28-06-2011 Toy Safety Changes

For instance the EN71 part 3 “Migration of elements” which comes into force July 2013 has a huge increase of 8 to 19 elements to be tested for).  See the brochure for more details. Please visit the official EU website for the complete Directives (also available in Chinese) and important factsheets!

Talking specifically there is a significant quantity of changes for (soft) toys. These include the following:
• A widening of the interpretation of what is a toy.
• New directives on warning labels.
• All toys for young children will need to be ‘cleanable’.
• Minor changes to flammability tests.
• Increase in traceability of toys. The company which first places the toy in to the EU must have their contact details on the se-in labels. If something goes wrong then the importer can be easily identified.

Technical Files

Most importantly to us the new toy legislation effectively moves from a position where you just test the finished product to testing all the individual components of the product before it is manufactured. It moves the onus of testing from the finished product to the design and components of the toys.

Manufacturers/importers must hold a technical file for all their products showing where each component was made and its test certificate. The toy is made from safe components and as long as it is then manufactured correctly it is guaranteed to be safe.

Technical files will need to be held for 10 years.

Instead of just testing the completed toy you will need to see where your new factory is sourcing its components from, and see all their test certificates.

The new legislation clearly defines the roles of companies in the supply chain:

Manufacturers: must ensure toy meets European safety regulations. Carry out safety assessment. Draw up technical documentation. Apply conformity assessment. Affix CE.

Importers: must ensure – safety assessment is carried out, that the technical document has been drawn up, labeling is correct, the toy is accompanied by safety information. They must keep Declaration of conformity and tech files for 10 years.

Distributors: must ensure labeling regs are met. Co-operate with Authorities and identify other economic operators.

Retailers only need to have a copy of declaration of conformity from supplier. They do not need to have technical files or test certs. Internet retailers will need to clearly state any warnings on the toy on the description of the toy. Each toy will now have a technical file associated with it. Retailers should have a copy of the Declaration of Conformity and you should ask your supplier to see it on any toy which sells in volume through your shop.