Toys

Document Purpose

The purpose of this document is to specify which requirements in Quality Standards & Requirements that are classified as legal according to below set definition.

All requirements necessary to comply with to get safe products that minimize the risk of personal injuries requiring assistance from medical personnel are classified as being legal. This since they fall under General Product Safety Laws. The extent of the injury and the probability of the injury occurring needs to be evaluated.

A requirement is considered as legal when the consequences of the requirement not being fulfilled can result in a personal injury requiring assistance from medical personnel based on foreseeable use and/or misuse. Cases of property damages are only falling under this definition when they have a reasonably foreseeable risk to lead to personal injuries requiring assistance from medical personnel.

Introduction

Children are both physically and mentally developing throughout their childhood. They are not always aware of cause and effect and this makes them more vulnerable to safety risks than adults. We at CDON therefore have a strong focus on safety for children.

It is important that children's products are developed and produced with safety in mind throughout all stages, from design, through production and all the way to the point of sales and beyond.

The purpose of this document is to set the CDON physical safety requirements for toys in order to eliminate or minimize safety risks.

This document will cover the most common physical safety risks in toys, but not necessarily all. All toys must fulfill the safety requirements, also after normal and foreseeable use and abuse.

Our partners need to ensure that the products that are uploaded to CDON marketplace are safe and fulfilling the necessary compliance from a chemical and a physical testing perspective.

GENERAL

TOY CLASSIFICATION

A toy is defined as: “Any product designed or intended, whether or not exclusively, for use in play for children less than 14 years old.”

It is sometimes hard to determine whether a product is a toy or not. For toy definition and product classification connect with CDON for further instructions.

MULTIPLE CLASSIFICATION

A product could have multiple classifications, for example toy + cosmetic or toy + food contact. Multiple classification products must fulfill the requirements for all classifications, tested and labeled accordingly.

PACKAGING

Packaging for toys could sometimes be considered as a toy itself.

PHYSICAL TEST REQUIREMENTS

Toy testing shall be done at a third-party test laboratory. The order number must be present on the test report. Observe that any age restriction on the product must match the information on the test report.

Some products are always for children below 3, and need to be tested accordingly (0 yrs+, 10 month+, 18 months+, 3 yrs+)

General

TEST	STANDARD METHOD	PRODUCTS	REQUIREMENTS
Safety
Toy test – EU	EN 71-1 EN71-2 EN 71-3 EN 71-9 (when applicable)	All toys	Comply according to standard
Additional test for electric toys – EU	EN 62115	All electric toys	Comply according to standard and also comply to EN 71-1, EN 71-2 and EN 71-3
CE Declaration of Conformity	Directive 2009/48/EC	All toys	Comply Certificate

Baby toys

Products in this category are always considered as products for children from age 0 yrs+. Small parts that do not withstand 90N pull test are therefore never allowed (adding a small part warning is not an option).

Baby rattle

A rattle is a toy designed for an infant to hold in the hand or around the foot and makes a noise when it is shaken. Could be made in a variety of materials or combinations of materials. Important that they are constructed so that no part non-textile components can enter the mouth and become lodged in the back of the throat.

All rattles

Tested for age 0 yrs+
No small parts allowed, unless 90N pull test is approved
Sound must not be too loud, will be tested for sound pressure level, maximum 85dB
Non-textile part which fits an oval hole of 5 x 3,5 cm, or a round hole of 4,2 cm must not be longer than 3 cm.

Non-textile rattles – additional requirements

Must withstand drop test.

Textile rattles – additional requirements

Rattling component/bell must be enclosed in a separate fabric casing
Seam strength will be tested so that no filling can be accessed.

Baby comfort blanket

Tested for age 0 yrs+
No small parts allowed, unless 90N pull test is pass
If classified as a soft toy, the requirements for soft toy must be fulfilled as well.

Baby pram chains – to be strung across the pram

Baby pram chains for prams/buggies are intended to be attached across the hood of the pram for a baby to look at and to interact with when older. Risk assessment of this product points to the risk of entanglement and strangulation for babies and young children.

Tested for age 0 yrs+
No small parts allowed, unless 90N pull test is pass
No designs with exposed cord
No round shapes in risky size (must be minimum 45mm in diameter)
Hanging objects from the chain – maximum 7,5 cm (a)

Baby pram toys

Tested for age 0 yrs+
No small parts allowed, unless 90N pull test is pass
Cord or figure on a cord: maximum 14 cm total length
Loop: max 28 cm circumference
Non-textile part which fits an oval hole of 5x3,5 cm must not be longer than 3 cm.
Seam strength will be tested so that no filling can be accessed.

Baby mobile for ceiling

A baby mobile is intended to be hung from a ceiling out of reach from children. This product is only classified as a toy in the USA. Will be tested and labeled as a normal product for all other markets.

Tested for age 0 yrs+
No small parts allowed, unless 90N pull test is pass
Cords: maximum length 22 cm
Require special labeling

Baby musical box

A baby soft toy with a mechanical music box inside. No batteries. You pull the cord and the music box starts playing.

Tested for age 0 yrs+
No small parts allowed, unless 90N pull test is pass
Cords with 3D ending: maximum 22 cm, or separate into parts of lengths not exceeding 22 cm.
3D ending of cord need to exceed small part measurements
Cord with no 3D ending: maximum 30 cm
Self-retracting cord should be min 1.5 mm in diameter (when 25 N is applied). Retraction will be tested in toy test. (Fabric covered cord is a safe option to avoid entrapment of skin)
Fixed loop: max 38 cm or separate into parts with lengths not exceeding 22 cm
Will be tested for sound pressure level
Melody/tune need to be approved by License dept.
Non-textile part which fits within an oval hole/template of 5x3,5 cm, must not be longer than 3 cm.
Seam strength will be tested so that no filling can be accessed.

Bags & Soft toy bag

Bags for children are generally not classified as toys unless they are designed for a multipurpose or designed as a soft toy. If it falls within the toy definition it will end up in one of the below categories: Toy bags: toys for children above the age of 3 years

Soft toy bags: toys for age 0 years+ or 18 months+

Bags sold together with a soft toy must comply with soft toy handbag requirements, tested from age 0 yrs+.

Toy bags

All toy bags

Tested for age 3 yrs+
Drawstring opening: if the opening is greater than 36 cm circumference, then the bag must be permeable to air, or have air holes.
Circular zipper puller holes: must be under 5 mm or over 12 mm to be safe and avoid risk of entrapment.
Labeling - not for children below 3 - small part or long cord depending on design.

Toy bag with shoulder strap – additional requirements

Break away on shoulder strap, 25N +/- 2N

Soft toy bags

All soft toy bags

No small parts allowed, unless 90N pull test is pass
Seam strength will be tested so that no filling can be accessed.
Drawstring opening: if the opening is greater than 36 cm circumference, then the bag must be permeable to air, or have air holes.
Circular zipper puller holes: must be under 5 mm or over 12 mm to be safe and avoid risk of entrapment.

Soft toy handbag – additional requirements

Tested from age 0 yrs+
Loops/handle/strap: max 36 cm circumference or break-away at 25N into free lengths max 22 cm
Zipper puller must not be longer than 3 cm

Soft toy shoulder bag – additional requirements

Tested from age 18 months+
Break away on shoulder strap, 25N +/- 2N
Labeling - not for children below 18 months - long cord strangulation

Soft toy backpack – additional requirements

Tested from age 18 months+
Labeling - not for children below 18 months – long cord strangulation

Balls

All balls

Labeling – not for children below 3 – small parts, if there are small parts or if ball is made of out of foam

Small balls (less than 45 mm diameter)

Not allowed for children below 3 years of age, unless the ball is made of 100% breathable textile such as for example an ordinary pom-pom made from yarn.
Labeling – not for children below 3 – small ball

Balloons

Uninflated or broken latex balloons are a serious choking hazard.

Beach toys – inflatable beach toys, sand buckets etc

There are several severe risks associated with inflatable floating products such as choking, chemicals, and drowning.

Inflatable beach toys (aquatic toys)

Cannot be made from PVC
Require special labeling

Sand bucket & spade

Make sure to use a plastic which breaks in a safe way
Limit the possibility of a child’s head to get stuck in the handle – circumference to be under 36 cm or over 53 cm.

Box/Chest

Boxes, chests that are large enough for a child to enter, and can be closed with a lid, must have ventilation holes or openings of sufficient size on two or more sides in order to prevent suffocation.

Building blocks

For children below 3 years. Not ok in fragile materials

Cooking & Baking sets

Cooking and baking sets for children marketed as toys are foreseeable to be mis-used for real cooking/baking.

Must be tested and labeled as toy and food contact.
No pan holders/oven gloves
Make sure cookie cutters are not sharper than needed for their function
If the products are made of the same or similar material as real cooking tools – then they should be tested so that they withstand normal use for baking/cooking.

Cosmetic products

Many cosmetic products for children will also be classified as toys due to their function/usage or their packaging.

Cosmetic product - face paint

Face paints are being used for skin decoration, especially in the face. The products primarily exist as solid colors; however, some products exist as fluid colors. The products are either water-based or based on fat.

Must be tested and labeled as cosmetic products and toys.

Cosmetic product - hair crayons/chalk

Must be tested and labeled as cosmetic products and toys.

Cosmetic product - lip balm in toy packaging

Lip balm in itself is not a toy, but the packaging could make it a toy.

Must be tested and labeled as cosmetic products and toys.
Lip balms for children may have a fragrance/scent or color as long as the fragrance isn’t enhanced by the packaging (i.e. strawberry fragrance in a strawberry shaped container).
Avoid packages in risky shape/size.

Cosmetic product - temporary tattoo

Temporary tattoo which is applied with water.

Must be tested and labeled as cosmetic products and toys.

Crayons and chalk

Must be tested and labeled as chemical product and toys
OK for all ages even if they become small parts when used – it is in the nature of the product.
Avoid risky shapes – egg shapes for example

Disguise costumes

Disguise costumes are often unique in their designs and have many different features which makes it difficult to set clear requirements for all. Therefore a careful risk assessment must be done on each product, not forgetting wear tests and check of accessories.

All disguise

Must fulfill all garment requirements – Products, as well as toy requirements,
Due to flammability 100% cotton is never possible
Capes must be detachable with a break away feature
Tails that are long and narrow (ratio more than 2:1) must be detachable with a break away feature such as touch-and-close, releasing at 20-25N.
Wider long details such as wings, mermaid tails, dinosaur tails etc must be evaluated through a risk assessment, connected with CDON compliance department.

Disguise for children up to 3 yrs (up to and incl. size 98) – additional requirements

No small parts allowed, unless the 90N pull test is passed.
Sequins not allowed
No narrow shoulder straps, must be minimum 3 cm wide

Disguise accessories – crowns and headbands etc

Note – some accessories are classified as toys due to the fact that they are sold as disguise accessories or together with disguise costumes.

All disguise alice bands, crowns, head bands

Labeling – not for children below 3 yrs – long cord or small part depending on style *
No metal wires thinner than 2 mm

*if fulfilling requirements for <3 yrs, then no labeling required

Disguise alice bands, crowns, head bands for children up to 3 yrs – additional requirements

No small parts
EU: must have a break-away feature
All other countries: not allowed to make for children <18 months

Disguise accessories - capes

Must fulfill all garment requirements.
Must have a break away feature if closed at neck, releasing at 20-25N.
Assess length so that there is no entrapment hazard.

Disguise accessories – footwear

All disguise footwear

Depending on design and making: could require testing and labeling as normal footwear as well as toys.

Disguise footwear for children up to 3 yrs, sizes up to and including size 26 – additional requirements

No small parts

Disguise accessories - headwear/hats, gingerbread man hat, santa hat

All disguise headwear/hats

Labeling – not for children below 3 yrs – long cord or small part depending on style *
Hats that are attached to the head – around the chin, and covering the entire head – risk assessment must be made if there are long details that could be an entrapment/strangulation hazard. Break-away feature could be an option.
Hats should be risk assessed so that the vision is not blocked. Should fit well so that when turning head the child can still see

* if fulfilling requirements for <3 yrs, then no labeling required

Disguise headwear/hats for children up to 3 yrs – additional requirements

No small parts allowed, unless the 90N pull test is passed.
Sequins not allowed
Cords narrower than 3 cm need a break away feature, each length of cord maximum 22 cm
Loop (cord): maximum 36 cm circumference

Disguise accessories – jewelry, bracelets, rings, necklaces, teeth etc

Note that jewelry/accessories that normally would not be a toy could become toy if the packaging suggests it is a play value or part of a disguise outfit.

Jewelry, bracelets, rings, necklaces etc

Labeling – not for children below 3 – small parts

Teeth

No small parts allowed for any age as these are supposed to be in the mouth
Material must be safe to bite without becoming small parts
Make sure they fit properly, and they are not sharp in the mouth

Disguise accessories – masks, eye patch, beards

Accessories that cover the face, or part of the face could obstruct the vision and cause trip and fall injuries. Ensure to have enough holes for breathing, and good vision. The elastics could cause snapping injuries or damage the eyes. Since this product is close to the eyes and mouth attention should be paid to loose glitter, fur or sharp details scratching the face. Fitting/trying products is essential to make a proper risk assessment.

All masks, eye patches, beards

Labeling – not for children below 3 yrs – long cord *
Holes for vision/breathing: recommended total of 1300 mm2, which is equivalent to 2 holes app 3 cm diameter each, minimum 15 cm apart.
If covering both eyes with mesh/clear plastic: make sure it doesn’t obstruct vision, or cause dizziness
Cords in elastic material: use soft or wide elastic
No loose glitter as it is close to eyes
If hairy: be aware of fiber shedding as it is close to eyes
No sharp edges: shape of the design as not to hurt cheeks or eyes
Plastic – check so that it doesn’t break too easily and become sharp

* if fulfilling requirements for <3 yrs, then no labeling required

Masks, eyepatches, beards for children up to 3 yrs – additional requirements

No small parts allowed, unless the 90N pull test is passed.
No foam
Break away needed, each length of cord maximum 22 cm (a=22cm, b=22 cm), measured when stretched at 25N

Disguise accessories – tails

Tail sold as a separate accessory to be attached around the waist.

All tails

Must have a break away feature, releasing at 25N.
Labeling – not for children below 3 yrs – long cord * - if designed with cords narrower than 3 cm
if fulfilling requirements for <3 yrs, then no labeling required

Tails for children up to 3 yrs – additional requirements

No small parts allowed, unless the 90N pull test is passed.
Each length of cord narrower than 3 cm: maximum 22 cm measured when stretched at 25N

Disguise accessories – wigs and fake hair

All wigs and fake hair products for children should follow flammability requirements for toys no matter what classification applies.

Please see section called Disguise accessories - capes

Electrical toys – including toy with batteries

It is very difficult to fulfill the requirements for electrical toys, and the test costs would be major. Toys for children should have batteries, which must be secured to require tooling to access them. No toy should plug straight into the mains electricity supply.

Hobby horse

Tested from age 3 yrs+
Labeling – not for children below 3 yrs – long cord
Break away feature on the reins (cord)
The rod/stick should be of a material that doesn’t break when adding pressure to it/being bent

Keychains, bag charms

There are different requirements for key chains that are soft toys, and ordinary toys.

Toy keychain/bag charm

Tested from age 3 yrs+
If attached to and sold together with garments or bags, key rings are allowed to be no longer than
14 cm including hook/ring and attachment.
Labeling – not for children below 3 yrs, small parts

Soft toy keychain/bag charm

Tested from age 10 months+
No small parts allowed, unless the 90N pull test is passed.
No sequins allowed
Seam strength will be tested so that no filling can be accessed.
Labeling - not for children below 10 months – due to size and shape

Kites

Kites with cords longer than 2 m

Cords must be tested for electric resistance
Special labeling required

Marbles

Tested from age 3 yrs+
Labeling – not for children below 3, choking hazard – small ball/this toy is a marble

Pillows & cushions defined as soft toys

Please see the soft toy section.

Play tents

Tested from age 3 yrs+
Holes: there should always be two holes unblocked by walls when standing in a 90° corner, which means that all sides need holes. The holes should be 650 mm2 each, situated at least 150 mm apart. Note – for a tipi/sloped tent the sides are not completely vertical (they are slopes), air will be able to enter 2 holes even if standing in a corner.
Pop-up tents with wire is not allowed
Require special labeling

Puzzles & Games

All puzzles & games

Puzzles must be appropriate for the intended age.
Labeling – not for children below 3 yrs – small parts *
if fulfilling requirements for <3 yrs, then no labeling required

Puzzles & games for children up to 3 yrs (less than 50 pcs) – additional requirements

No small parts allowed, unless the 90N pull test is pass.
No part of the pieces may break off
No foam puzzles
Puzzles with pegs – not recommended, too difficult to secure

Rugs & play mats

Slip resistant backing

Skipping rope

Tested from age 3 yrs+
Don’t make the cord too lightweight as it makes it difficult for a child to use
Labeling – not for children below 3 yrs – long cord strangulation warning

Snap-on bracelet

Non-soft toy snap-on bracelet

Metal should have molded rubber as casing, or a thick plastic cover inside a fabric outer shell.
Labeling – not for children below 3 yrs - small parts

Soft toy snap-on bracelet – additional requirements

Tested for age 10 months +
No small parts allowed, unless the 90N pull test is passed.
Seam strength will be tested so that no filling can be accessed.
Labeling – not for children below 10 month + due to shape and size

Soap bubbles

Must be tested and labeled as chemical products and toys.
If packaging contains small parts – then small part labeling is required

Soft toy

Soft toys are always for children from 0 yrs of age.

Tested from age 0 yrs+
No small parts allowed, unless the 90N pull test is passed. Small rubber bands to keep hair in place are small parts.
Sequins not allowed
Seam strength will be tested so that no filling can be accessed.
For recycled materials both the chemical, environmental and physical risks need to be
considered.
Plastic beads/polystyrene foam (Styrofoam type) beads are not allowed.
Cords (unpadded): maximum 22 cm
Monofilament hair on fabric base: maximum 5 cm
Yarn hair is OK: maximum 22 cm
Fiber shedding must be tested for long pile
Plastic/glass eyes, noses are not allowed
Must be washable. If a soft toy is too big for a domestic washing machine, then alternative cleaning methods are possible, such as “surface clean”.
Accessories sold together with soft toy must also be tested for 0+

Stationary defined as toys

Not all stationery products are classified as toys

Stationery - eraser

Tested from age 3 yrs+
Labeling – not for children below 3 yrs – small parts

Stationary - coloring pencils, felt tip pens

Small part warning on coloring pens or crayons is only necessary if there are any additional small parts attached to the pencils, such as an eraser. They do not need a small part warning because they get smaller and smaller when sharpened, this is considered part of a pencil’s nature.

All coloring pencils, felt tip pens, crayons, chalk

Must be tested and labeled as a chemical product and toy.
If adding a small part to these products – then a small parts warning must be added

Felt tip pens (pens with caps) – additional requirements

If the lid is a small part – then a small parts warning must be added
Caps which are less than 16 mm in diameter must have a hole to let air through

Stationery - glue

Must be tested and labeled as chemical products and toys.

Wand

Tested from age 3 yrs+
Make sure material is not brittle so it breaks when being bent
Not too sharp
Labeling – not for children below 3 yrs – small parts

Water squirter

Tested from age 3 yrs+
No weapon shapes
Labeling – not for children below 3 yrs – small parts

Watch

Watch which is for play purpose. Moveable arms.

Tested from age 3 yrs+
Labeling – not for children below 3 yrs – small parts
For snap-on watch – see Snap on bracelets

Whistles, blow horns

Whistles and blow horns are toys which are meant to be used with the mouth – therefore no small parts are allowed for any age.

No small parts allowed, unless the 90N pull test is passed.
No loose parts on inside of whistle
Sound level will be checked. Maximum 85 db
Break away feature if long cord
Labeling if cord is used – Not for children below 3 yrs – long cord

Wind-up toys

Tested from age 3 yrs+
Holes: maximum 5 mm
Space between winder key and toy – minimum 12 mm
Labeling – not for children below 3 yrs – small parts

Wings

Wings could be constructed in many different ways, wire, textile covered foam, loose pieces of fabric.

All wings

Labeling required – long cord strangulation*
Wire: No metal wire thinner than 2 mm diameter is allowed for children’s products. Even for wider wire, consider using plastic wire for a safer option.
Wires ends must be turned back or shall be covered with smoothly finished protective caps or covers.