Handmade Toys – CE Marking
Updated Post 1st May 2015
The law regarding children’s toys and CE marking changed back in July 2011 and the new Toy Safety Directive 2011 came into force. This meant that all products (mass produced and handmade) which either looked like a toy or were a toy and for use in play by children under the age of 14 are required by law to have been tested in accordance with the toy safety directive and display a CE logo on their label or packaging.
This was a big change for those making handmade toys as there were previously no laws or guidelines to follow and now small time makers would now have to test their toys to the same spec. as large scale manufactures and mass produced toys. Handmade soft toys in particular would now have to be suitable from birth and although there are some exemptions on the whole if a creation looks like a toy and is considered to have play value by a child then it is considered to be a toy. As this is a legal requirement now for any toy which is manufactured and sold in the UK and EU you can be fined £5000 or even receive a prison sentence if you are making and selling toys without the CE mark.
Below I have put together a variety of information and links together regarding this subject for any fellow artisans who make soft toys such as knitted / crocheted / felt or other fabric style toys (including sock toys) on how to obtain a CE logo for there products.
To start with it is ideal to read up on the BS EN71 toy safety regulations and all the information which your product complies with. You can usually obtain a copy of the directive through your local library services or local trading standards. In regards to soft toys part 1-3 of the the BS EN71 are applicable to you. Another good resource is the gov.uk website for Toy Manufacturers and their Responsibilities this will give you a basic outline of the directive and what is involved. Here is a very good basic guide from Hampshire Trading Standards in relation to Home Toy Producers and their responsibilities.
As I mentioned previously the toy safety directive was updated in June of 2011, to find out how this now effects the manufacturer of toys (including those which are handmade) you can visit the Conformance website HERE. Conformance are an experienced company dealing with CE marking across a whole range of products. Although you can send your toys away to a testing lab to be tested, the most obtainable way for handmade toys to gain CE marking is to self certify your products. Conformance have developed a variety of self certification packs for those who make handmade toys. They do a pack called ‘CE marking for handmade soft toys’ which is specifically designed to help home soft toy-makers to meet the legal requirements of the Toy Safety Directive. This pack has a step by step guide to CE marking for those making handmade toys which includes testing details, what certificates of compliance you will need to collate for your materials and templates for your all your paperwork which is required by law for each type of toy you manufacture. Once you have purchased this pack Conformance are also on hand for advice and guidance via phone or email correspondence.
Once you have completed the self certification process you will be able to add the CE logo to your product. Which can either a sewn in label on your handmade product or a tag style label around your product which ever if more suitable. This will cover any products you offer for sale in the UK and Europe ONLY! If you want to sell your products worldwide then you must abide by the laws on toys for those countries too!
Each type of toy you make will require testing to part 1-3 of the BS EN71 Toy Safety Directive, which include part 1 – torque and tension tests, part 2- flammability and part 3- chemical migration. Parts 1 and 2 are easy to complete at home however you will need to acquire further information about the components of your toys regarding part 3 which is the chemical migration for all external components which would be accessible to a child. Internal components such as toy noise inserts (rattles, squeakers, jingle columns and so forth) do not need testing for part 3 of the regs themselves as they should not be accessible to a child and will just need to be tested inside of the whole toy for parts 1 and 2. You can sometimes acquire details about part 3 from your supplier or the manufacturer of your components such as fabrics, thread, stuffing and so forth. However if these details can not be obtained then your components will require 3rd party testing by a testing house. Once your toy/s have been tested you will require to document all of the details about your toys and the tests which have been carried out to form a full Technical File and Declaration of Conformity to show that your toys reaches the appropriate standards within the regulations and is safe for the appropriate age of child required by law. Once you get the hang of it all it isn’t too complicated it does however just take time and needs to be kept up to date and then kept for 10 years of making each toy.
If you would like further information on CE marking then please visit our new facebook page CE Marking Support Network we are a non-profit association for help and guidance to self certify in accordance with the toy safety directive 2011/13.
For established toy makers who are looking to CE mark their creations we have two support groups which run in conjunction with this page to help spread the cost of sending fabrics to laboratories (notified bodies) to be tested against EN71-3 – Migration of certain chemicals. These test results are then used as part of our technical files to show due diligence. Please join our facebook page where you can then find out further information about these groups.
If you are not making handmade toys however your products are aimed at Children then it is best to seek advice regarding this from your local trading standards. They will be able to advise you on whether your product requires CE marking or if needs to comply with other general safety standards specifically to your product.
DISCLAIMER: Please note while I can inform you of my personal experiences with CE marking, it is not, and should NEVER be, taken as a replacement for information from Toy Safety Experts. Please research the EN71 directive yourself and it is YOUR RESPONSIBILITY to do so. ‘Odds & Soxlets’ take no legal responsibility for the content of this blog post or further advice given. The information provided is based on my personal experience self certifying my own handmade toys for their CE mark.