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New Toy Safety Standards Named in Latest Official EU Publication Covering Toys

On 13 March 2015, the EU’s Official Journal published the most recent list of harmonised European toy safety standards within the framework of the toy safety Directive 2009/48/EC. The list includes a reference to three new standards which Hong Kong toy manufacturers may need to become familiar with.

The toy safety Directive sets out the essential safety requirements with regard to toys, including the particular safety requirements regarding physical and mechanical properties, flammability, chemical properties, electrical properties and hygiene.

Further and more specific technical details are adopted by the European Committee for Standardisation (CEN) and the European Committee for Electrotechnical Standardisation (CENELEC) in the form of harmonised standards.

Conformity of their products with harmonised standards, the reference numbers and titles of which are published in the EU’s Official Journal, will provide Hong Kong’s toy exporters with a presumption of conformity with the requirements of the EU’s toy safety Directive.

If the standards are followed and applied correctly, the toys covered by them may be sold without obstacle anywhere in the EU. In order to keep up with technical developments, the Commission issues mandates to CEN or CENELEC, which then prepare new standards as and when required.
The Official Journal publication of 13 March 2015 lists the following titles and references that are marked as the first publication:

  • EN 71-1:2014 – Safety of toys - Part 1: Mechanical and physical properties
  • EN 71-3:2013+A1:2014 – Safety of toys - Part 3: Migration of certain elements
  • EN 71-14:2014 – Safety of toys - Part 14: Trampolines for domestic use

All three standards can be purchased from a national member of the EU standardisation body, CEN. For more information including contact details for acquiring any of the standards, Hong Kong’s toy manufacturers should click into the following link: CEN.

Regarding the first, the new European Standard EN 71-1:2014 – Safety of toys - Part 1: Mechanical and physical properties replaces BS EN 71-1:2011+A3:2014. Hong Kong’s toy manufacturers may be relieved to note that in reality, it contains very few new technical requirements. The only key technical amendment which manufacturers will be concerned with relates to Article 5.4 e) “Toys with self-retracting cords”. Such cords are not permitted to retract under the specified testing conditions. The new standard, revising the previous one, emphasises that such cords are permitted to retract by a maximum of 6 mm. In the previous standard, no ‘distance’ had been specified. The other revisions are mainly textual, so as to comply with the CEN rules that regulate the way standards are drafted.

As for the second new standard, EN 71-3:2013+A1:2014 – Safety of toys - Part 3: Migration of certain elements, it specifies requirements and test methods for the migration of aluminium, antimony, arsenic, barium, boron, cadmium, chromium (III), chromium (VI), cobalt, copper, lead, manganese, mercury, nickel, selenium, strontium, tin, organic tin and zinc from toy materials and from parts of toys. Hong Kong manufacturers should bear in mind that packaging materials are not considered to be part of the toy unless they have intended play value. The standard sets out requirements for the migration of certain elements from the following categories of toy materials:

  • Category I: Dry, brittle, powder-like or pliable materials;
  • Category II: Liquid or sticky materials;
  • Category III: Scraped-off materials.

The requirements of this standard will not apply to toys or parts thereof which, due to their accessibility, function, volume or mass, clearly exclude any hazard due to sucking, licking or swallowing or prolonged skin contact when the toy, or part thereof, is used as intended or is used in a foreseeable way, keeping in mind the behaviour of children. Indeed, as far as this new standard is concerned, it is for the following toys and parts thereof where the likelihood of sucking, licking or swallowing is considered significant:

  • All toys intended to be put in the mouth or to the mouth. It should be noted that cosmetics toys and writing instruments classified as toys can be considered as being susceptible to being sucked, licked or swallowed;
  • All the accessible parts and components of toys intended for children up to 6 years of age can be considered to come into contact with the mouth. By and large, the likelihood of mouth contact, with parts of toys intended for older children, is not considered significant.

As for the third one, EN 71-14:2014 – Safety of toys - Part 14: Trampolines for domestic use, it is reported that this standard has been in the pipeline for several years. It sets out specific requirements and test methods for trampolines for domestic use, their access devices and their enclosures, intended for outdoor and/or indoor use above ground level by one person at a time. A number of trampolines are expressly excluded from scope, including (among others) trampolines used as gymnastic equipment (these are said to fall under EN 13219), floating inflatable trampolines (said to fall under the EN 15649 series), and trampolines used in public playgrounds.

In general, the requirements relate to the following (among other) matters: mini-trampolines intended for indoor use have to be provided with anti-slip feet; medium and large trampolines have to be equipped with an enclosure (which is itself subject to various requirements); the durability of (both metallic and non-metallic) materials; padding requirements; and the resilience of frames, access devices and enclosures.

In order to view the full list of the harmonised European standards falling under Directive 2009/48/EC on the safety of toys (comprising both the above titles, and those whose titles have been published in the Official Journal on previous occasions), Hong Kong’s toy manufacturers should view the Official Journal Communication of 13 March 2015. This document also provides, where appropriate, references to superseded standards.

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