Toy Updates: June 2019
Our toy experts explain some of the issues surrounding the following frequently asked questions:
- Is it a toy or not?
- Marking requirements for counter displays
- Correction: Is a key ring with a plush toy attached to it a toy?
IS IT A TOY OR NOT?
At first glance, the question of whether an item is a toy, or not, seems really simple. In practice however, it can be quite complex. To help, let’s take a look at the formal definition of toys.
In the EU, the Toy Safety Directive and EN 71 define toys as “Products designed or intended, whether or not exclusively, for use in play by children under 14 years of age”.
Or more simply, toys are items for children to play with. Though we know that children can play with anything presented to them, the key point is that toys are designed or intended to offer play value.
The EU Commission has drafted several guidance documents to support the classification of toys discussion. See: EU Commission Guidance on Marking requirements for counter displays
MARKING REQUIREMENTS FOR COUNTER DISPLAYS
Some markings are allowed on counter displays, others are not. What are the rules?
Warnings: These are NOT allowed on a counter display. Any warnings should be on the toy, on an affixed label or on the packaging (if present). Warnings are important for caregivers.
CE mark: This mark IS allowed on counter displays. The CE mark is important for surveillance officers.
CORRECTION: IS A KEY RING WITH A PLUSH TOY ATTACHED TO IT A TOY?
In a previous Toys Update we told you that soft filled toys with simple features intended for holding and cuddling are considered as toys intended for children under 36 months, and that this also applies to soft filled toys attached to a key ring.
We also told you that the ring intended to hold keys should comply with the shape and size requirements of clause 5.8 of EN 71-1 (template A). However, compliance of the ring to clause 5.8 is not needed provided a suitable warning or age labeling is present. Such a warning or age labeling should clarify that the ring is not suitable for babies or children that are not able to sit up. For instance, this could be a label indicating that the toy is not suitable for children under 10 or 12 months, where children are unable to sit up unaided.
The hazard for children that are unable to sit is related to impaction. This means that a baby lying on its back could move the ring into its mouth, but may not then be able to remove it. Such a ring could become lodged and close off airways.
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