Compliance with EN 71 testing requirements is mandatory for importing toys into the EU. EN 71 specifies testing methods for assessing toy design, durability and safety for compliance with the EC Toy Safety Directive.
But many foreign manufacturers are unaware of EU toy safety requirements, which if you’re an importer, puts your business at risk for noncompliance. Conducting toy testing to EN 71 standards through an accredited third-party laboratory can help you verify your supplier’s goods and protect your business from liability.
There are two terms you should be familiar with if importing toys into the EU: the “EC Toy Safety Directive” and “EN 71”.
The EC Toy Safety Directive (2009/48/EC) is a legislative act that sets toy safety targets for all EU countries to achieve. The EN 71 standard sets the official test methods for ensuring compliance with the Directive’s requirements. It also includes some labeling requirements for specific toys, like those not intended for children under three years old and aquatic toys.
Toys are defined in EN 71 as “any product or material designed
EN 71 has 14 different parts, which are continually updated. The most recent changes to EN 71-1, EN 71-3, EN 71-7, EN 71-8 and EN 71-14 took effect in February 2019.
All economic operators, meaning the manufacturer, the authorized representative, the importer and the distributor, are responsible for ensuring EN 71 compliance.
Importers, in particular, are responsible under the Toy Safety Directive for:
In many cases, the importer is also considered the manufacturer. You are the manufacturer under the EC Toy Safety Directive if you place your name or trademark on the product. In that case, you will be fully responsible for ensuring compliance with EN 71 and will also be responsible for providing technical documentation for CE marking.
This standard applies to all toys regulated under the EC Toy Safety Directive. Noncompliance with EN 71-1 is one of the most common causes for toy recalls in the EU, as its requirements are the most wide-reaching of all parts of the EN 71 standard.
Some of the main requirements of the EC Toy Safety Directive in relation to EN 71-1 include:
The specific testing requirements for your toy will vary based on its design. A third-party laboratory can help you understand how to specifically test your toy product. Some tests under EN 71-1 include:
EN 71-2 categorizes prohibited flammable materials in all toys. It also specifies flammability requirements and test methods for certain high-risk toys and children’s textiles (related: Flammability Tests for Fabric and Clothing Importers).
Flammable materials forbidden in all toys under EN 71-2 include:
The child should be able to drop the toy or distance themselves in case of ignition to prevent serious injury.
Toys that pose the greatest fire hazard and which have specific testing requirements under EN 71-2 include:
During the flammability test, a flame is applied to the test specimen and if ignition occurs, the lab technician measures the duration and distance of the flame. The specific EN 71-2 testing methods vary based on the toy’s intended use and design.
The purpose of EN 71-3 is to simulate a child’s digestion of any part of a toy and identify the risk to the child of exposure to heavy metals.
The EN 71-3 test methods simulate conditions in which the toy material remains in contact with gastric juices for a period after swallowing. This testing extracts soluble elements from the material which can then be measured against the migration limits.
The EN 71-3 test method generally includes:
EN 71-3 separates toy materials into three categories, with different requirements for each:
The EN 71-3 migration limits for each of the 19 elements are shown in the table below:
The number of test samples will therefore vary according to your toy’s design—even simple toys can contain up to 20 materials or components. Some importers choose to test just three of the highest risk materials to minimize toy testing costs. But this option doesn’t offer as much protection against noncompliance.
Although not included in EN 71-3, the EC Toy Safety Directive also forbids the use of carcinogenic, mutagenic and toxic for reproduction (CMR) substances and 55 allergenic fragrances in toys. Toy importers should also separately test for these substances in their products.
The above three parts are the most common EN 71 standards that are applicable for all toys. But there are also several more parts of EN 71 that are only relevant for specific toys.
EN 71-4 applies to experimental sets for chemistry and related activities including crystal growing sets, carbon dioxide generating experimental sets and supplementary sets.
This standard specifies requirements for the maximum amount and in some cases the maximum concentration of certain substances and mixtures used in experimental sets. It also specifies requirements for marking, contents lists, user instructions, eye protection and experiment equipment.
EN 71-5 specifies requirements and test methods for the substances and materials used in chemical toys other than experimental sets, including:
Like EN 71-4, this standard also specifies requirements for markings, warnings, safety rules, contents lists, user instructions and first aid information.
EN 71-7 specifies requirements for the substances and materials used in finger paints. This standard intends to minimize the risk of prolonged skin contact or possible ingestion of paints. It includes requirements related to preservatives, impurities, migration of certain elements and other attributes.
EN 71-8 specifies requirements and test methods for activity toys for domestic use intended for children under 14 years.
Activity toys are often attached to or incorporate a crossbeam and are intended to bear the weight of one or more children. This standard applies to slides, swings, playhouses, climbing frames and other similar activity toys.
This standard tests the product for risks of head and neck entrapment, stability, static strength and impact.
EN 71-14 specifies requirements and test methods for trampolines for domestic use intended for outdoor and/or indoor use at above-ground level by one person at a time.
This standard sets design requirements for the frame size, frame height and maximum user weight. It also includes testing for head and neck entrapment, sharp edges, impact resistance, strength and stability.
In the EU, toys might also need to comply with specific directives other than the EC Toy Safety Directive, depending on the toy’s characteristics. Some common directives applicable to toys include:
ASTM F963 is the toy safety standard equivalent to EN 71 in the U.S. The two standards are largely similar, especially after ASTM F963 was revised in 2016 and 2017 to harmonize it further with EN 71.
But there are still some main differences between the two standards, including:
There is no requirement for an independent lab to conduct EN 71 testing under the EC Toy Safety Directive, unless the toy is subject to an EC-type examination. EC-type exams require testing by a notified body and might be required for toys not covered in EN 71.
But importers usually rely on accredited third-party laboratories to perform EN 71 testing. The mandatory requirements of this standard, the high level of government oversight and the safety risks associated with toys all make reliable EN 71 testing results essential.
And merely relying on your supplier to conduct EN 71 testing could put your importing business at risk for liability issues related to defective or noncompliant products.
The Toy Safety Directive reads “Manufacturers and importers who have placed noncompliant toys on the Community market are liable for damages”. Defective products you’ve imported might need to be withdrawn from the market, and you might need to bear the cost of the withdrawal, in addition to fines and legal actions (related: Don’t Let Your Customer be the One Finding QC Issues in Your Products).
Asian suppliers typically have a limited understanding of Western regulatory requirements and might lack the necessary resources and equipment to test the products they manufacture. They can also be biased in their assessment of their own products compared to an independent lab.
An accredited laboratory can help you understand which parts of EN 71 and the EC Toy Safety Directive you need to test your products to for full compliance. And then they can issue a test report demonstrating your compliance for customs officials or highlight any nonconformances you need to fix before shipment.
In many ways, EN 71 compliance starts well before you ever place a purchase order with your supplier.
You should design your product specifically to be compliant with the EC Toy Safety Directive. Eliminate small parts, heavy metals and other dangerous materials from your product before even beginning production.
Once you’re ready to begin mass production, be sure to enlist the help of a third-party accredited laboratory to ensure the safety and compliance of your children’s toys. EN 71 testing will ensure your toys bring joy to kids and not headaches to your business.
How do you ensure compliance with EN 71 standards and the EC Toy Safety Directive? Share your tips in the comment section below!