When looking at packaging for toys, and watching others choose packaging, I’ve realised there are two types of packaging.
Disposable packaging – clear plastic sheeting/cellophane/tissue paper/gift type packaging – the type where the intention of it is to be binned, not intended as part of the toy in any way.
Functional packaging – boxes for games, a drawstring bag to keep things together
And then there’s toy bags, bags that are meant as toys, or meant to carry toys for example a doll’s changing bag, a soft toy dog carry bag. (needs a CE mark)
So thats what I see….The EN71 in all its wonderful vagueness, in its packaging section largely concentrates on cylinders and their choke risk (think how many times the kinder egg inners have been changed since you were small – all to do with en71 packaging risks) They also have this awful tendency to use the term ‘toy bags’.
The european guidance documents referenced in the regulations can be checked out here: European guidance document Its well worth a read as it helps clear up toy bags, normal bags,and packaging with pictures and its largely what I’m working with on this blog today.
But if you’re anything like me you’ve read it now and A. have got a headache, and B. you still haven’t got a clue on what is OK in packaging and what is not!
So here’s what I can gather together.
Rules on Disposable packaging
by that I mean Packaging meant to be thrown away, and is not part of the toy.
Most packaging itself doesn’t necessarily come under the EN71 regulations, and it is referenced in the european guidance doc that it should follow the General Product Safety Directive, which in very very short, means that it should be safe and not harm anyone…(helpful ;)) If you’d like to read more about the GPSD look here and here if you’re up for some legislation words.
The EN71 DOES mention:
Rules applying to plastic sheeting/bags
– they must be thicker than 0,038mm (bit tricky to measure this at home!)
– for each 30mmx30mm perforated holes needs to remove 1% minimum of the area (so 9 1mm holes in every 30x30mm square)
-Bags made of a flexible plastic with an opening of 380mm or more must not have a cord or drawstring closing (suffocation hazard – they need to be permeable to air)
Due to the complicated rules on plastic bag packaging you might well want to rethink or consult a lab or trading standards before taking that route, and also especially with ball shapes/hemispheric shapes – there are particular rules (this is unlikely to be needed as handmade toy makers, so I’m going to skip over that, but you’re welcome to ask if you did need it!) do be aware if you’re making ball shaped, or cylindrical ended anything when it comes to toys it features heavily as a choke risk.
So going back to the GPSD, in theory if you’ve bought your organza gift bags/tissue paper/ for example from elsewhere, they should also be covered by the GPSD as they shouldn’t be sold if they are unsafe, however as a small time maker its pretty wise to cut any risk you possibly can. Just assume the worst possible case scenario every time and bear in mind your packaging could be used again – by a child. Its not necessary to send warnings on packaging(but some do prefer a discard packaging comment) instead make sure the packaging is safe – choose packaging within the standards in terms of lengths of ribbon or string. and that will not cause suffocation. You could risk assess your packaging if you felt it was a good idea (I know, I know more paperwork!) Examine your packaging each time for quality purposes.
Toy Bags vs Toy bags…
This is where the lines all go a bit blurry.. and fuzzy and wriggly.
Quite often people like to sell their toys with its own bag to store the toys in to keep them clean, together etc. The EU guidance doc states:
“The packaging of many products these days can be re -used whether intended by the manufacturer or not. The packaging might be of a style that encourages it to be used as a means of storing the toy, keeping it clean, transporting the toy and keeping the parts together. Some packaging can be used as background decoration to help display the toy in an appealing way. These are all attributes of “packaging” and nothing to do with play and toys.”
Which is about as clear as mud in terms of ‘is my packaging part of the toy or not, and does it need testing?’
However a bit further on it states: “The reference to toy bag in the standard may result in confusion and more and more bags (bags considered as packaging having no intended play function) being wrongly treated as “toy bags”. Toy bags have to comply with clause 4.4 of the standard, but also with other relevant clauses as these products are toys and not packaging. Bags that are packaging can be attractive to children because they are brightly coloured for example or have child appealing characteristics (Mickey Mouse decorations) but this is not enough to make them a toy bag. There has to remain a difference between a child appealing article like a decorated bag and a so-called toy bag.”
Now its very difficult for me to tell you what the answer is here in terms of your ‘toy bags'(the functional type) and whether they need testing, but in my opinion you can’t really go wrong with keeping drawstrings/lengths/loops minimal and using certified fabrics, but whether they need the CE mark alone I’ll let you decide. CE marking them as part of the toy set is also possible.
and finally.. Bags with an actual play function need to be classed as toys and tested as toys would be, so if you’ve got a shape with a sweets storing function, it looks like a toy, so needs testing. The same with an animal shaped bag, or a dolls nappy changing bag, or if your bag converts into a handy play mat, or other item, its still a toy and needs testing.
Always remember we can guide you but our word is not the law, and its down to you as a maker to ensure you comply with the standards.
Any comments? pop them in the facebook comments box! Happy Packing!