Beyond conformity marking: Toy safety assessment procedure

Are you manufacturing, importing or distributing toys in the European and UK markets? Did you know that the Directive and Regulation^* applicable respectively in the EU and UK require manufacturers to carry out a mandatory safety assessment? 

That’s right, aside from the conformity assessment procedures through testing with the well-known EN 71 series of standards and before placing a toy in the market, manufacturers must carry out a safety assessment to evaluate not only the possible presence of some hazards but also the potential exposure to them. 

_{*EU Toy Safety Directive 2009/48/EC and UK The Toys (Safety) Regulations 2011}

What is requested in the toy safety assessment? 

The legislation referenced above, requires manufacturers to study and document the potential hazards that each toy may present. The types of hazards to be considered are: 

• Chemical
• Physical & mechanical
• Electrical
• Flammability
• Hygiene 
• Radioactivity

In addition to identifying these hazards, the likelihood and severity of these hazards and the possible injury scenario must also be assessed. 

When to conduct a safety assessment? 

Safety assessments should be carried out before placing the toy on the market. The legislation does not specify when to carry it out and it can take place at any stage during toy development. In any case, it is advantageous to carry out the assessment as early as possible in the concept development stage and keep the safety assessment as a live document during other key stages.

This approach allows manufacturers to implement faster corrective actions when any risk is identified at these early stages, rather than in the production stage or, in the worst case, after a full batch order has been manufactured. 

Regardless of when it is carried out, the safety assessment should reflect the toy to be placed on the market.  

Is there a generic format/content/process for safety assessments? 

The legislation does not specify any particular format and the generic content should be enough to identify all the possible risks. In that sense, it is recommendable to: 

• Obtain detailed information about the product and user (including intended design and function, intended user characteristics, foreseeable use of the toy, BOM and/or BOS, final market, warnings, etc.)
• Identify the applicable legislation and standards
• Assess any hazards not being addressed by legislation or standards
• Evaluate the risk of any remaining hazards
• Reduce and manage these hazards

As the last step and in the scenario that it is not possible to address or identify all possible hazards, manufacturers must undergo the conformity assessment procedure through a Notified or Approved Body to obtain the applicable conformity type certification. 

Why do importers or distributors need to be aware of this as well? 

Importers need to ensure that the technical documentation has been properly drawn up by the manufacturer. In addition, together with distributors, the obligations of a manufacturer may apply to them. For example, if the importers or distributors place a toy on the market under their name or trademark, or modify a toy already placed on the market, they will assume the obligations of a “manufacturer”. 

Eurofins Toys and Hardlines' laboratories in France and the UK are CE Notified Body (NB 2817) and UKAS Notified Body (NB 0355), respectively. Our portfolio offers a variety of services to help companies assess the safety of toys. 

Contact us for support anytime.