I’ve moved this over from the wiki to get it a bit more love! If you’re looking for paperwork for your technical file for your crayons, they can be found in our guide here
Wax crayons that are shaped do need a CE mark, but the good news is that with a good paper trail, its not so difficult to do. It helps to have a basic knowledge of the EN71.
Mechanical and physical properties: Because crayons are not intended for use from birth as soft
toys are, it is right to put a warning on the label as not suitable for under 3 years due to small parts.
Crayons are exempt from small parts testing whatever the shape, so there is not much do be done for
Crayons do not need flammability testing.
Crayons will need data on the heavy metals in them, which you can obtain but contacting your
crayon supplier. Heating them does not create any new heavy metals in them, so by reshaping them it
makes no difference to the heavy metal content.
It is good practice to request this technical information from your supplier at least annually as manufacturers can change the way that the crayons are produced, keeping your records up to date is essential. (also remember that up to date EN71-3 testing is from 2013 onward, so any certificates before this are not valid)
It is worth noting crayons must not be made in food shapes as this is against the law due to the
possibility of a child trying to eat them.
It is also worth noting that although they may be popular, character crayons are also illegal and breach copyright if reproduced, therefore creating Disney or other Character Crayons are not recommended.
Suggested way to use due diligence to CE mark your crayons:
- Start by choosing your crayon brand and obtaining the data sheet for that brand, put it aside for
your file. Its advisable to use one brand at a time so as not to mix any, and keep separate
moulds for each brand as well as keep a file on each brand separately.
- Keep any emails or information sent from the company or found online on your crayons. Put all
information in your files.
- When buying crayons it is important to mark down the batch numbers of your crayon boxes,
and keep record of this so that if something should happen, you can trace the batch number
back to when and where your crayons were bought from. Keeping a data spreadsheet would be
recommended, so you can mark where it was bought, when, the batch numbers and then also
when you come to batch numbering your own reshaped crayons from that batch, you can mark
this down on the sheet as well.
- If you are working by orders for example, Sue smith orders some crayons from you, You make all
Sue Smiths crayons from a box with batch number 123456, You would note Sue smith’s name
and address, the original batch code(s), and your own code(which could be the date, or
whatever).eg. Sue Smith, 4,Smith Street, smith town, batch 123456, reshaped(animal) 1/1/15
However some people do find it easier to continue using the original batch code provided on the purchased crayons.
The more information kept the better. This way, if the crayon company recalls batch 123456,
you’ll know exactly who to contact to recall yours.
- Document your process of melting, have a separate jug/jar marked with each colour and
perfect your process so it is the same each time. Photograph each stage and put it in your file
with all information such as heat used etc. Ensure everything is washed thoroughly after each
batch of makes so as not to cross contaminate batches.
- Test out your crayon’s performance and durability. This is good practise as a manufacturer.
Document any findings in your file.
- Your packaging is important, you need all the correct labelling to be legal, any warnings should
be bold with a plain background, the CE mark should be 5mm tall, your name and address
should be on there as should keep for future reference, and to remove all packaging prior to giving to a child.Transfer any warnings from the original crayon pack such as the not suitable for under threes.
Its also important to add warning that crayons are just crayons and that spanner shaped crayon is not going to work as a spanner(!!)
Keep copies of your labelling in your file.
- Finally fill in a declaration of conformance stating that your crayons conform to the en71-1,en71-2 and en71-3, sign it, add in any extra information such as warnings on to it as well. You’ll need a new one for each crayon shape you use, but you can add on that it covers all colours by Xbrand.Remember its down to the maker to ensure that they comply with the up to date regulations.
This guide was made with help from Lesley Chattaway: www.fb.com/giftsforyoubylesley
and also Emma Chapman: https://www.facebook.com/TheCraftyMouse
If its been helpful, please do go and share the love!