| Product classification and age grading | Requirements depend on the product’s intended use, design, marketing, and target age. A “decorative” label alone does not automatically exclude a product from toy-safety rules. | Confirm whether the item is legally considered a toy in each destination market. Check age grading, intended users, play features, warnings, and sales descriptions before production. | Written product classification rationale, approved packaging and listing copy, age-grade assessment, and a documented review for each sales market. |
| European Union toy safety | Where classified as a toy, the EU Toy Safety Directive 2009/48/EC applies, with relevant harmonised standards such as EN 71. Conformity assessment, technical documentation, a Declaration of Conformity, and CE marking are required as applicable. | Check that test reports cover the finished product and relevant components, and that the technical file and EU Declaration of Conformity match the exact model and materials. | Current test reports, technical documentation, signed EU Declaration of Conformity, traceability information, and compliant CE marking and warnings. |
| EU chemical and mechanical safety | Relevant EN 71 parts commonly include EN 71-1 (mechanical and physical properties), EN 71-2 (flammability), and EN 71-3 (migration of certain elements), depending on product construction and materials. | Assess seams, attachments, eyes, noses, accessories, filling, surface coatings, and small parts. Confirm test selection reflects the product’s age grade and construction. | Test plan and reports identifying the tested model, materials, methods, laboratory, and report date; records of corrective actions for any failures. |
| United States toy requirements | Applicable toys must meet U.S. requirements, including the mandatory toy standard incorporated under 16 CFR Part 1250, based on ASTM F963. Children’s products subject to applicable rules also require a Children’s Product Certificate (CPC) supported by testing by a CPSC-accepted laboratory. | Verify the applicable ASTM F963 edition and test scope, age grading, required warnings, tracking information, and whether third-party testing and certification apply to the product. | Applicable laboratory test reports, CPC with the required product and rule details, traceability markings, and controlled copies of labels and packaging. |
| Lead and regulated phthalates in the U.S. | For covered children’s products, U.S. limits include 100 ppm total lead in accessible component parts. Certain specified phthalates are restricted to 0.1% in accessible plasticised component parts of covered children’s toys and child care articles. | Review each accessible component, including prints, coatings, plastic parts, and accessories. Confirm whether exemptions or specific testing rules apply rather than relying on a general material declaration. | Component-level material declarations and, where required, test results linked to the actual production materials and finished-product components. |
| EU chemical restrictions | REACH restrictions may apply to substances in articles, including restricted chemicals in accessible or relevant components. Other chemical rules may apply depending on material, product use, and market. | Request substance information for fabrics, dyes, prints, plastics, adhesives, and accessories. Assess restricted substances against current legal requirements and the product’s intended use. | Up-to-date supplier declarations, material specifications, risk-based chemical test reports, and change notifications for material or process changes. |
| Flammability and material selection | Toy flammability requirements may apply under standards such as EN 71-2 in the EU and the applicable ASTM F963 requirements in the U.S. | Check plush pile, fabric, filling, trims, and accessories as a complete product configuration. Avoid assuming that a fabric certificate alone establishes finished-toy compliance. | Finished-product test evidence where required, approved bill of materials, and documented controls for fabric, filling, and trim substitutions. |
| Mechanical integrity and small parts | Toy safety assessments address hazards such as accessible small parts, sharp points or edges, and component detachment. Exact tests depend on age grading and product design. | Inspect eyes, noses, buttons, ribbons, decorative pieces, seams, and closures. Verify attachment strength and foreseeable-use performance for the intended age group. | Approved construction specifications, seam and attachment test records, pre-production samples, and inspection records for the finished product. |
| Product traceability and labeling | Applicable rules can require product identification, manufacturer or importer details, warnings, and traceability information. Requirements differ by destination and product classification. | Check that model or batch identification is legible and that required contact details and warnings appear on the product, packaging, or accompanying documents as permitted by local rules. | Approved label artwork, production lot records, carton markings, and a system linking finished goods to production dates and material batches. |
| EU general product safety obligations | The EU General Product Safety Regulation (EU) 2023/988 has applied since 13 December 2024. It applies to consumer products within its scope and complements sector-specific rules where relevant; it does not replace toy-specific requirements. | For products within scope, confirm applicable risk assessment, responsible economic operator information, consumer-facing safety information, and online-offer details. | Product risk assessment, economic-operator and traceability records, safety-information review, and documented procedures for complaints and corrective actions. |
| Incoming materials and production quality control | Quality-control practices are not a substitute for legal compliance, but consistent material and process controls help maintain conformity across production batches. | Check incoming fabric and filling, color consistency, dimensions, weight, stitching, stuffing distribution, odor, appearance, and workmanship against an approved sample and specification. | Incoming-material inspection records, approved reference sample, in-process checks, final inspection reports, defect criteria, and batch release records. |
| Change management and repeat orders | A change to materials, supplier, construction, factory, or production process can affect existing test evidence and product conformity. | Require written approval before substitutions or design changes. Determine whether a risk review, additional testing, or updated documentation is needed. | Controlled bill of materials, change-request approvals, revision history, re-test decisions, and records showing which documentation applies to each batch. |
| Independent testing and report quality | Testing requirements vary by jurisdiction and product. For applicable U.S. children’s-product rules, testing must be conducted by a CPSC-accepted laboratory. | Confirm laboratory acceptance where required, report authenticity, test methods, sample identity, report date, and whether the tested sample matches the order’s final specification. | Verifiable laboratory reports, sample photographs or descriptions, test scope, laboratory credentials, and a documented link between the report and the production model. |
