Adding warnings to toys can be a tricky path to navigate (even I’ve been putting this blog off for months! ;)) With all the different toy types, its tricky to explain this in a way that applies to all, so if you do get stuck, feel free to post in the community group and we’ll see what we can help with.
For added info on this blog post, we really recommended reading the europa document on classification of toys:
Its a really informative document with examples, so its worth a read.
So, we know that all items aimed for under 14s need a CE mark. After that in general toys (as in play toys rather than chemistry sets!) we have two(ish) areas of toys in categories, from birth, and from 3 upwards.
Suitable from birth or not suitable for under threes?
There are certain factors which you can think about to help classify your toy for under threes or not. These are mentioned in the guidance doc linked above, but in short
- The way a small child needs to cuddle objects
- The way they are attracted to objects that are like they are, babies/child like, baby animals small etc
- Their development – abilities, patience, etc
- Their physical development – dexterity, strength
All soft toys need to be classified from birth as it is expected that the toy will be given to a small child/baby regardless. So this means if you’ve made a soft toy or doll, and it fails the tests, you can’t add a warning to cover yourself. It still needs to pass, because it would be confusing to have a warning which conflicts with the function, size or characteristics of the toy.
This can get rather vague in the examples of ‘busy books’… books intended to keep small children busy, are often made containing small parts which may not be suitable for very young children. By being made of cloth they characteristically look like they are aimed at babies, which crosses a very difficult line, when the actual activities are beyond baby/toddler skills. Its a very grey area and its up to you as the maker to make the difficult decision as to whether the warning applies or not, but it is always good to err on the side of caution, and perhaps consider your design so that it can be applicable to all.
Is a soft toy ever not classed for under threes?
Not really but just in case you’re not sure…
The guidance docs state, if it can be cuddled as a soft toy, it is a soft toy. They particularly name these items:
‘actual soft toys and musical soft toys;
– door decorations;
– height gauges for children’s bedrooms which, when filled, are the shape of a soft toy;
– animal-shaped cushions.’
If the toy has something additional that prevents it being cuddled, it might not be classed as a toy (such as if its incorporated into a picture frame etc), however items such as toy-like backpacks and purses still apply and need to be suitable for under threes. Even adult themed bears need to be suitable too! :/
Complex accessories for simpler toys
As a soft toy, and nearly all handmade dolls come into the category of from birth,but sometimes accessories for that particular toy may not. This is again a bit of a tricky one, for example, perhaps a soft doll and a bag with a long strap. In which case it would probably be safest practise to separate the doll and bag in packaging and sale point, adding a warning to the bag, or make the bag safe with a breakaway point/shorter straps etc.
Fancy dress for under 12 months is a bit of a grey area, according to the guidance documents:
Babies under the age of one do not have the capability to dress or understanding to ‘play’ a character, therefore the fancy dress items ‘should’ fall under the GPSD (general product safety directives) and be safe through those instead of EN71. However, generally on the market these costumes are CE marked, and any costumes which could fall across the age range from under/over ones need the CE mark.
Age warnings apply the same way to fancy dress as they do to toys, though varying due to the fact that the items may be more complex in terms of closures and skill to use (unlike the soft toy rule) and of course, sizing itself will cause an age barrier.
Not suitable for under threes?
If your toy is aimed at over threes, is not a soft toy, and does not pass the lengths and loops measurements, or the small parts cylinder, or other tests then its possible you can place the warning on to say its
‘Not suitable for children under 36 months” or “Not suitable for children under three years,’
and you must include the harm and the hazard (ie small ball: choke risk, long cord: strangulation hazard)
or you may use the 0-3 symbol(the grumpy baby symbol!), The symbol must have a white background, red strike, and needs to be 10mm tall. It must only apply to the 0-3 age to avoid any confusion.
There are a couple of other age warnings you may be able to use. Should your cord or strap length meet the criteria.
Its possible you may use a not for under 18 months warning:
“Warning. Not suitable for children under 18 months. Long cord/Long chain. Strangulation hazard.”.
Or if your toy uses ’monofilament’ hair fibres on a fabric base at 50mm or above:
”Warning. Not suitable for children under 10 months due to long hair.”
Its fine to put an age recommendation on your toy, as long as its not confused with a warning, and as long as the toy is still safe for all ages if that is what is necessary.
As always: while we can guide you it is always down to the maker to make sure they follow the guidelines correctly.
Hopefully that helps you through another minefield on your way!
Any questions pop them in the facebook comments box, or post in the community group!