Sometimes when you’re toy designing you may want to use something within your design that you haven’t made yourself, which is already sold, for example adding a toy car to a car mat, crayons to a crayon roll etc etc.
There are varying opinions across trading standards on what you should do to prove your added item is safe, some say photograph packaging, some say keep packaging, and some recommend obtaining a declaration of conformity from the supplier of your toy. Do what you have to do to feel confident in proving the item is safe.
Getting a declaration of conformity (similar to getting hold of fabric certificates) may be a bit hit and miss, and its important when buying from abroad they produce genuine certificate for the actual toy you are purchasing -many put up certificates which apply to other toys rather than the actual toy so be sure to read and contact them before parting with your money. The declaration of conformity should be much like yours for your own item, stating what standards are relevent, and with a photo.
Something else important to remember is that the CE mark does not just apply to toys, its a passport for travelling goods around europe and different standards apply to different products, so the CE does not always mean that it is safe for children. Now in some cases that would be fairly obvious, but in others perhaps not so, and that is where obtaining the declaration of conformity would be important as it would inform you what standards would apply to the product.
Any warnings applied to the toy you are adding, must be transferred over to your own item, so bear that in mind when selecting your toy to be sure it is aimed at the same age range you are working for.
Your final product must be tested as a completed toy. So anything added must be tested alongside the rest of your item to be sure it doesn’t pose a risk.
There is a growing trend at the moment to buy a commercially made toy, and personalise it, with embroidery or vinyl etc. These still need testing/retesting once you have finished the personalisation. This feels like a quick and easy way to sell things, but actually it isn’t when you take into account being within the law. The original bought toy should already have the CE mark on it (quite likely attached!) and altering the toy in any way then means this CE mark no longer applies, and your own labelling needs to be added once it passes testing.
Physical tests: If your original purchased toy is deconstructed or altered in any way, it must be retested. So for example if you had to deconstruct a part of a bear to add embroidery/vinyl, it would need a full retest to be sure there wasn’t a weakness in the stitching. If there was no deconstructing, you may feel covered enough for most seams, but if you then had to stuff it, your closing seam would need testing. Your additional personalisation material(embroidery,HTV) will need testing too to check it does not pose a choke risk.
Flammability: anything added or altered on a toy will need a complete flammability test.
Chemical: all additional materials need certificates to prove their compliance to toy safety, including threads for embroidery and vinyl. We have many materials tested in the collective, or alternatively you can contact manufacturers for certificates.
If you’re a newbie to CE marking you may find this link helpful.
Hope this helps to explain where you stand using ready made toys in your work!