Toy Updates: October 2018
Our toy experts telling you more about the issues surrounding the following frequently asked questions:
- Do plush toys need to have wash labels?
- When do I need to print the importer's address?
- Is a puffer or fluffy ball classified for children over or under three years of age?
Do plush toys need to have wash labels?
The simple answer is no. However, the EU's Toy Safety Directive does set requirements for the washability of toys. Its requirements are: "A toy intended for use by children under 36 months must be designed and manufactured in such a way that it can be cleaned. A textile toy shall, to this end, be washable, except if it contains a mechanism that may be damaged if soak washed. The toy shall fulfill the safety requirements also after having been cleaned in accordance with this point and the manufacturer’s instructions."
For plush toys, this means they must be washable and after being washed, still comply with all requirements.
Wash labels can be provided in cases where special care is needed.
When do I need to print the importer's address?
All toys that are imported into the EU need, in principle, to bear the address of the importer and manufacturer. There are although some derogations:
- Own name or trademark
An importer, importing toys into the EU, who places the toy on the market under their own name or trademark is considered to be the manufacturer. Only the address of the importer needs to be printed. Please note that in such cases, the importer bears the full obligations of the manufacturer.
- Modifying the toy
An importer who modifies a toy (in such a way that compliance may be affected) is considered to be the manufacturer and only the address of the importer needs to be printed. Please note that in such a case, the importer bears the full obligations of the manufacturer.
- EU manufacturer manufacturing outside the EU
A manufacturer located within the EU, but producing goods outside its borders is considered to be the manufacturer who places the toys on the EU market, even if the actual importation is done by another company. In this case, it is sufficient to put only the manufacturer's address.
- If the manufacturer is within the EU
A company located in the EU presents itself as being the manufacturer (by putting their trademark, address, etc. on a product) although the products are manufactured outside the EU. In this case that company is considered to be the manufacturer who places the toys on the EU market, even if the actual importation is done by another company. In this case, there is no importer in the meaning of the importer's definition and it is sufficient to put only the manufacturer's address.
Is a puffer or fluffy ball classified for children over or under three years of age?
Puffer or fluffy balls are squeezable hairy balls made of thermoplastic rubber (no filling). EU authorities decided to classify simple puffer balls without a string as being suitable for children under three years of age, as they claim only simple handling (catch and throw) is possible. This includes toys that look like plush or crib toys, but are made of the same hairy thermoplastic material. However, as small pieces of material can be pulled off, these toys are banned in the EU. An official EU guidance document is still to be published.
Puffer balls that are yoyo-balls (there is a string attached so that you can bounce or sling the ball) are intended for children over three years of age. Fine motor skills are needed to bounce and sling the balls.
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To learn more about how SGS can help you place safe and compliant toys on your target markets, please visit SGS Toys or contact:
Global Marketing Manager
t: +33 4 42 61 64 46