Not so long ago, each country had its own specific rules for toys, which meant that a toy made in one country might not meet the regulations of another. Fortunately, the launch of the European Single Market helped minimise these barriers, facilitating the life not only of producers, but of consumers too. The aim of the Single Market has been to ensure that toys offer children the same levels of safety and quality throughout Europe.
Standards are at the heart of this harmonisation process, as they ensure that commonly-agreed principles are shared among companies and stakeholders. However, standardization, especially in the field of toys, is not something abstract: it is a consensus-based process; it involves a wide variety of actors, who collaborate in order to achieve a high level of harmonisation throughout the whole cycle, from production and design, to retail and purchase.
Who are these actors, and how are they involved in the toy safety standardization process?
Given the importance of toy safety for the European consumer, the European Commission (EC) took the initiative to issue a common legislation on toy safety. The latest version of this legislation, the Toy Safety Directive 2009/48/EC, continues to set the same minimum requirements to ensure the safety of toys all across the European Single Market.
A European Directive requires its specific implementation and application by all Member States. In order to specify how this should be implemented, the EC also published accompanying guidelines for producers and public authorities, contained in the Guidance on Toy Safety.
European legislation does not happen in a void: societal and economic stakeholders participate in the drafting of the legislation, share experiences and propose ideas. Their contributions come already at the start of the legislative process, when the need for action on safety emerges.
CEN and CENELEC, two of the three official European Standardization Organizations (ESOs), host the drafting of European Standards that become applicable as national standards in the 34 countries of their memberships. In the field of toy safety, European standardization has a specific relevance, as it supports the legislative requirements of the EC.
In practice, the EC tasks the ESOs with developing the so-called Harmonised Standards (hENs). Compliance with Harmonised Standards (referenced in the Official Journal of the European Union) provides manufacturers with a presumption of conformity to the legal requirements of the Toy Safety Directive.
From the concept of ‘safety by design’, to drafting strict requirements to reduce risks to a minimum, Harmonised Standards related to toy safety cover a wide range of elements in the design and production of toys, ensuring their high reliability.
CEN/TC 52 - Safety of toys, whose Secretariat is held by DS, the Danish National Standardization Organization of CEN, is responsible for establishing requirements and test methods, which support the essential requirements of the Toy Safety Directive. Electrical aspects of toys are dealt with separately by CENELEC/TC 61 ‘Safety of household and similar electrical appliances’.
If the first standards developed in the framework of the Directive dealt with mechanical – such as EN 71-1 ‘Mechanical and physical properties’ - or chemical elements- such as EN 71-3 ‘Migration of certain elements’ or ‘EN 71-2 ‘Flammability’ - in subsequent years, the scope of standardization activities has become wider. The ambition of standardizers is to include and adapt to evolutions in technology, and to proactively anticipate and mitigate risks that can be reasonably foreseen in new toys. An example is the evolution of the EN 71-1 standard itself: through subsequent updates and amendments, it has recently extended its scope to include new types of toys, such as certain flying toys, toy slings, and toy catapults supplied with projectiles.
Reputable manufacturers are guided by the concept of ‘safety by design’ when making toys. Toy safety standards help to give shape to this process, and provide the criteria a toy needs to meet to be considered safe for a child to play with. These criteria do not only look at the toy as an object in itself, they also consider how a child may use it.
As a toy is developed, manufacturers carry out a range of tests to check that the toy complies with all relevant standards. For some toys, this means complying with over 2000 pages worth of rules and standards. Reputable manufactures carry out compliance checks along the different stages of the production process.
There are standards for many different aspects of toy safety, and the specific standards manufacturers apply vary from toy to toy. Testing against standards allows manufacturers to check things like: toys don’t contain substances that they shouldn’t; there are no sharp edges or points; no small parts will break off if dropped or thrown by a child; it is suitably fire resistant and many more. Standards also provide a framework for manufacturers to decide whether any warning labels – such as not being suitable for young children because of small parts - are needed.
The final step in making sure a toy is ready for the shelves is the creation of a ‘declaration of EC conformity’. The declaration, in conjunction with relevant technical documentation, must be kept available for ten years. It certifies to the authorities that the toy conforms will all relevant safety requirements and shows that the manufacturer takes responsibility for this.
Toy safety standards are constantly evolving to make sure that safety keeps up with the latest knowledge. Reputable manufactures have an important role in this process – they provide their real-world knowledge and experience of making safe toys to policy makers and standardisation bodies. Toy Industries of Europe (TIE) is the voice of reputable manufactures to the EU and provides a platform for exchange of information and best practice for its members.
Consumers also make their voice heard and participate to the development of European Standards through ANEC (the European Association for the Co-ordination of Consumer Representation in Standardisation). ANEC brings together experts from its member countries to set positions in the collective European consumer interest.
ANEC acts mainly through participation of its experts in the standards development work of CEN and CENELEC. It also aims to influence European legislation and public policies within the scope of its activities, and represents the consumer view in European fora on the use and application of standards.
On toys, ANEC is particularly involved with the work regarding their safety and the risks posed to children, especially those younger than 3 years of age. It also seeks to safeguard that the requirements of the standards ensure warning symbols, other marks and instructions-for-use are legible and fit for purpose for the wider public, and that test methods and performance requirements reflect how toys are actually used by children.
To lead consumers to a more conscious and responsible purchase of toys, ANEC and TIE have published a free guide with 10 toy safety tips.
The actors and processes presented above are only a glimpse of the complex and important toy safety ecosystem in Europe. To know more about the state of the toy safety ecosystem in Europe on the occasion of the 25th anniversary of the European Single Market and the expectations for the future, read the article on European standardization on toy safety.
For more information, please contact Claire Dalier.
This article is the second one of a series of three articles that CEN and CENELEC is publishing this week dedicated to the toy safety standardization ecosystem. This article is part of our campaign on the 25th Anniversary of the EU Single Market. Follow us throughout the year with the hashtag #SingleMarket. Let us know your examples of how European Standards contributed to the prosperity of the EU economy or how they impact your life for the better. Tell us your stories through the hashtag #TellEUstandards.