UKCA and CE marking of handmade soft

toys
Guidance Notes

This pack is intended to help small-scale home producers who are making and selling
handmade soft toys (e.g. knitted, crocheted, felt or fabric toys). The UKCA and CE marking
process can seem daunting when you first start, but this pack provides a step-by-step
guide to meeting the requirements, including the tests you need to carry out and the
evidence you will need to produce and keep. These requirements also apply to toys that
are given away, donated to charity and rented out.

The pack contains:

• Guidance notes (this document) - Instructions, details of tests and information
on how to complete the UKCA/CE marking process
• Checklist to the essential safety requirements for toys
• Contents list for a technical file (blank for you to edit)
• Example UK and EU Declaration of Conformity (blank for you to edit)

Please note: this pack is only suitable for those making handmade soft toys on a small
scale. If you are making toys on a larger scale as a commercial enterprise, you will be
expected to have your toys tested independently.

Document ref. 3745/23D1784

© Conformance Limited 2023. All rights reserved. No part of this document is to be re-sold, reproduced or transmitted in any form
or by any means, electronic or mechanical, without prior written consent from Conformance Limited.
Scope of this guide
This guide covers the requirements for simple knitted, crocheted, felt and fabric soft toys.

Not included within this guide:

• Toys with magnetic components
• Toys with any metallic or sharp components
• Toys with springs
• Toys with any electrical/electronic elements

If your products fall into any of the categories above, please contact us for further
information.

Please note - although this guide includes the requirements for labels and warnings, it
does not cover the requirements for packaging of toys; please visit our website if you
need further guidance on this: https://www.conformance.co.uk/ce-directives-
information/plastic-bag-warnings

1
Contents
Introduction to UKCA and CE marking 3

The checklist and what to do with it 5

Notes on the checklist 6

The technical file 8

Declaration of conformity 9

The UKCA and CE logos 10

Physical tests (EN 71-1) 11

Small parts cylinder 12

Tension test 14

The test rod 16

The drop test and impact test 17

Small components test 17

Tips if your toy fails the physical tests 19

Flammability tests (EN 71-2) 20

Chemical migration (EN 71-3), organic chemical 22

compounds (EN 71-9) and other chemical
requirements

Laboratories and additional resources 26

2
Introduction to UKCA and CE marking
All toys sold, given away*, donated** or rented out within the UK and EU (including
handmade toys) must be marked appropriately. For the EU, you will need the CE mark;
currently, for Great Britain, the appropriate mark is the UKCA mark but the use of the CE
mark is still permitted.

The UKCA mark

The UKCA mark was introduced at the beginning of 2021. It is the equivalent of the CE
mark and should be used in Great Britain after Brexit. On 1st August 2023, the UK
Government has stated (under what it calls an ‘Easement’1) that it intends to continue
recognition of the CE mark indefinitely for most goods being placed on the market in Great
Britain; this is a statement which revokes the previous mandatory requirement for the
UKCA mark to be placed on applicable goods after December 2024. Hence, at the present
time, the CE mark can be used in Great Britain.

The UKCA mark only applies in Great Britain (England, Scotland and Wales). Because of
the Northern Ireland Protocol, the CE mark is the only mark of the two that can be used
in Northern Ireland.

A toy with a UKCA mark will need a slightly different Declaration of Conformity, listing
the UK legislation instead of the European directives.(Please refer to the ‘Declaration of
Conformity’ section later in these guidance notes). We have also provided a draft of this
type of Declaration if you wish to use the UKCA mark.

In summary:
• You can use either the UKCA mark or CE mark for toys sold in England, Scotland and
Wales (i.e. Great Britain or GB).
• You must use the CE mark for toys sold in Northern Ireland, the Republic of Ireland and
the rest of the European Union.

A toy sold in both Great Britain and Europe can have both the CE and UKCA marks. In this
case, you should fill in both of the Declaration templates accordingly.

Importers and authorised representatives

Additional requirements apply to toys that are imported into Great Britain (GB) or Europe.
As a result of Brexit, from the start of 2021, toys that were previously moved between
these territories by a distributor now require a region-based importer (or an equivalent
region-based ‘Economic Operator’, see below) instead. There are additional obligations,

1 An ‘Easement’ is an official statement, issued by the UK Government, to allow persons to deviate from Directive(s) for a short
period. Their explanation is as follows:
‘This package of measures (Easement) is intended to provide businesses with more flexibility and reduce burdens for businesses. We
(the UK Government) use our regulatory autonomy to help businesses navigate the current global economic and supply chain
challenges whilst prioritising growth. In parallel, we will also consider how we could reduce costs and burdens associated with the
UK regulatory framework in the longer-term, including opportunities under the Product Safety Review. We also intend to introduce
legislation to give effect to the measures previously announced in June 2022 with amended timescales, in line with the extension’.
In effect, the UK Government is trying to introduce the UKCA mark in a less disruptive way, to allow manufacturers to ‘ease into’ the
new requirements.

3
including marking the importer’s name and contact details on the toy itself, its packaging
or documentation. (For the UKCA, there is an additional ‘labelling easement’2).
Please also be aware that new import regulations (the MSR)3 came into force in July 2021.
Products (including toys) that are imported into the EU can only be sold if a company has
representation based in that territory. This is by means of an EU-based ‘Economic
Operator’ such as an importer, authorised representative or fulfilment service provider.
This is important because it also applies when a toy is sold direct to end users, such as
online. It is also very important to note that whomsoever fills this role, the MSR imposes
specific requirements upon them, including the legal obligation to either hold or have full
access to all the evidence of compliance.

Although the UK Government has decided not to implement the requirements of the MSR
(apart from in Northern Ireland, where it does apply) strict obligations do remain on all
importers as imposed by the Toy (Safety) Regulations (i.e. the transposed Toy Safety
Directive), associated legislation plus any other applicable regulation that has been used
in the manufacturing of the toy.

If you only sell toys in the country where you are based, (i.e. if you make toys in GB and
only sell them in GB, or if you make them in the EU and only sell them in the EU) then you
do not need a representative. If you make toys outside the EU and sell them in the EU
(and likewise for the UK) and you would like more information, please email
enquires@conformance.co.uk.

Note that, whether you are applying the CE or the UKCA mark, if you do use an ‘authorised
representative’ as your Economic Operator, then their name and addresss is to be added
to the Declaration of Conformity. (See later in this guidance on how to complete your
Declaration).

If an importer is used, this information is usually added to the toy post production but it
is important to note that it must be present before it is put up for sale (given away, hired,
donated, etc.).

You should also make yourself aware that if you are intending to export into the EU or
into the UK, using an ‘authorised representative’ may well have certain advantages over
using an importer. Further information on this subject and its advantages can be found
at: https://www.authorisedrepresentativeservice.com.

* and **: To find out if this applies to you, or for further advice, please email
enquiries@conformance.co.uk.

2 This ‘labelling easement’ (issued on 14/11/2022) was presented by the UK Government, and is as follows: ‘These measures intend
to reduce labelling costs by continuing to allow businesses to affix the UKCA marking, and to include importer information for
products from EEA countries (and in some cases, Switzerland) on an accompanying document or a label until 31 December 2027’.
Hence, with regards to the physical UKCA mark itself and irrespective of the other requirements in applying the mark, until 31st
December 2027, rather than being permanently (i.e. rigidly, indelibly, etc.) affixed to the toy itself, the UKCA mark (and also the
importer’s name and address, if applicable) may be applied instead by means of a label (of the mark) affixed to the toy and /or its
packaging and /or a document accompanying the toy.
Therefore for toys being sold only in Great Britain and are using the UKCA, you may add the UKCA mark and importer information
onto an accompanying document or label. This Easement does not apply to CE marked goods (for sale either into the EU or into Great
Britain). The Government’s intention (given the resistance from industry) for this Easement was that stocks of already manufactured
and labelled goods could simply have the information added; i.e. to have a transition period permits the use of temporary labelling
rather than the need for it to be 'permanent and indelibly fixed’ / sewn-in.
(Author’s note: We appreciate that these Easements are often contradictory (there are others in other Directives which are
generating more concern) but we can only cite the current legislation as presented - as to not highlight these allowances may cause
you and other companies unnecessary issues. So, while the UK Government allows this Easement, we, at Conformance, recommend
that you follow the Toy Safety Directive itself and satisfy 3.1 on the checklist).
3
The Market Surveillance Regulation (EU) 2019/1020

4
The Checklist
The checklist consists of two sections, the Toy Safety Standard (EN 71) and the
Essential/Particular Safety Requirements. The Particular Safety Requirements (PSRs) are
taken from the Toy Safety Directive (for CE marking), and the Essential Safety
Requirements are taken from the Toys (Safety) Regulations (for UKCA marking). These
are the most basic legal requirements that your toy must meet.

In order to determine if the requirements have been met, more specific guidance is laid out
in EN 71, the Toy Safety Standard. This standard gives detailed instructions on what
testing should be carried out, what to include on your toy labels and what documentation
you need to produce and keep. There are three main parts to the Standard - Part 1:
Mechanical and physical properties, Part 2: Flammability, and Part 3: Migration of certain
elements. Our checklist also includes some sections from Part 9: Organic chemical
compounds. It is generally accepted that if your toy complies with all the relevant parts of
the toy safety standard, you can assume it complies with both the Directive and the
Regulations. You should work through the Toy Safety Standard checklist first, checking
off each section as indicated below. If your toy passes all these sections, you can read
through and tick off the requirements. Your toy must pass all of the applicable safety
requirements.

Please note - if you make accessories for soft toys such as clothes, these accessories must
also meet the same requirements as the toy itself.

Completing the Checklist

You should complete the checklist in the order it is written, as the tests need to be carried
out in this specific order. Go through each line of the checklist and carry out the tests as
described. Detailed guidance for each test can be found on page 11 onwards. Mark each
line as "pass", "fail" or "not applicable", as shown on the front page of the checklist. If you
have ticked "not applicable" for any line, you should explain why this requirement doesn't
apply to your toy in the comments section. If your toy has failed a section you will need
to reconsider the design of the toy, or the materials or methods used in its construction.
You will need to address any issues before you can continue testing, and once you have
resolved these issues you will need to start the checklist again from the beginning. Some
tips are given on page 19 if your toy has failed any of the tests.

Please be aware that these standards are subject to change. While we do our best to
keep this information up to date, you should ensure that the standards you use are
current. This can be checked through BSI using the link on page 26 (or similar standards
organisations around Europe). As the manufacturer of a toy it is your responsibility to
monitor updates to the standards, and apply the changes as necessary.

Please note - the checklist, technical file and declaration of conformity all have space for
a document number. This is for your own reference and will help you if you have more
than one model of toy that you keep records for.

5
Checklist A
The Toy Safety Standard: Mechanical and physical properties (EN
71-1)
Section 1: Material cleanliness
The standard requires you to use material that is "new or as clean as new", so according
to this part of the standard, you can use recycled, vintage or second hand material.
However, you will find it much harder to meet the requirements of Part 3: Migration of
certain elements if you use second hand material.

Section 2: Toys intended for children under 36 months

You must be able to soak wash your toy (i.e. wash by completely immersing the toy in
water), unless this is likely to damage an internal component such as a rattle or squeaker.
If the toy cannot be soak-washed, then you must be able to wash the surface of the toy.
You should include washing details on the label or packaging. You should also consider
the effects of washing on the toy, and if necessary carry out the tests again after washing.

Section 3: Labelling - warnings, markings and instructions

A soft toy must have a sewn-in label, unless it is not possible, for example where the size
or nature of the toy does not allow it. If the CE and/or UKCA mark is not affixed to the
toy there must be a reasonable and legitimate reason to justify this decision. We
recommend this is documented within the Technical File.
If your toy has a sewn-in label, you should include the UKCA and/or CE mark on this label.
Don't forget, this label also needs to comply with the same requirements as the toy itself,
including the chemical migration requirements. If it doesn't have a sewn-in label then
you will need to include the UKCA and/or CE mark on the packaging (which can be a simple
tag label), as well as the following details:

• Name (or company name) of the manufacturer (the person making the toy)

• Address of the manufacturer (this must be a physical address, a website/email

address is not sufficient)

• Toy model number or name (so each toy can be identified)

• Warnings (to notify the consumer both before purchase and during use of any
potential hazards to a child). Warnings should be visible at the point of sale - if
you sell online for example, you should make sure you include any warnings in
your product information.

• Cleaning/washing instructions

• Instructions for use and additional safety information if applicable

• If you have included information on the packaging or a removable label, it is

advisable to include the phrase "Please retain this information for future
reference".

6
 • If required, the name and contact details of an importer (or an equivalent region-
based ‘Economic Operator’) must be included. (Please see page 3 above for
further details). For products imported into the UK and EU please email
enquiries@conformance.co.uk if you require further information.

Section 4: Test methods

The tests should be carried out on a completed, stuffed toy. However, some of the tests
may damage the toy, so you might want to make a sample specifically for testing. Make
sure you use the same methods and materials as you usually use for your toys.

Section 5-8
See details of tests on page 11 onwards. We have not included any extra details on the
torque test - simply follow the instructions given in the checklist.

Section 9: Quality control measures

You will need to make sure you have a clear written method to ensure that all of your
toys meet the same standard as the toy you used for testing, and this needs to be
documented. For example, for knitted toys you would need to keep a record of the type
and make of yarn, needle size, stitch tension and method of sewing seams. You will need
to make sure all your products are made to the same standard. If you use a different yarn
or stitching method on a different model of the toy, you will need to consider the effects
of this on the physical strength of the toy, and carry out further tests on the new toy if
required.

Checklist B: Flammability (EN 71-2)

See the details of how to carry out the flammability tests on page 20.

Checklist C: Migration of certain elements (EN 71-3) and organic

chemical compounds (EN 71-9)
You cannot carry out these tests yourself, so you will need to obtain this information from
the supplier or have your toys tested by a lab. Details on what to look for are given on
page 22.

Checklist D: Essential/Particular Safety Requirements

Your product MUST pass all the applicable sections in this checklist! These are taken from
the Toy Safety Directive and Regulations; they are the legal requirements your toy must
meet. Some of the requirements are quite vague in their wording, so they are cross-
referenced with other checklist sections which contain more specific details. If your toy
has met all of the requirements of checklist A, B and C, you can assume that it meets the
essential safety requirements of checklist D but you still need to complete the checklist
to show that nothing has been overlooked.

7
The Technical File
The technical file for your toy should contain all the evidence to show that the product
meets the legal requirements of the Toy Safety Directive and/or Regulations. Each model
of the toy should have its own technical file, and each model should be given a name or
number to identify it. For example, if you made 10 different knitted animals, these would
need separate technical files. If you made one animal in two sizes, you would include the
details of both sizes in the same technical file. You don't have to store all your evidence
as a complete technical file - you may find it easier for example to keep all your
certificates/data sheets from manufacturers together, rather than copying the same
information into every technical file. However, whichever method you chose to store your
evidence, you will need to be able to collate all the relevant information quickly for each
toy.

The technical file needs to be kept for 10 years after the toy is sold. You don't need to
keep a hard copy, but you will need to consider what format to store it in to avoid any
potential problems with obsolete or incompatible technology. If you are storing the file
electronically, you will also need to ensure that you have your documents backed up
sufficiently. The only people who have a right to see your technical file are enforcement
authorities such as Trading Standards - you don't need to supply it to your customer.

Completing the Technical File

You should fill in the highlighted sections of the technical file with the relevant details.

Description of product: This should be detailed and include colour photographs.

Rationale for claim of compliance: This has been completed for you.

Address of manufacturer and place of storage: You are the manufacturer; this doesn't
refer to the manufacturer of your supplies. You should use a company name if you have
one, or your own name if not.

Photographs of product and packaging: These should be high resolution, in colour, and
include all views of the toy (i.e. front, back, sides, top and base), and an indication of
scale.

Quality control measures: In this section you should include all the information from your
suppliers (e.g. datasheets, certificates or packaging showing that all your supplies meet
the Directive) as well as details on how you will maintain the quality of your products
(e.g. design and construction methods such as stitch tension, seams, etc.).

Checklist: Include your completed checklist, and fill in the document reference number.

Declaration of Conformity: Include your completed Declaration (see notes on page 9).

8
The Declaration of Conformity
You will need to fill in the highlighted sections on the <Company header / Logo / Trademark if applicable>

example. (The example shown is the Declaration for CE EU Declaration of Conformity (No. ####)1
In accordance with European Parliament and Council Decision No 768/2008/EC Annex III

1. Product model / product:

marking rather than for UKCA marking). The description can Product
Model/type
<Type of toy>
<Model name/number/reference>

be quite brief, but you do need to include a high-resolution

Batch/serial no. <Batch or serial number, single or range>
2. Manufacturer:
Name <Company name>

photograph. The declaration should be stored with the Address <Full postal address>
Authorised Representative:2

technical file, and is usually only seen by an enforcement Name

Address
<Company name>
<Full postal address>

authority if there is an issue in the future.

3. This declaration is issued under the sole responsibility of the manufacturer.
4. Object of the declaration:
Product <Detailed description of the toy>
<A colour image of the product MUST be included here
It must be sufficiently clear to identify the toy>

There is a section on the example declaration for listing the

5. The object of the declaration described above is in conformity with the relevant Union
harmonisation legislation:
2009/48/EC The Toy Safety Directive

standards you have assessed the product to - if you have used 6. References to the relevant harmonised standards used or references to the other
technical specifications in relation to which conformity is declared:
Reference & Date Title

any standards in addition to the toy safety standards, you will EN 71-1:2014+A1:2018
EN 71-2:2020
Safety of toys – Part 1: Mechanical and physical properties
Safety of toys – Part 2: Flammability

need to list them here.

EN 71-3:2019+A1:2021 Safety of toys – Part 3: Migration of certain elements
<Standard reference, <Standard title>
date, amendments>
7. The notified body <name, number> performed <description of intervention> and issued
the certificate: <reference>3
8. Additional information:

You should fill in the UKCA Declaration template for toys sold Signed for and on behalf of:
Place of issue:
Date of issue:
<Name of manufacturer or authorised representative>
<Location>
<Date declaration issued>

in England, Scotland and Wales, otherwise you must use the Name:
Function:
<Full name of signatory>
<e.g. Director, Q.A. manager>

EU Declaration. You must fill in the EU Declaration template Signature: <Signature of person detailed above>

for toys sold in Europe and Northern Ireland.

Realistically, unless you are importing toys, it's very unlikely that you will need to show
your technical file or declaration(s) to anyone, so it is tempting to ignore them as they do
take some time to compile. However, they are a legal requirement of the UKCA & CE
marking process, and they should be in place before you apply the appropriate mark to
your toy. It is also much easier to compile your technical file when you have just made
your toy than several years later when an issue has been raised and you are told to provide
it in a court of law.

You will notice that there is an item 7 on the example which talks about a ‘Notified Body’.
This refers to an EU-based, government-recognised test house; when based in the UK it is
called an ‘Approved Body’. You may need to perform the necessary tests that are listed
in the the toy-safety standards (which are explained in more detail later in this guidance)
if you are unable perform the required tests yourself.

If you do need to use such a body, this is straight forward in the EU as, once your selected
Notified Body has performed the tests for you and issued you with a certificate, you can
then place that information on the Declaration. Note that in the EU, Approved Bodies are
not recognised so the test must be done by an EU-based, ‘Notified Body’. In the UK, where
it was once mandatory to have a UK-based ‘Approved Body’ perform the tests for the
UKCA mark, this requirement has both been eased and is also under review. Hence, given
the recent changes rearding the use of the CE mark in the UK, this may well change again.
Given this constantly changing situation, we advise you to contact us for information on
the latest situation if you do need to go down this route.

9
The UKCA and CE mark

The checklist contains details on the size and position of the UKCA and CE logo. You can
download both logos from our website:
https://shop.conformance.co.uk/hikashop-menu-for-module-98/product/ukca-logo
https://shop.conformance.co.uk/hikashop-menu-for-module-98/product/ce-mark-logo

Once you are confident that your toy meets the requirements, and have signed the
corresponding Declaration, you can add the UKCA and/or CE mark and start selling. You
don't need to notify or register with anyone; the process is entirely self-regulating.

Help!
You can purchase 1 hour of consultancy time for any queries you have whilst completing
this process. If you need help with completing the checklist, technical file or Declaration,
then please purchase your consultancy time from our online shop.

10
The physical tests (EN 71-1)
As mentioned previously, you should carry out the tests in the order specified on the
checklist, and on a complete, stuffed toy. Some of the tests may damage the toy though,
so you might want to make a sample specifically for testing. Make sure you use the same
methods and materials as you usually use for your toys.

You should also consider the effect that washing will have on your toy, and if necessary
carry out the physical tests again after washing the toy in the recommended way. For the
flammability requirements, you will need to carry out the tests both before and after
washing the toy.

What you will need to carry out the tests:

• 2 x G-clamps with 19mm diameter clamp pads (see figure 6)

• "S" shaped hook
• Strong bag
• Up to 9kg of weights in small units (tins/bags of sugar are good for this)
• "12mm diameter rod with fully radiused end" (i.e. a hemispherical or rounded end) -
for example the handle of a wooden baking spoon.
• Set of spring scales
• Stopwatch
• Another pair of hands if available

Figure 1: What you will need to carry out the physical tests

11
 The small parts cylinder

The
Thesmall parts
small parts cylinder
cylinder tests ensures that the toy will not cause a choking hazard. The
toy, or any detachable part of the toy must not fit entirely into the cylinder in any
Theposition.
small parts cylinder
If any partstest ensures
of the that the
toy come off toy will
after thenot causetest
torque a choking hazard.
or tension test,The
these
toy, or any detachable part of the toy must not fit entirely into the cylinder in any
parts must not fit entirely into the cylinder. If you are using small parts, or if any part
position. If any parts of the toy come off after the torque test, tension test, drop test or
of your toy such as arms, legs, ears etc, are small enough to fit into the cylinder, then
impact test, these parts must not fit entirely into the cylinder. If you are using small
you or
parts, must ensure
if any these
part of yourdotoy
not come
such off when
as arms, legs,the
earstorque andsmall
etc, are tension teststohave
enough been
fit into
thecarried out.then you must ensure these do not come off when the torque and tension
cylinder,
tests have been carried out.
A template for the cylinder is shown below. Make sure the template is the correct size
before you
A template foruse
the it! Cut the
cylinder template
is shown out in
below. paper
Make sureorthe
card, and use
template is the correct
tab to glue
size or
tapeyou
before together. Place
use it! Cut thethe cylinderout
template on in
a paper
flat surface as and
or card, shown
usein figure
the tab to3.glue
Youorcan then
tape
together. Place
place any theparts
small cylinder
into on
thea cyclinder
flat surface
andasdetermine
shown in figure
whether 3. they
You can then placeAn
"fit entirely".
anyexample
small parts
of ainto
toy the
thatcylinder and determine
fits entirely whetheristhey
into the cyclinder "fitinentirely".
shown An example
figure 4, and a toy that
of adoes
toy not
thatentirely
fits entirely into the
fit is shown in cylinder
figure 5. is shown in figure 4, and a toy that does not
entirely fit is shown in figure 5.

Figure 2 - the small parts cylinder

Figure
This2template
- the small parts be
should cylinder
to scale, but check the size before you use it. The
bottom edge (not including the tab) should be 100mm, and the short side edge
This template
should should be to scale, but check the size before you use it. The bottom
be 25.4mm
edge (not including the tab) should be 100mm, and the short side edge should be
25.4mm

12
 Figure 3 - 3completed
Figure testtest
- completed cylinder on on
cylinder flatflat
surface
surface
Figure 3Figure
Figure 3 - completed
- completed test test cylinder
cylinder ononflat onsurface
flat surface
surface
Figure 33--completed
completed test
test cylinder
cylinder flat
on flat surface

Figure 4 - 4a -toy
Figure that
a toy fitsfits
that entirely into
entirely thethe
into test cylinder
test cylinder
Figure 4 - a toy that fits entirely into the test cylinder
Figure 4 - a toy that fits entirely into the test cylindercylinder
Figure 4 - a toy that fits entirely into the test
Figure 4 - a toy that fits entirely into the test cylinder

Figure
Figure 5 - 5a -toy
a toy that
that does
does notnot
fit fit entirely
entirely into
into thethe
testtest cylinder
cylinder
Figure 5Figure
- a toy5that
- a toy that
does notdoes not fit entirely
fit entirely into theinto
testthe test cylinder
cylinder
Figure 5 - a toy that does not fit entirely into the test cylinder

13
The tension test ensures that the cover material and seams are strong enough t
withstand pulling and tearing. If a part comes off after this test, you need to make sur
Thefit
it doesn't
The tension test
entirely
tension into the small parts cylinder. You also need to make sure that n
test
stuffing has come loose.
The tension test ensures that the cover material and seams are strong enough to
The tension
withstand testand
pulling ensures
tearing.that
If athe
partcover
comesmaterial
off afterand seamsyou
this test, areneed
strong enough
to make sureto
For this test,
itwithstand you will
doesn't fitpulling
entirely need:
and tearing.
into If aparts
the small part cylinder.
comes offYouafter thisneed
also test,toyou
makeneed to that
sure makenosure
it doesn't
stuffing hasfit entirely
come loose.into the small parts cylinder. You also need to make sure that no
stuffing has
•2 x G-clamps with 19mmcome loose. clamp pads
For this test, you will need:
•"S" shaped hook
For this test, you will need:
•Strong
• 2bag x G-clamps with 19mm clamp pads (see figure 6)
•7.2kg• •2ofx weights,
"S" shaped hook
G-clamps in small
with 19mmunits
clamp pads
• •"S"
Strong baghook
shaped
• •Strong
7.2kg of
bagweights, in small units
•7.2kg of weights, in small units

Figure 6 - G-clamps with 19mm

clamp pads
Figure 6 - -G-clamps
Figure with
G-clamps 19mm
with 19mm
clamp pads
clamp pads
The clamp pads should have
Thediameter
The clamp
clamp pads of should
pads 19mm to ahave
have
should ensurea that th
diameter of 19mm to ensure that the
tension
diameter is spread
of 19mm to ensure over
that the
the correc
tension
tension is spread
is spread over
over the correct
the tocorrect
area.
area. You You may
may need need
to improvise improvise
to t
area. You may need to improvise to
get
get thethe correct
correct size -size - washers
washers or coins or coin
get the correct size - washers or coins
can be be
useful for this.
cancan
be useful useful for this.
for this.

Figure
Figure 77 -- attaching
attaching the
the clamps
clamps

Figure 7 - attaching the clamps

14
 Figure 8 - attaching the clamps to your toy
(The tissue paper Figure was used -to protect the toy as the
toclamps were covered in oil)
Figure 8 - attaching the8clamps attaching
to your thetoy clamps your toy
(The tissue paper was used to protect the toy as the
the clamps were
were covered in oil)
Attach(The the tissue
clampspaper to the wastoy usedon to protect
either sidethe of toy
the asseam. clamps
The clamps covered
must beinatoil)least
30mm
Attach apart, and at equal toydistances eitherfrom the seam.
seam.Once you havemustattached least
the
Attach the the clamps
clamps to the toy
to the on either
on side of
side of the
the seam. Theclamps
The clamps must bebeatatleast
clamps
30mm firmly, hold the toy by one of the clamps and hang the hook and bag onto the
30mm apart, apart,and andatatequal equal distances
distances from fromthethe seam. OnceOnce
seam. you have attached
you have the clamps
attached the
other
firmly, clamp,the as shown in figure the9. The bag should be hanging off the floor.
clampshold firmly, hold toy by theone toyofby oneclamps
of the and hang the
clamps andhook
hangand
thebag onto
hook the
and other
bag ontoclamp,
the
as shown
other clamp, in figure
as 9.
shown The
in bag
figure should
9. The be hanging
bag should off
bethe floor.
hanging off the floor.
Gradually add the weights to the bag over a 5
second
Gradually period the until you have reached 7.2kg
Gradually add add the weights weights to to thethe bagbag overover aa 55
(equivilant
second
second period
to 70N).
period until
Maintain
until you you have
the reached
have reached
weight for 7.2kg 10
7.2kg
seconds,
(equivalent
(equivilant then to remove
to 70N).
70N). Maintain the weights
Maintain the and clamps.
the weight
weight for
for 1010
seconds,
Check that then
no remove
parts or the
stuffing weights
have and
come clamps.
loose.
seconds, then remove the weights and clamps.
Check that no parts or stuffing have come loose.
Check that no parts or stuffing have come loose.
If you have used eyes, buttons or other small parts
onIf you
yourhavetoy,used you eyes,
will buttons
need or other
to carry outsmall
a parts
separate
If you
on your have
toy, used
you eyes,
will buttons
need to or other
carry out small
a parts
separate
test on
on your these
toy, you components. If
will need toIf carry the component
out a separate has a
test on these components. the component has
diameter larger than 6mm diameter (or the
atest on theselarger
diameter components.
than 6mm If the component
diameter (or hasthea
longest
diameter edgelarger is longer than than 6mm),
6mm you will (or
diameter needthe to
longest edge is longer than 6mm), you will need to
attach
longestaaedge
attach clamp
clamp to
to the
is longer component
the than 6mm), you
component and will
and oneneed
one to the
to the
to
body
attach
body of the
of athe clamptoy.
toy. to Gradually
the component
Gradually add the
add the and weights
weights over
one over
to the aa
55body
second
second
of the period
period until you
until you add
toy. Gradually have reached
havethereached
weights9.2kg. 9.2kg.
over a
Maintain
Maintain
5 secondthe the weight
weight
period for
for you
until 10 seconds,
10 seconds,
have reached then remove
then remove 9.2kg.
the
the weights
weights and
and clamps.
clamps.
Maintain the weight for 10 seconds, then remove Check
Check that
that the
the
component
component
the weights has
has notnot come
and clamps.loose. If If the component
the
Check component
that the
has
has aa diameter
diameter less
less than 6mm
component has not come loose. If the component (or the
the longest
longest edge
edge
isis
hasless
less than 6mm),
than
a diameter 6mm), lessyouthan should
6mm apply(or the the
the same
same edge
longest test
test
but
but with
withthan
is less 5.1kg.
5.1kg. 6mm), you should apply the same test
but with 5.1kg.
fIfyou
you have
have used attached ribbons,
applique yarn ortechnique
or similar similar to to the
toy please refer to the checklist for safety
attach
f you a small
have usedcomponent
applique (for example
or similar eyes made
technique to
requirements on the length. If the ribbon or yarn
ofattach
felt),athen small check to see if
component (foryouexample
can insert eyes a made
fits into the small parts cylinder, you should carry
0.4mm
of felt),
out thick
thencard
a tension check
test between
as to see the
indicated if you small
can part
above. insert
If theand the
aribbon Figure 9 - suspending the
Figure 9 - suspending the
main
0.4mm
or toy.
yarn thick If
is too youcard can't
large insert
between
to fitthe the
into card,
small then
thepartsmall you
andparts
the weights
Figure from the
9 - from the toy
suspending toy
the
weights
don't
main need
toy. to
If carry
you out
can't this
insert test.
the
cylinder, carry out the tension test as above using card, then you weights from the toy
don't need
2.5kg of weights. to carry out this test.

15
 If you have used applique or a similar technique to attach a small soft component (for
example eyes made of felt), then check to see if you can insert a 0.4mm thick card
between the small part and the main toy. If you can't insert the card, then you don't need
to carry out this test.

The test rod

The test rod
After youyou
After have
havecompleted
completed thethe
tension
tensiontest,
test,you
youneed
needtotocheck
checkthat
thatthe
the stuffing
stuffing cannot
cannot be
be felt
felt through
throughthe thecover
covermaterial.
material.TheThetesttest requires
requires you you tototry
to try to insert
insert a "12mma "12mm
diameter
diameter rod with a fully radiused end" through the seams or cover material
rod with a fully radiused end" through the seams or cover material where the tension where thetest
tension test was
was carried carried
out. The out.
"fully The "fullyend"
radiused radiused
meansend"
the means the end
end should should be
be hemispherical
hemispherical (rounded) rather than flat. You will probably be able
(rounded) rather than flat. You will probably be able to find a wooden baking to find a wooden
spoon with
a 12mm
baking spoondiameter handlediameter
with a 12mm and rounded
handle end.
and rounded end.

Area where tension

test was carried out

Figure 10 - exerting a 10N force with the test rod

Figure 10 - exerting a 10N force with the test rod
You need to try to insert the test rod with a force of 10N, which equates to 1kg. You can
You need to try to insert the test rod with a force of 10N, which equates to 1kg. You can
measure this by pushing down onto a set of spring scales, as shown in figure 10.
measure this by pushing down onto a set of spring scales, as shown in figure 10.
Hold thethe
Hold spoon in place
spoon overover
in place thethe
scales withwith
scales the the
rounded endend
rounded pointing upwards,
pointing upwards,andand
position thethe
position toy toy
so that thethe
so that section youyou
section need to test
need (where
to test the the
(where tension testtest
tension waswas
carried
carried
out)out)
is over thethe
is over end
endofofthe
thespoon.
spoon. YouYou may
may find anan extra
extrapair
pairofofhands
handshelpful
helpful here.Push
here.
Pushthethe
toytoy down
down ontoonto
thethe spoon
spoon untiluntil
the the scales
scales readread
1kg. 1kg. You need
You will will need
to testtothe
testseams
the as
seams as well as the cover material. Watch the end of the spoon carefully to see if it
pushes through the seam/cover, and inspect the toy carefully after the test. If the
16
spoon can be inserted through the seams or cover material, or if the spoon has created a
hole in the fabric, you will need to re-think your design (see tips on page 15).
well as the cover material. Watch the end of the spoon carefully to see if it pushes
through the seam/cover, and inspect the toy carefully after the test. If the spoon can be
inserted through the seams or cover material, or if the spoon has created a hole in the
fabric, you will need to re-think your design (see tips on page 19).

The drop test and impact tests

If you have used any small hard components such as buttons or eyes, you will also need to
carry out the drop test and impact test. This does not need to be done if you have used
“safety” eyes or other components which already bear the CE mark.

For the drop test, drop the toy five times from a height of 850mm onto a flat hard surface,
preferably steel. You should drop the toy in such a way that the small component hits
the metal surface first – so for example if the toy has a button nose, drop it so the button
hits the surface first. After the fifth repeat, check to make sure that the component has
not broken or cracked.

For the impact test you will need a cylindrical 1kg weight with a diameter of 80mm (try
using a tin can filled with weights). Place the toy on a flat hard surface (again, preferably
steel) in the position where the hard component is most likely to break. Drop the 1kg
weight from a height of 100mm onto the toy so that the 80mm diameter surface (the
bottom of the can) hits the toy first. This only needs to be done once. Check that the
component has not broken or cracked.

These two tests ensure that any hard components used on the toy will not break into small
pieces which would be a choking hazard, or produce any hazardous sharp edges.

The small components test

If you have used any small internal components in your toy (e.g. rattles, squeakers, etc.)
that fit entirely into the test cylinder, you will need to carry out this test. If the
components are too big to fit in the cylinder, you don't need to. Standard fibre toy stuffing
isn't classed as a small component, but if you use a filling such as polyester beads or
similar, you will need to carry out this test.

After carrying out the tension test and using the test rod, you need to use another probe
to ensure the small component or filling can't be touched. The dimensions of the probe
are shown in figure 11. It basically mimics a child's finger, so it is made of rigid material
and is articulated in two places, and is therefore more tricky to improvise than the other
tests. However, since the probe is designed to mimic a small child's finger, the easiest
way to carry out this test would be to obtain a small child whose fingers are the right
dimensions!

17
 the right dimensions!

Figure 11: The articulated test probe. The three sections marked "14.7mm" are the
Figure 11: The articulted test probe. The three sections marked "14.7mm"
articulated sections, and should bend up to 90o, mimickingo a finger bending at two
are the articulated sections, and should
joints.bend up to 90 , mimicking a finger
bending at two joints.
You
Youneed
needto
to determine
determine whether you can
whether you can insert
insert the
the articulated
articulatedpart
partofofthe
theprobe
probethrough
through
the
theseams
seamsororcover
cover material
material using
using aa force of 10N
force of 10N (equivalent
(equivalent to
to 1kg)
1kg)ororless.
less. You
Youcan
can
measure the force by pushing against a set of spring scales, as for the test rod (figure 10).
measure the force by pushing against a set of spring scales, as for the test rod (figure
You should try to insert the probe where the tension tests have been carried out. Remove
10). You should try to insert the probe where the tension tests have been carried out.
any accessories or clothing where possible, and try to insert the probe at all possible
Remove any accessories or clothing where possible, and try to insert the probe at all
angles, pivoting the sections up to 90 o if necessary. You should not be able to touch the
possible angles, pivoting the sections up to 90o if necessary. You should not be able to
small component, or filling material if you think that your filling counts as a small part.
touch the small component, or filling material if you think that your filling counts as a
small part.

18
Hints and tips if your product fails any of the physical tests
Toy or parts of toy come apart after torque or tension tests
If this happens, check to see whether the loose parts fit in the test cylinder. If they are
too big to fit in the test cylinder, the toy will still pass - although you might want to
reconsider your construction technique to avoid complaints! If the loose parts are small
enough to fit in the test cylinder, you will either have to develop a stronger stitching
method, or alter the design of the toy so that any parts that come off are too large to fit
in the cylinder.

Stuffing comes loose after torque or tension tests

If your stuffing is classed as a small component, you will either need to ensure that your
stitching is strong enough to prevent stuffing coming loose, or you will need to consider
using a lining material to contain the stuffing.

The testing rod or articulated probe can be inserted through the cover material
You will either need to re-design the toy (e.g. using a different fabric, or for knitted toys,
using tighter tension, smaller needles etc), or consider using a lining material.

Eyes, buttons or other small parts come off after torque or tension tests
If these small parts fit into the test cylinder you will either need to develop a stronger
stitching method, or consider a different design that doesn't use these small parts.
Including a backing material or lining fabric where the stitching is might help to give more
strength.

19
The flammability tests (EN 71-2)
All toys need to meet the requirements for flammability. Unless you can get evidence
from your suppliers that all your materials comply with EN 71-2, you will need to carry
out the flammability tests yourself, or pay for a laboratory to do it for you. This section
describes how to carry out the flammability tests yourself. However, the tests laid out in
the standard are very specific, and you may not be able to reproduce them accurately at
home. Therefore it is very important that if you have any doubts as to whether or not
your product meets the requirements, you should get the toy tested professionally.
Details of labs can be found on page 26.

Important safety notes

In case you didn't know, attempting to set fire to things is dangerous. Before you start,
take the time to prepare your workspace properly. Have a fire extinguisher, fire blanket
or bucket of water to hand, and make sure someone else is nearby. Use a suitable non-
flammable stand to hold the toy - don't hold it yourself. Be aware of any molten or flaming
material falling onto the floor or work surface and setting your carpet/lawn/feet alight,
and clear away any flammable material such as paper. If you have them, use safety goggles
and gloves, and make sure you are not wearing flammable clothing. We recommend you
carry out the tests outside, or in a space that has solid flooring. If you carry out the test
outside, make sure there is no wind as this could cause the toy to burn more quickly.

The test should be carried out on a complete toy. You should test the toy both before
and after washing in the recommended way, so you may need two samples for testing. If
you sell the toy with any clothing or covering, you should carry out the test with these in
place - however, if there is more of a risk when the clothes or covering are removed (i.e.
the covering is less flammable than the toy itself), you should also test it without the
clothes.

You should test each component or material separately before testing the completed toy.
This is for your safety, and also to reduce the likelihood of wasting time making a toy out
of material that is too flammable. When held vertically, the toy (or the soft-filled part
of a toy) needs to have a minimum height of 150mm - if no surface on your toy is greater
than 150mm, you should test each component separately. The test for individual
components is referred to as a "surface flash" test - you simply need to check that when
you apply a flame to the component, it extinguishes itself or does not spread rapidly.
Carry out the test on all the components you use on your toy, and any new components
you include at a later date. If the toy is larger than 150mm you will need to carry out the
full flammability test below. You will also need to test on all the components you use for
each different toy (e.g. different colours of the same material), but you may not need to
test a completed toy each time.

The toy should be at normal room temperature (around 20oC), and at normal humidity
(65% if you happen to have a hygrometer). The temperature of the test room should be

20
 between
o
10oo and 30o, and with no air movement. If you choose to do the tests outside,
between 10 C andbe
it must 30aC,completely
and with no airday
still movement.
(and dry If youobviously!).
too, choose to doThe theflame
tests outside,
height should be
it must be a completely still day (and dry too, obviously!). The flame height shouldo be
20mm, plus or minus 2mm, and the flame should be held at an angle of 45 (see figure
20mm, plus or minus 2mm, and the flame should be held at an angle of 45±2o (see figure
12). 12).
The toy should be held vertically to present the maximum area for vertical spread - use
a non-flammable
The toy should stand for
be held vertically this, don't
to present theattempt
maximum toarea
holdforthevertical
toy yourself.
spread Apply
- use athe flame
for 3 seconds.
non-flammable stand for Thethis,distance between
don't attempt the the
to hold burner
toy tube and the
yourself. Applytoythe
should
flamebefor
5mm, and
3 seconds.theThe flame shouldbetween
distance make contact at the
the burner bottom
tube and the of toy
the should
toy, or be at 5mm,
least 150mm
and thefrom the
top of the toy. When you remove the flame after 3
flame should make contact between 20 and 50mm above the base of the toy, and at leastseconds, you need to time the
120mm fromspread the of
topthe
of the toy. When
flame/burn toyoutheremove
top of the flame
toy. If after
your 3toyseconds, youthan
is bigger need500mm,
to you
time the spread of the flame/burn to the top of the toy. If your toy is bigger
can stop timing when the flame/burn reaches 500mm. If the toy self-extinguishes (i.e. than 500mm,
you can stop
flaming timing when
occurs andthethen
flame/burn
goes out reaches
without 500mm.
spreading),If the
then toyit self-extinguishes
meets the requirements.
(i.e. flaming occurs and then goes out without spreading),
If it doesn't self-extinguish, you need to work out the rate of then it meets thespread
requirements.
(time divided by
If it doesn't
distance!). If the rate of spread is less than 30mm per second, then the toyby
self-extinguish, you need to work out the rate of spread (distance divided meets the
time). Ifrequirements.
the rate of spread is less than 30mm per second, then the toy meets
If you are not sure of your results or the results are borderline, then get the
requirements. If you are not sure of your results or the results are borderline, then get
your toy tested by a lab.
your toy tested professionally by a laboratory.

If you useIfa you useofamaterials

variety variety of materialsthe
throughout throughout thehead
toy (e.g. the toy is
(e.g. the head
a different is a different
material
material
to the body) to need
you will the body)
to makeyousure
willthat
needeach
to make surematerial
different that eachis different material
tested. This meansis tested.
that if theThis means
flame that if the flame
self-extinguishes self-extinguishes
and doesn't spread onto and doesn't
every spread
material ontoyou
used, every
will material
used, you will need to start the test
need to start the test again on the new section. again on the new section.

Top
At least 120mm
*

Flame
Base
: 20 mm (min) to
*

50 mm (max)
(vertical distance
from base of toy
to flame)

Figure
Figure 12: 12: Carrying
Carrying out the flammability
out the flammability test test

21
The chemical migration (EN 71-3), organic chemical compounds
(EN 71-9), Toy Safety Directive and REACH chemical
requirements
There are currently four references for chemical compliance requirements when
manufacturing toys:

• EN 71-3
• EN 71-9 (Now discontinued but a useful resource for best practice)
• Annex II, (Indent 11 and Appendix C) of the Toy Safety Directive
• REACH Annex XVII

The chemical migration requirements from EN 71-3 are obligatory and ensure that certain
elements with the potential to be present in toys either; a) do not leach out of the toy
when it is sucked or chewed, or b) if they do leach out, they are within safe limits. You
will need to compare migration figures shown on data sheets with the maximum migration
limits shown in Table 1. If the migration amounts on the data sheet are less than the
limits in Table 1, you can assume that your toy meets the requirements. If you have proof
that your materials don't contain any of these 19 elements, then this will also meet the
requirements. In the absence of datsheets you should have your toys tested in a
laboratory, where fabric samples would be taken from your toy and placed in a solution
that mimics stomach acid. The solution would be agitated for a set amount of time, then
analysed to determine the quantity of these elements that have migrated from the fabric
into the solution.

Restrictions for organic chemical compound contents were previously detailed in EN 71-9
(shown in Tables 2a, 2b and 2c), but this standard has now been withdrawn in favour of
directly referencing compounds in Appendix C, Annex II of the Toy Safety Directive
(examples listed in Table 3 but the list is regularly updated – so check the Directive). You
should ensure that the chemicals listed in Appendix C are not listed on datasheets for your
components or materials, but we recommend that it is best-practice to also do this for
those listed in Tables 2a,b and c. Where you have obtained certification for your
materials, you should check the requirements of the certifying body and ensure that the
certificate covers these compounds. Note: Some compounds are collectively known as azo
dyes and so you may find that the certification states that the product doesn’t contain
any azo dyes, rather than listing the individual compounds shown in Tables 2b and 2c.

Part III ,Section 11 in Annex II of the Toy Safety Directive lists a set of allergenic
fragrances which are also banned from toys, or which require a warning label. Please refer
to the Directive for more information. If possible we recommend not using any such
fragrances altogether.

The REACH (Registration, Evaluation, Authorisation and Restriction of Chemicals

Regulations), apply to the manufacture and use of chemicals. ANNEX XVII of the
Regulations covers the restriction of certain substances from being used or placed on the
EU market in products (including toys). This mainly affects the use of plastics, so if you
use any plastic components in your toys you need to ensure that they don’t contain any
substances that are banned or restricted under the REACH Directive. Three groups of
materials known as phthalates, azo dyes (see also EN 71-9) and polycyclic-aromatic
hydrocarbons (PAH) are restricted. As an example, the list of restricted phthalates is
shown in Table 4, but you should check for Azodyes and PAH substances too.

22
Testing
Unlike tests from other parts of the Toy Safety Directive, which you may be able to
undertake, it is not possible to re-create the chemical tests required yourself. It is wise
therefore to first search for supplier certification or evidence that the materials you use
comply already, as testing will be costly and you may be able to avoid it. Some of your
materials (such as toy stuffing or safety rattles) may already be CE/UKCA certified, or
come with test certifications, in which case you simply need to keep a copy of the
packaging or accompanying information. Otherwise you will need to contact the
supplier and, if you are lucky, they might know that their materials or products comply
with EN 71-3, EN 71-9, Appendix C, Annex II of the Toy Safety Directive and REACH.

Unfortunately, many suppliers don't have this kind of testing done themselves and won't
be able to tell you whether or not the materials are safe for toy making. They should
however be able to provide you with data sheets for dyes, coatings and materials. You
can then check these data sheets against the requirements.

If you can't obtain the relevant data sheets, or are unsure if the data sheets you have
obtained are suitable for providing the evidence required for chemical compliance, then
you may need to consider having the toys tested independently. Please note evidence of
EN 71-3 is compulsory as this standard is harmonised. If this is not practicable, then you
can use a risk assessment process to ensure you have lowered the risk of harm to the end
user to a level that is as low as reasonably practicable, given the absence of test results
or certification. It may be possible to rationlise the use of e.g. OEKETEX or GOTS certified
materials, or purchase from UK or EU-based suppliers/manufacturers in order to mimimise
the risk of non-compliance. A word of warning though - if you choose to use third-party
certifications (for example an Oeko-Tex certificate), then you will need to compare those
results with the details shown in Table 1, but the limits given are specific to the test
method detailed within the EN71-3 standard. Other testing methods (such as those used
in Oeko-Tex certification for example) may not be the same, leading to results that are
not directly comparable. You need to be aware of this as you take a risk (a very slight
risk - it is extremely unlikely that any manufacturer will be using these chemicals in their
products) that your toy may not meet the standards required, even though you have test
data.

It is important that you record the rationale behind decisions you have made to mitigate
risk when other certification is not available, and this mitigation should only be done if
other avenues have not produced the documented evidence required in a practicable way.

The CAS numbers shown in Tables 2,3, and 4 are unique numbers assigned to every
chemical. They are an internationally recognised reference, and you may find that the
CAS number is used instead of the compound name on data sheets or certificates.

23
 Element Migration limit from toy material
when tested in the specified way
mg/kg
Aluminium 28 130
Antimony 560
Arsenic 47
Barium 18 750
Boron 15 000
Cadmium 17
Chromium (III) 460
Chromium (VI) 0.053
Cobalt 130
Copper 7 700
Lead 23
Manganese 15 000
Mercury 94
Nickel 930
Selenium 460
Strontium 56 000
Tin 180 000
Organic Tin 12
Zinc 46 000

Table 1: Maximum limits of chemical migration when the tests are carried out in the
way specified in the standard

Compound CAS Number

Tri-o-cresyl phosphate 78-30-8
Tris(2-chloroethyl) phosphate 115-96-8

Table 2a: Organic compounds banned in toys – flame retardants

Colour Index Name CAS Number

Disperse Blue 1 2475-45-8
Disperse Blue 3 2475-46-9
Disperse Blue 106 12223-01-7
Disperse Blue 124 61951-51-7
Disperse Yellow 3 2832-40-8
Disperse Orange 3 730-40-5
Disperse Orange 37/76 12223-33-5 and 13301-61-6
Disperse Red 1 2872-52-8
Solvent Yellow 1 60-09-3
Solvent Yellow 2 60-11-7
Solvent Yellow 3 97-56-3
Basic Red 9 569-61-9
Basic Violet 1 8004-87-3
Basic Violet 3 548-62-9
Acid Red 26 3761-53-3
Acid Violet 49 1694-09-3
Table 2b: Organic compounds banned in toys – colours (azo dyes)

24
 Compound CAS Number
Benzidine 92-87-5
2-Naphthylamine 91-59-8
4-Chloroaniline 106-47-8
3.3’-Dichlorobenzidine 91-94-1
3,3’-Dimethoxybenzidine 119-90-4
3.3’-Dimethylbenzidine 119-93-7
o-Toluidine 95-53-4
2-Methoxyaniline (o-Anisidine) 90-04-0
Aniline 62-53-3

Table 2c: Organic compounds banned in toys – primary aromatic amines (used as the
base for azo dyes

Substance CAS Number

TCEP (Tris(2-chloroethyl) phosphate) 115-96-8
TCPP 13674-84-5
TDCP 13674-87-8
Bisphenol A 80-05-7
Formamide 75-12-7
1,2-benzisothiazol-3(2H)-one 2634-33-5
Reaction mass of: 5-chloro-2- methyl- 55965-84-9
4-isothiazolin-3-one [EC no. 247-500-
7] and 2-methyl-2H -isothiazol-3-one
[EC no. 220-239-6] (3:1)
5-Chloro-2-methyl-isothiazolin-3(2H)- 26172-55-4
one
2-methylisothiazolin-3(2H)-one 2682-20-4
Phenol 108-95-2
Formaldehyde 50-00-0

Aniline 62-53-3

Table 3: Substances restricted by Appendix C, Annex II of the Toy Safety Directive

Phthalate CAS Number

Polychlorinated biphenyls (PCB) 1336-36-3
Polychlorinated terphenyls (PCT) 61788-33-8
Bis (2-ethylhexyl) phthalate (DEHP) 117-81-7
Dibutyl phthalate (DBP) 84-74-2
Benzyl butyl phthalate (BBP) 85-68-7
Di-“isononyl” phthalate (DINP) 28553-12-0 and 68515-48-0
Di-“isodecyl” phthalate (DIDP) 26761-40-0 and 68515-49-1
Di-n-octyl phthalate (DNOP) 117-84-0

Table 4: Phthalates restricted in toys to concentrations of 0.1% by mass

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Useful Contacts - Testing

The following laboratories can carry out testing to EN 71-1, 2 and 3.

Bureau Veritas Consumer Products Services UK Limited

31 Kingsland Grange
Woolston
Warrington
Cheshire WA1 4RW
Tel: 0345 600 1828
Email: bvsales@uk.bureauveritas.com
Web: http://www.bureauveritas.co.uk

SGS UK Limited: 0151 350 6666

Intertek UK: 0116 263 0330
SATRA Technology Centre: 01536 410 000

Support and information

Some general advice on CE marking handmade toys can be found on the Conformance
website:
https://www.conformance.co.uk/handmade-or-homemade-toys

You may also find the information on the BusinessLink website helpful:
www.businesslink.gov.uk/bdotg/action/layer?r.i=1084732005&r.l1=1081597476&r.l2=108
4663915&r.l3=1084755726&r.l4=1084731529&r.s=m&r.t=RESOURCES&topicId=1084731529

The Toys Advice website also has some useful information:

http://www.toysadvice.co.uk/

There is also a Facebook support group for anyone UKCA and CE marking their toys:
https://www.facebook.com/groups/779808745368557
While they can't give legal advice, people often share information from suppliers and
recommend suppliers whose products meet the standards.

The Directive and Regulations

The Toy Safety Directive can be viewed here:
https://www.conformance.co.uk/ce-directives-information/toy-safety-directive
The Toys (Safety) Regulations can be viewed at:
https://www.legislation.gov.uk/uksi/2011/1881/contents

The Standards
You can purchase copies of all parts of the Toy Safety standards through the BSI shop:
https://shop.bsigroup.com/

26
You may be able to view them for free at your local library. If you think that your toy
may need to comply with any additional standards, you can search for these on the BSI
webpage.

Useful links
For the latest information and updates please read more on the gov.uk website:

https://www.gov.uk/guidance/placing-manufactured-goods-on-the-market-in-great-
britain
https://www.gov.uk/guidance/using-the-ukca-marking
https://www.gov.uk/government/publications/toys-safety-regulations-2011/toys-
safety-regulations-2011-great-britain#glossary
https://www.conformance.co.uk/about/news/452-ce-mark-recognition-extended-
indefinitely-by-uk-government

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