An Open letter to Fabric Manufacturers, Retailers and Importers from the Toy crafting world | CE Marking Handmade Toys Collective

An Open letter to Fabric Manufacturers, Retailers and Importers from the Toy crafting world

An Open letter to Fabric Manufacturers, Retailers and Importers from the Toy crafting world

Dear Manufacturers, Designers, Importers and Retailers,
The toy makers in the UK would like to bring your attention to EN71-3, the chemical transfer testing of all materials used for making toys in the UK (and the EU)
You may have heard of it before, you may have even tested for it previously! But what you may not know is the new changes that have happened recently that have updated (from November 19th 2019) the EN71-3 for lower chromium VI, Lead and tin levels. This also involves a whole new procedure to testing, as well as rendering any previous certificates out of date.

What can I do? How do I do it?
Ideally you would test your fabrics asap (with an accredited UK lab!)so that toy makers can continue to use them. Currently they are in limbo as to what they can use while groups and companies retest. We know this is expensive – its so expensive small time toy makers can’t afford to test the fabrics themselves. For small time toy makers here comes in ‘due diligence‘  this is where the small time toy makers do as much as they can within their money limits to keep their materials compliant. This usually includes testing or buying certificates of a selection of material colours (black, cyan, magenta and yellow- or prints containing these colours for the minimum) for each brand and composition of fabric. By doing this yourselves and offering the certificates for free it opens your fabrics up to small scale toy makers, who become loyal (win- win! and especially so if your materials are exclusive to you!)

But my materials already conform to GOTS/OEKOTEX/REACH/earlier dated EN71-3 tests/EN71-2?

Unfortunately this isn’t enough to conform to toy making standards, it needs to be EN71-3 2019 to be up to date and test for all the necessary heavy metals to the right levels with the correct procedures, and needs to have those levels stated on the certificate. If you have recently tested to the 2018 levels with addendum, it may be possible that your certificates state that the levels are within limit and could be used, but the complete certificate with levels is needed for proof and comparison.
EN71-2 for soft toys needs testing on a complete toy rather than fabric samples (fancy dress is different)

Can’t I just issue a conformity note?
No, its just not enough without the proof for the technical files of toy makers, should they come into difficulty with the law, its easier to have a complete technical file with levels stated than backtrack to manufacturers later on, as well as it being a legal need for the technical file.


I hope this helps you as an Importer, Manufacturer, Retailer or supplier with some understanding, we would love to add you to our free resources section!

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