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New EU toy guidance 11: how to classify toys for under three years of age or of three years and over

SafeGuardSToys and Juvenile ProductsFebruary 10, 2023

SG 18/23

The EU Commission and expert group on toys have issued new guidance on the classification of toys: under three or three years and over.

EU 2009/48/EC, the Toy Safety Directive, sets stringent requirements for toys intended for children younger than three years of age. This is because very young children are more at risk due to their limited capabilities. For instance, young children explore everything with their mouth and are at higher risk of choking or suffocating on toys. Toy safety requirements aim to protect young children from these hazards.

The correct classification of toys assures that suitable requirements are applied.

In 2009, the EU Commission and expert group on toys published guidance to help with correct classification. This guidance, document 11, covered three categories for toys: puzzles, dolls, and soft and stuffed toys. As there are many more categories of toy on the market it was decided to expand the document and increase the number of toy categories.

The new guidance covers the following categories:

  • Puzzles
  • Dolls
  • Soft and stuffed or partially stuffed toys:
    • Soft and stuffed or partially stuffed toys
    • Squishies
  • Fidget toys
  • Modeling clay/dough, slime, soap bubbles
  • Movable/wheeled toys
  • Play scenes, constructed models and construction toys
  • Game sets and board games
  • Toys intended to be entered
  • Toys intended to bear the mass of a child
  • Toy sports equipment and balls
  • Hobby horse/stick horse
  • Push-pull toys and pull-along toys
  • Audio/visual equipment
  • Toy figures and other toys

The guidance focuses on borderline cases and provides many examples and pictures of toys.

In order to define the play value of a toy intended for children under 36 months the following factors have been taken into account:

  1. The psychology of children of under 3 years, particularly their need to “cuddle”
  2. Their attraction to objects “which are like them”: baby, small child, baby animal, etc.
  3. Their preference to imitate adults and their activities
  4. Their mental development, particularly their lack of capacity for abstraction, low level of knowledge, limited patience, etc.
  5. Their less developed physical abilities in terms of ease of movement, manual dexterity, etc. (the toy may be small and light for the child to handle it easily)

Please find full details of EU toy guidance 11.

SGS offers a wide range of services to ensure that your products comply with the EU Toy Safety Directive. We offer training, safety/risk assessment, technical documentation check, labelling review, testing according to harmonized standards, SVHC screening, inspections and audits. We operate the world’s largest network of toy experts and testing facilities – around 30 toy laboratories and certification bodies worldwide, including 3 EU Notified Bodies (France, Germany and Netherlands). Please do not hesitate to contact us for further information or visit our website. In the end, it’s only trusted because it’s tested.

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For further information, please contact:

Sanda Stefanovic

Sanda Stefanovic

Toy Business Development and Technical Manager

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