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On September 23, 2019, the EU Commission published a guidance document to clarify when soother holders are double use products: intended to fasten the soother to a child’s garment and intended as a toy to play with.

SAFEGUARDS | Toys & Juvenile Products NO. 140/19

Baby with Pacifier

The EU Commission and Member States Toy Expert Group have published guidance documents to assist in the application and understanding of the EU Toy Safety Directive 2009/48/EC.

Soother holders are intended to be fastened to children’s garment, in order to prevent them from getting lost. Products of this type, which only have a “keep safe” function are not toys. For these soother holders the General Product Safety Directive 2001/95/EC and the dedicated soother holder standard EN 12586 apply.

However, some soothers also have play value. Therefore, they are soother holders and toys at the same time. These double use products need to comply with the General Product Safety Directive 2001/95/EC and the EU Toy Safety Directive 2009/48/EC.

In order to clarify the difference between a ‘functional soother holder’ and a ‘soother holder with play value’ the EU Commission has published a guidance document.

The guidance shows images of soother holders that are NOT toys. These are ‘functional soother holders’ with a simple strap, but no play value (though they may be designed to be appealing to children).

Baby Soother Holder

Examples of soother holders that are not toys, as shown in the guidance document.

Soother holders with a play function have additional features, such as:

  • Intended interaction
  • Highly varying shaped elements (e.g. cars, flowers) in the same soother holder strap with beads
  • Rattle effect
  • Three-dimensional figurine (animal, child, etc.) built of various elements
  • Plush toys attached to the strap

Baby Soother Holder

Examples of products that are classed as soother holders and toys, as shown in the guidance document.

Please find a link to the full text of the guidance document here.

SGS has dedicated experts and services to assist you in the development of juvenile products and childcare articles. SGS offers physical/mechanical tests, chemical tests, packaging evaluation, inspections to ensure the compliance of your products in target markets.

For enquiries, please contact:

Sanda Stefanovic
Global Toy Expert
t: +31 88 2144517

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