Variations | CE Marking Handmade Toys Collective




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Due diligence is a pretty difficult thing to grasp at the best of times, you in no way want to under-test your toy, as its important that you have a whole toy tested as par the regs. However sometimes you want to make slight variations to your tested toy which you feel may not warrant a full retest. As a small maker with limited funds, with due diligence its possible to do this by testing parts of your toy, cross referencing /using your testing knowledge to show that your variations are safe.

When looking at your variation you need to look at the whole toy in a testing light, to decide what is safe to change and what isn’t without retest. The list of variations are as long as my arm so here’s a few that might apply so you get the general idea.
Changing animal
So, you’ve tested a bunny, and now you want to test a bear – its the same shape and size, but what you’ll do is switch the bunny ears for bear ears. The bunny ears are floppy, unstuffed, the bear ears are round, also unstuffed. They’re the same width. In the flammability test, the ears of the bunny caught light and took the flames up faster but it still passed.
In this example, the bear ears pose less of a risk to the bunny ears, they’re not likely to change the flammability result, and the construction method is the same amount of stitches for each type of ear, so you could feel comfortable in doing this fairly safely. Documenting it all on a variations page in your file. However, If you were to switch this around, you’ve made a bear and now want to make a bunny – the flammability tests are now not transferable from bear to bunny, and you need to retest for flammability.

Test head for hair and ears

test head

some quirky test heads by Hook yarn and stitcher! hook yarn and stitcher

So say now you’d like to make a fox,
If your new fox ears were different somehow in construction, perhaps you’ve stuffed them or they are narrower than your previously tested bunny ears, you may feel that it doesn’t warrant a whole retest of your toy but it does have some changes there, so you need to do something to show they are safe. You might consider a test head.

17800366_10154922087147247_7576256000330051734_nA test head is where the maker makes up a whole head, with the variation(s) on it, sometimes it may have more than one hairstyle or type of ears – that’s fine but remember it may weaken the structure, so if it does not pass first time you may want to try them singularly. It may have two types of eye, three different shaped pony tails and a bow. It will look pretty crazy.
You would then test all the physical variations of your toy on this test head, just as long as the changes are not significant enough to need complete re testing (ie changes in total construction/shape of the toy, changes that could increased risk to flammability) and document them in your file.


Embroidery or applique
If you’re adding embroidery or applique, as long as they are flat to the surface (check if you can get under it with a credit card) they do not need physical testing, large amounts of either could alter the flammability so as long as you’ve previously tested this, altering it won’t mean retesting. Large amounts of new applique or embroidery will probably need testing for flammability.

Colour variations on the same type of fabric don’t need retesting (ie cotton to cotton). However if you’ve switched fabric type they do need a complete retest.

Size variations
Minor size variations may be ok, but think carefully when going from big to small, or vice versa. are there less stitches holding your construction now? Did your small toy not need a flammability test (if it was under 15cm) and now it does?

Adding rattles/squeakers or other additions
Heres one I wrote earlier…
rattles, squeakers, and other additions

Using cross referencing
When you have a few toys under your belt (or rather in your file) its possible to cross reference from one toy to another if the construction for your variation is the same on both toys. So if dolly A has a bow sewn onto cotton fabric and dolly B will have one the same, you could cross reference your files and point towards Dolly A’s testing.

Its no get out clause …just remember, its down to you to test your toys according to the law, and if in any doubt, your safest bet is to test your completed toy.