the standards.

Toy safety standards cover limits to heavy elements and other substances, mechanical requirements, and other safety requirements. The goal is to ensure that children won’t get injured or exposed to harmful substances while playing with the toys.

Mechanical and physical properties

Children’s toys may inherently present mechanical and physical hazards during playtime.

As such, requirements in toy safety standards might cover physical properties such as material quality, accessible points, or sharp edges. Mechanical properties might also include folding mechanisms and hinges, projectile toy characteristics, and more.

Small parts

Safety standards, such as ASTM F963-17, might also cover requirements for small parts, which in some cases may be the entire toy or a component that may be detached during use.

If the toy, or parts of it, is small enough to be accidentally ingested by a young child, then it presents an inherent choking hazard and would be potentially unfit for sale. For this reason, toys containing small parts are banned, if these are intended for children younger than 3 years.

However, if the small toy (or regular toy with small parts) is intended for use by children between the age of 3 and 6 years, it has to carry a warning label noting its inherent dangers.

Chemicals and heavy metals

Toy safety standards might also restrict hazardous chemicals and heavy metals that may be found in toys. This might include:

  • Phthalates
  • Lead
  • Cadmium

Safeguards such as lab testing must be in place to ensure that products and materials do not contain an excessive amount of dangerous substances.

Electrical safety

Some children’s toys have either electrical components, batteries, or both. There exist standards that cover requirements that ensure electrical safety to protect children from any potential electricity-related hazard that may arise during the use of the toy.

ASTM F963-17 covers safety requirements regarding electrical energy, thermal energy, battery-powered ride-on toys, and more.

Batteries

Batteries might be found in electrical or electronic toys, the safety of which is covered by safety standards such as ASTM F963-17. Battery-operated toys might require testing to ensure they do not pose harm to children playing with them.

Flammability

Flammability is an aspect that might also be covered by toy safety standards. This is because some types of toys can catch fire easily due to the fact that they contain flammable material that would pose a hazard to children (e.g. plush toys).

Warning labels

Toy safety standards might cover requirements regarding warning labels. These labels are intended to provide caution statements and symbols that help the user of the toy (or the caregivers) avoid hazards such as electrocution, accidental ingestion, and more.

Are you safety standards mandatory in the US?

Yes, because the CPSIA states that all children’s products (i.e., for 12 years or younger) must comply with applicable ASTM safety standards and other relevant standards. Hence, it’s not allowed to import or manufacture toys in the US that are not compliant – and verified as such though lab testing – with the recognized toy safety standards.

ASTM F963-17 – Standard Consumer Safety Specification for Toy Safety

ASTM F963-17, developed by the American Society for Testing and Materials (ASTM), focuses on the safety of children’s toys, covering aspects such as:

  • Chemical safety
  • Mechanical safety
  • Electrical safety

Compliance with standards is often voluntary. However, compliance with ASTM F963-17 is mandatory as the standard was incorporated into the Consumer Product Safety Improvement Act (CPSIA) in the US.

ASTM F963-17 generally covers requirements for toys used by children up to 14 years of age even though it is mandatory for toys intended for children up to 12 years of age.

Product scope

The toy products covered by ASTM F963-17 include:

  • Projectile toys
  • Wheeled ride-on toys
  • Magnets
  • Pom-poms
  • Marbles
  • Rattles
  • Squeeze toys
  • Elastic tether toys
  • Stuffed and beanbag-type toys

Substance restrictions

ASTM F963-17 lists different types of heavy metals and their maximum soluble migrated element limits.

Mechanical properties

ASTM F963-17 lists several mechanical and physical properties that might affect the safety of the product. For example, those properties include:

  • Edges
  • Sharp points
  • Cords and straps
  • Holes and mechanisms
  • Small parts

Small parts with dimensions smaller than the test cylinder are considered to be inherent choking hazards, and as such, are non-compliant and unfit for use by children under 3 years of age. However, if a toy that contains small parts is designed to be used by children between 3-6 years, it has to carry a warning label.

Electrical safety

ASTM F963-17 also covers some aspects of electrical safety, applicable to electronic toys. The specific technical and safety requirements can only be found in ASTM F963-17.

Flammability

Under ASTM F963-17, solids, soft toys, and fabrics are subject to flammability testing procedures. The CPSC, however, notes that the CPSIA excludes ASTM F963-17 flammability testing from its testing requirements.

Labeling requirements

Warning statements may also be required. The specific wording depends on the product and the potential risk. But, you can find examples in ASTM F963-17.

Note that the age group may also impact the relevant warning. Further, warning labels are complementary to the CPSIA tracking labeling requirements.

UL 696 – Standard for Electric Toys

UL 696 is titled the “Standard for Electric Toys”. It covers electric products meant to be used as toys by children over the age of 3.

Product scope

The products covered by UL 696 include:

a. Electrically-operated toys

b. Miniatures of full-sized appliances

c. Toys that copy the function or form of an appliance that has been established for general use

d. The toy’s packaging, if it is meant to be used with the toy itself

Requirements

UL 696 requires toys that mimic functional general-use appliances to fall under the established requirements of general-use appliances. Those requirements should supplement UL 696’s requirements for electrical toys.

Test Methods

Here are some examples of test methods that can be applied to toy safety testing.

CPSC-CH-C1001-09.4 – Standard Operating Procedure for Determination of Phthalates

CPSC-CH-C1001-09.4 is a test method that has been approved by the CPSC. The procedure has three main components to it:

a. Prepare the sample

b. Extract the phthalates

c. Analyze the findings

It is used to determine whether the phthalate content in toys meant for children and articles meant for child care complies with 16 CFR Part 1307, titled “Prohibition of Children’s Toys and Child Care Articles Containing Specified Phthalates”.

16 CFR Part 1307 specifies that children’s toys or childcare products containing several types of phthalates over 0.1% should be prohibited from being imported or manufactured into the US.

We list the following phthalates below:

  • Di-(2-ethylhexyl) phthalate (DEHP)
  • Dibutyl phthalate (DBP)
  • Benzyl butyl phthalate (BBP)
  • Diisononyl phthalate (DINP)
  • Diisobutyl phthalate (DIBP)
  • Di-n-pentyl phthalate (DPENP)
  • Di-n-hexyl phthalate (DHEXP)
  • Dicyclohexyl phthalate (DCHP)

CPSC-CH-E1001-08.3 – Standard Operating Procedure for Determining Total Lead (Pb) in Children’s Metal Products

CPSC-CH-E1001-08.3 is a test method that has been approved by the CPSC. The three main sections of the test method are as follows:

a. Prepare the sample using one of two stated methods

b. Analyze the metal sample for lead

c. Determine the total amount of lead using X-ray fluorescence spectrometry

The method is used by testing laboratories to determine whether the lead (Pb) content in children’s metal products shows compliance with Section 101 of the CPSIA (as outlined in 15 USC 1278a, titled “Children’s products containing lead; lead paint rule”).

15 USC 1278a specifies the limit for lead content in children’s products to fall below 100 ppm.

In situations where it is not feasible for the lead content of a child’s toy to be limited to 100 ppm, the Commission would allow the limit to be 300 ppm.

CPSC-CH-E1002-08.3 – Standard Operating Procedure for Determining Total Lead (Pb) in Non-Metal Children’s Products

CPSC-CH-E1002-08.3 is a detailed test method that has been approved by the CPSC. The test method is used to determine the amount of lead (Pb) in non-metal products such as:

  • Ceramics
  • Glass
  • Crystal (and other siliceous materials)
  • Plastics
  • Polymers (and other non-siliceous materials)

The procedure uses an ICP method to analyze samples for total lead content in acid digests of polymeric or siliceous materials.

The method is used by testing laboratories to determine whether the lead (Pb) content in non-metal children’s products complies with 16 CFR 1500.87.

16 CFR 1500.87, titled “Children’s products containing lead: inaccessible component parts” specifies that according to Section 101(a) of the CPSIA, non-metal toy products designed for use by children 12 years of age and below cannot contain more than 100 ppm.

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    Sources: Our articles are written in part based on publicly available information, and our own practical experience relating to product compliance. These are some of the primary sources we use:

    • ec.europa.eu
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    • ecfr.gov
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    • ftc.gov
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  • 10 Responses to “Toy Safety Standards in the United States: A Complete Guide

    1. Cathy at 3:50 am

      What is the purpose of the stuffing label for toys?
      What type of toy stuffing material is applicable to the labeling?

      1. Fredrik Gronkvist at 3:16 pm

        Hi Cathy,

        Are you referring to a law label?

    2. Paula Guran at 4:39 pm

      I have a question regarding Amazon requirements for selling toys on the US market. “Selling Toys in the US”: https://sellercentral.amazon.com/gp/help/GV9VZ5A7PJZQYRFF, mentions that “Test reports from a CPSC-accepted testing laboratory confirming each product was tested to the requirements listed below: ASTM F963-17 (Toys), CPSIA (Lead, Phthalates) and Small Parts Warning”. My question would be if we need to test the toy for compliance with all mandatory-for-testing requirements from ASTM F963-17 as per 16 CFR §1112.15(b)(32)?

      Or do we need to test compliance with all ASTM F963-17 requirements, regardless if they are mentioned as mandatory-for-testing or not by 16 CFR §1112.15(b)(32)?

      1. Fredrik Gronkvist at 7:52 pm

        Hi Paula,

        I am not sure if I understand the question, but in short, you CPSIA requires lab testing. This is explained here: https://www.cpsc.gov/Business–Manufacturing/Testing-Certification

        1. Paula-Andreea Guran at 12:23 am

          Hi Fredrik,

          My question was targeted more at Amazon’s requirements for sellers in the US market. For example, CPSIA says that testing toys for the ASTM 963-17 Flammability requirement is not mandatory. Amazon’s requirement regarding selling toys is as follows: “Test reports from a CPSC-accepted testing laboratory confirming each product was tested to the requirements listed below: ASTM F963-17 (Toys), CPSIA (Lead, Phthalates) and Small Parts Warning*. My question is if its mandatory to test for Flammability if you sell on Amazon US.

          1. Fredrik Gronkvist at 3:32 pm

            Hi Paula,

            I see, perhaps they mean that flammability testing is not applicable to all products and materials, but I don’t think that test is in itself voluntary.

    3. vakho at 8:40 pm

      Hello, I am Vakho from Georgia. We have an electric toy where you can make circuits, also age limit is 12 years old, we want to put it in the US market. I am wondering what criteria must be met or what certifications are required.

    4. janet kline at 12:26 am

      I bought a toddler bath book that changes color in the water says made in China but doesn’t have product materials . Isn’t that something that needs to be listed ? I have checked everywhere , online and from Amazon to no avail! Label states polyethylene foam inside but nothing about color change materials…it is for my grandson and I want to be sure it is safe! Kregel children’s books is on the label.

      1. Fredrik Gronkvist at 3:34 am

        Hi Janet,

        Are you perhaps thinking about a tracking label?

        https://www.compliancegate.com/cpsia-tracking-label/

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