• Product Safety

Toy Safety - new chemical requirements in Europe pose new challenges

changes-to-toy-safety.jpgFor those of us involved in making and designing toys for the European market the implementation of the chemical requirements of the Toy Safety Directive is now looming.   All toys placed on the market after July 13th 2013 will need to comply with the revised EN71 part 3 (now in draft).

The key points of difference to the current standard are as follows: 

  • there are 19 elements which will now need testing, the current standard looks at 8 elements
  • many of the limits for the existing elements are lower than currently
  • different limits have been set according to what type of material is being used : dry / brittle, liquid, scrapeable

There is no historical data to show if the materials that are used routinely in printing (for example) are likely to contain any of the newly restricted elements.   So, where we might currently feel comfortable self certifying or relying on supplier's raw material certificates, that comfort blanket has been rudely whisked away!   

As for the cost - testing costs are set to rise, perhaps by as much as three times the current level.  Such hikes are likely to be prohibitively expensive for certain products.   

To add insult to injury, early trials amongst the notified bodies show that there can be huge deviations between results from the different labs, for some elements the detection limit of the equipment and the maximum permissible limits are so close that it impossible to say for sure if the material complies or not!  For one element (Chrome VI) there is no published test method yet.

We'd recommend a three pronged attack:  

  • Engage with raw material vendors and suppliers to ensure they provide you with Bills of Material for your products and have a new programme in place for their raw material testing.    
  • Trial testing on generic final product to start building a picture of where the greatest risks lie so that you can focus on the problem areas whilst still complying with the directive
  • Carry out detailed safety assessments on your product ranges.    Get to know more about the materials used in the manufacture of your toys and the potential chemical risks associated with those materials

And don't have nightmares!


Debbie Knight, Imago UK