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Vietnam strengthens its national technical regulation on toy safety to meet modern-day requirements. The new technical regulation will become effective on January 1, 2021.

SAFEGUARDS | Toys & Juvenile ProductsNO. 184/19

 SG 18419 Girl with Bear

In 2017, Vietnam informed the World Trade Organization (WTO) of its draft QCVN 3:2017/BKHCN ‘National Technical Regulation on Safety of Toys’ (SafeGuards 1/18).

In September 2019, the Vietnamese Ministry of Science and Technology announced the nation’s new technical regulation on toy safety.  The new QCVN 3:2019/BKHCN technical regulation, published under Circular Number 09/2019/TT-BKHCN of September 30, 2019 (the Circular), contains several important changes to QCVN 3:2009/BKHCN:

  • Revising the version of standards for physical and mechanical properties, flammability and migration of certain elements (see Table 1) 
  • Adding requirements for six phthalates – three phthalates for (all) toys and three phthalates for toys which can be placed in the mouth
  • Requirements for labeling in accordance with Decree No. 43/2017/ND-CP of April 14, 2017.

In addition to the above changes, other important provisions in the new technical regulation include:

  • Declaration for toys conforming to the technical requirements (Section 2) in the regulation, conformity mark (CR mark) and labeling before they are placed on the market.
  • Toys manufactured domestically or imported are required to undergo certification using Mode 5 or 7 – the certificate is valid for three years
  • Declaration of Conformity (DoC) for domestically manufactured toys
  • Imported toys to be registered for inspection on their quality (Circular 28/2012/TT-BKHCN)
  • List of HS Codes for toys falling under the scope (Appendix I)
  • List of products not considered as toys (Appendix II) 

There are two effective dates:

  • December 31, 2019 for the Circular other than Section 2 ‘Technical Regulations’ to the QCVN 03:2019/BKHCN national technical regulation 
  • January 1, 2021 for Section 2 ‘Technical Regulations’ to the QCVN 03:2019/BKHCN national technical regulation (requirements for physical, flammability, chemicals, accessible liquids, electric safety and labeling)

According to the Circular, toys that are compliant with the QCVN 3:2009/BKHCN national technical regulation under Circular Number 18/2009/TT-BKHCN of June 26, 2009 may remain on the market until December 31, 2021.

Highlights on the technical requirements between QCVN 3:2019/BKHCN and QCVN 3:2009/BKHCN are summarized in Table 1.

National Technical Regulations on Safety of Toys

QCVN 3:2019/BKHCN QCVN 3:2009/BKHCN
Scope Toys for children under the age of 16 Toys for children under the age of 16
Physical and mechanical properties TCVN 6238-1: 2017 
(ISO 8124-1: 2014)
TVCN 6238-1:2008
(ISO 8124-1:2000)
Flammability  TCVN 6238-2: 2017
(ISO 8124-2: 2014)
TVCN 6238-2:2008
(ISO 8124-2:2007)
Migration of certain elements TVCN 6238-3:2011
(ISO 8124-3:2010)
TCVN 6238-3:2008 
(ISO 8124-3:1997)
Accessible liquids 3 ≥ pH ≤10 3 ≥ pH ≤10
Formaldehyde in accessible toy materials for children under the age of 3 ≤ 30 mg/kg content (textiles)
≤ 30 mg/kg content (paper)
≤ 80 mg/kg release (resin bonded wood)
≤ 30 mg/kg content (textiles)
≤ 30 mg/kg content (paper)
≤ 80 mg/kg release (resin bonded wood)
Phthalates ≤ 0.1% for each of BBP, DBP and DEHP in toys

≤ 0.1% for each of DIDP, DINP and DNOP in toys which can be placed in the mouth

(TCVN 6238-6:2015 (ISO 8124-6:2014))
 ---
Primary aromatic amines
(PAA)
≤ 5 mg/kg each listed PAA ≤ 5 mg/kg each listed PAA
Electric safety ≤ 24V for nominal input voltage (toy)
≤ 24V for nominal or instantaneous voltage (toy or part of toy)
≤ 24V for nominal input voltage (toy)
≤ 24V for nominal or instantaneous voltage (toy or part of toy)
Labeling Decree No. 43/2017/ND-CP of April 14, 2017
In accordance with law on labeling and corresponding standards
Effective date January 1, 2021
In force
Table 1

Definitions

Item Acronym Phthalate     Item Acronym Phthalate
1 BBP Benzyl butyl phthalate
4 DIDP
Di-iso-decyl phthalate 
2 DBP Di-n-butyl phthalate 
5 DINP
Di-iso-nonyl phthalate
3 DEHP Di-(2-ethylhexyl) phthalate  6 DNOP
Di-n-octyl phthalate 

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. With the largest global network of toy experts and testing facilities around the world - around 20 toy labs worldwide including 3 EU Notified Bodies (France, Germany and Netherlands), SGS is the partner to trust. Please do not hesitate to contact us for further information or visit our website

For enquiries, please contact:

Hingwo Tsang
Global Information and Innovation Manager
Tel:(+852) 2774 7420

Huong Nguyen
Technical Manager
Tel: +84 (0) 28 38 160 999  Ext. 612

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