Ensuring the accuracy of your toy technical documentation

Nowadays, various laws and regulations exist across markets requiring that toy manufacturers draw up necessary technical documentation upon market entry.

When creating technical documentation, toy manufacturers/importers must include the relevant data to ensure the safety of toys and compliance with legislation for each market. In the case of the European market, this is according to the requirements of Toy Safety Directive 2009/48/EC. Let’s take a closer look at this European Directive.

What is toy technical documentation or a Technical Compliance File (TCF)?

Toy technical documentation is a set of documents that demonstrates your toy product has complied with design, manufacture, safety and operational requirements. It is the responsibility of toy manufacturers to produce and retain the technical documentation.

Toy manufacturers are also required to keep the toy technical documentation updated, such as to reflect any changes to the toy and changes in applicable legislation or standards. Whenever a change is made, the history of the product must also be retained.

How long and in what format should a toy technical documentation be kept?

Toy manufacturers must keep the technical documentation and the EC declaration of conformity for 10 years after the toy has been placed on the market. In terms of format, technical documentation can be stored in any format and at any location within a company.

Toy manufacturers are obligated to submit the technical documentation when a market surveillance authority requests so, normally they will fix a deadline for receipt of such file within 30 days unless a shorter deadline is justified in the case of serious and immediate risk.

What should the technical documentation include?

The technical documentation must contain the relevant data used by toy manufacturers to ensure compliance, including:

1. 1. a detailed description of the design and manufacture, including a list of components and materials used in the toy (such as Bill of Materials and Bill of Substance) as well as the safety data sheets on chemicals used, to be obtained from the chemical suppliers;
2. 2. the safety assessment(s) carried out in accordance with Article 18 of The Toy Safety Directive 2009/48/EC;
3. 3. a description of the conformity assessment procedure followed;
4. 4. a copy of the EC declaration of conformity;
5. 5. the addresses of the places of manufacture and storage;
6. 6. copies of documents that the manufacturer has submitted to a notified body (if any);
7. 7. test reports and a description of the means used by the manufacturer to ensure conformity of production with harmonised standards;
8. 8. a copy of the EC-type examination certificate;
9. 9. a colour image of the toy.

Why ensuring the accuracy of toy technical documentation is important?

Technical documentation acts as proof that toy manufacturers have carried out the applicable conformity assessment procedures that ensure their products have been designed and manufactured in accordance with the requirements and regulations when placing their toys on the market.

Recalling products and restricting or prohibiting the toys from being made available on the market are the possible consequences of not complying with the requirements of toy technical documentation. The market surveillance authority may also require the toy manufacturer to have further product examinations performed by a notified body at their own expense within a specified period.

Why choose the Eurofins Toys & Hardlines network of laboratories?

Our global technical experts can assist you in complying with toy technical documentation requirements and help mitigate your compliance risk, protecting your brand alongside ensuring toy safety. Our Technical Compliance File (TCF) service can also be offered together with other services such as chemical, physical, mechanical, electrical, flammability tests which are required by the legislation, offering you an all-in-one testing and compliance solution.

For more details, please visit our Documentary Review and Technical Dossiers (TCF) Service.