EU Toy Safety Directive: A Key Guide to Ensure Toy Safety

EU Toy Safety Directive: A Key Guide to Ensure Toy Safety
In today’s globalized market, the EU Toy Safety Directive (2009/48/EC, TSD) is of vital importance to toy manufacturers, especially those facing international wholesale buyers. Whether it is a traditional toy manufacturer or an emerging squeeze toy manufacturer, understanding and complying with this directive is an important prerequisite for successfully entering and expanding the EU market. This article will explore the specific content of the EU Toy Safety Directive in depth to help you ensure that your products meet the relevant requirements and conduct business smoothly.

1. Background and Scope of Application of the Directive
The EU Toy Safety Directive (2009/48/EC) was issued on June 30, 2009 and came into effect on July 20, 2011, repealing the previous old Directive 88/378/EEC. The directive aims to ensure that toys on the EU market do not pose a threat to the health and safety of children. Its scope of application is wide, covering products designed or intended for children under 14 years of age to play with, including plush toys, plastic toys, electronic and electric toys, etc. However, there are some exceptions, such as public playground equipment, toy cars with internal combustion engines, toy steam engines, etc., which are not within its control scope.

2. General safety requirements
The directive requires that all toys must meet general safety requirements, that is, under normal or foreseeable use, toys and the chemicals they contain must not endanger the safety or health of users or third parties. This means that manufacturers need to fully consider the various behaviors and possible usage scenarios of children during play to ensure that toys remain safe in all situations.

3. Special safety requirements
Physical and mechanical properties: Toys must have sufficient mechanical strength, and accessible parts such as edges and protrusions should reduce harm to the human body, and the size of components must meet safety standards to avoid dangers such as strangulation and suffocation. For example, mouth-actuated toys cannot contain small parts. In addition, toys must pass drop tests, impact tests, and tensile tests to ensure that they will not cause safety hazards when subjected to external forces.
Flammability: Except for toy detonators, other toys themselves must not be explosives and must not contain flammable, explosive, or volatile substances. Toys should be designed and manufactured to ensure that they will not cause fires due to contact with fire sources, thereby protecting the safety of children.
Chemical properties: This is a more stringent and complex part of the directive. First, the directive strictly restricts the migration of specific elements. The number of restricted migratable chemical elements has been expanded from 8 to 19, including lead, arsenic, barium, chromium, cadmium, mercury, selenium, antimony, aluminum, boron, cobalt, copper, manganese, nickel, tin, strontium, zinc, etc., and the limit requirements have been reduced. Secondly, it is prohibited to use carcinogenic, mutagenic or reproductively toxic substances (CMR) in toys or toy parts. In addition, it is also proposed for the first time to prohibit the use of 66 allergic fragrances in toys, adding 55 banned allergenic fragrances, and 11 allergic fragrances that need to be labeled when the content exceeds 0.01%.
Electrical properties: Toys shall not be driven by a DC power supply with a rated voltage exceeding 24 volts or an equivalent AC power supply, and any accessible part of the toy shall not exceed 24 volts DC voltage or an equivalent AC voltage. At the same time, toys must have appropriate insulation and mechanical protection to prevent the risk of electric shock, and the maximum temperature reached by all directly accessible surfaces should not cause burns due to contact. Electric toys must also provide adequate fire protection, etc.
Hygiene: The design and production of toys must ensure that they meet hygiene and cleanliness requirements to avoid any infection, disease and pollution hazards. For toys for children under 36 months, their design and production must ensure that they can be cleaned.
Radioactivity: Toys should comply with all relevant measures on the establishment of the European Atomic Energy Community in Chapter III of the EC Treaty to ensure that they do not cause radioactive hazards to children.

4. Label, packaging and warning label requirements
Label: Toys and their packaging should be accompanied by clear, easy-to-read and indelible labels, including the name and address of the manufacturer or importer, identification information of the toy, CE mark, etc. The CE mark is an important mark indicating that the toy complies with the requirements of the relevant EU directives. Only toys that have been evaluated and meet the requirements can be affixed with this mark.
Packaging: Toys sold with food must be packaged separately, and such packaging must prevent swallowing or inhalation, and must be marked with warning statements. At the same time, the packaging itself should not be small parts to avoid children from accidentally ingesting or choking hazards.
Warning labels: Warning labels should appear on the product and correctly identify the user’s restrictions, such as minimum and maximum age requirements, user ability requirements, maximum or minimum weight requirements, and whether adult supervision is required. In addition, the minimum and maximum age of its users must be stated when the product is sold. For certain types of toys, such as toys with sharp parts or small parts, corresponding warning labels are also required on the packaging to remind consumers to pay attention to safety.

V. Conformity assessment and technical documentation
Conformity assessment: Manufacturers need to ensure that toys meet the requirements of the directive and conduct conformity assessment in accordance with the prescribed procedures. This may include internal production control, type testing or other conformity assessment procedures. When manufacturers adopt relevant harmonized standards or parts of standards published in the Official Journal of the European Union, the presumption of conformity of toys remains valid. However, to ensure that toys are presumed to comply with standards in the absence of relevant harmonized standards, the European Commission will have the right to adopt common specifications.
Technical documentation: Manufacturers should prepare technical documentation to record in detail the design, manufacturing, testing and evaluation process of toys, as well as how to meet the various requirements of the directive. These documents should include product descriptions, design drawings, material lists, test reports, risk assessment reports, etc. When required by market surveillance agencies, manufacturers must be able to provide these technical documents to prove the compliance of toys.

5. Obligations of economic operators
Manufacturers: When placing toys on the market, manufacturers must ensure that their design and manufacturing comply with the requirements of the directive, and prepare product files and implement conformity assessment procedures. When the product evaluation results are qualified, an EC declaration of conformity is prepared and the CE mark is affixed. If the manufacturer finds that the toys that have been placed on the market do not comply with EU regulations, it must immediately take necessary corrective measures, such as withdrawing or recalling the toys, and notifying the competent authorities of the member states.
Importers: Importers should check whether the manufacturer meets the relevant requirements, such as whether there are technical files and whether the conformity assessment procedures are carried out. Random sampling inspections can be carried out if necessary. Importers must also ensure that the instructions or other information on the toys are written in a language that consumers can understand, and ensure that the toys still meet the requirements during transportation or storage.
Distributors: Distributors should check whether toys meet relevant requirements step by step, including checking CE marks, warning labels, etc. If toys that do not meet the requirements are found, the manufacturer or importer should be notified immediately and the product should be stopped from being sold.

6. Recommendations for responding to the EU Toy Safety Directive
In-depth understanding of the directive requirements: Manufacturers should carefully study the various provisions of the EU Toy Safety Directive and clarify the compliance requirements required for their products. At the same time, pay attention to the latest regulatory trends and standard updates released by the EU official to adjust production and management strategies in a timely manner.
Establish a sound quality management system: From raw material procurement, production process control to finished product inspection, establish a comprehensive and strict quality management system to ensure that each link meets the requirements of the directive. Strengthen cooperation with suppliers to ensure the quality and safety of raw materials.
Conduct strict testing and evaluation: According to the test methods and standards specified in the directive, the toys are tested in many aspects such as physical, chemical, and electrical. Professional third-party testing agencies can be entrusted to conduct tests and obtain relevant test reports and certification certificates as proof of product compliance.
Strengthen supply chain management: Establish long-term and stable cooperative relationships with reliable suppliers and partners to ensure transparency and traceability of the entire supply chain. Regularly audit and evaluate suppliers, urge them to comply with the requirements of the directive, and jointly ensure the quality and safety of products.
Focus on product design and innovation: On the basis of meeting the requirements of the directive, focus on product design innovation and function optimization to improve the competitiveness of products. For example, develop safer, more environmentally friendly and more interesting decompression toys to attract the attention and favor of international wholesale buyers.
Training and education: Train employees on the EU Toy Safety Directive and related standards to improve their awareness and understanding of the importance of toy safety and ensure strict compliance with relevant regulations during the production process.

In short, the EU Toy Safety Directive sets strict standards and requirements for toy manufacturers to enter the EU market. For independent sites of products such as decompression toys and squeezing toys, fully understanding and strictly complying with this directive to ensure the quality, safety and compliance of products is an important guarantee for winning the trust of international wholesale buyers and expanding the EU market. At the same time, this is also a necessary measure for enterprises to fulfill their social responsibilities and protect the health and safety of children. By strengthening quality management, technological innovation and market research, enterprises can continuously improve the competitiveness of products and achieve sustainable development on the basis of meeting the requirements of the directive.