5.EU Toy Safety Standards for Products Under Age 14: CE Marking & EN 71 Compliance Guide

2. CE Marking Responsibilities

2.1 Manufacturer Responsibilities

If you are the manufacturer, you must complete the following six steps before affixing the CE marking:

1. Identify applicable EU directives and harmonised standards

2. Verify product-specific safety requirements

3. Determine whether third-party conformity assessment (Notified Body) is required

4. Test the product and confirm compliance

5. Prepare and retain technical documentation

6. Affix the CE marking and issue the EU Declaration of Conformity

The conformity assessment procedure may vary depending on the product.

2.2 Importer Responsibilities

When importing toys from non-EU countries, the importer must ensure that:

1. The manufacturer has completed all compliance steps

2. The EU Declaration of Conformity (DoC) and technical documentation are available

3. Communication with the manufacturer is always possible

Importers must retain documentation for at least 10 years after the product enters the EU market.

2.3 Distributor Responsibilities

Distributors must ensure that handling and storage do not compromise compliance. They must:

• Confirm the product bears CE marking where required

• Identify non-compliant products

• Assist authorities by providing documentation

📌 If a distributor or importer markets the product under their own brand, they legally assume manufacturer responsibilities.

3. EU Declaration of Conformity (DoC)

3.1 What Is a DoC?

The EU Declaration of Conformity is a mandatory legal document signed by the manufacturer or authorised representative, declaring full compliance with EU law.

By signing the DoC, the manufacturer accepts full legal responsibility for product compliance.

3.2 Required Contents of a DoC

A valid DoC must include:

1. Manufacturer or authorised representative name and address

2. Product model, serial number, or type identification

3. Statement of sole responsibility

4. Product identification for traceability (image optional)

5. Notified Body details (if applicable)

6. Applicable EU legislation and harmonised standards

7. Name and signature

8. Date of issue

9. Supplementary information (if applicable)

The DoC must be translated into the official language(s) of the EU country where the product is sold.

3.3 Technical Documentation

In addition to the DoC, manufacturers must maintain technical documentation, including:

• Test reports

• Risk assessments

• Material specifications

Both documents are used together to demonstrate compliance.

4. Toy Safety Directive 2009/48/EC (EN 71 Standards)

Toy products bearing CE marking must comply with the harmonised EN 71 standards.

Core EN 71 Test Requirements

4.1 EN 71-1: Mechanical & Physical Safety

Evaluates risks such as:

• Sharp edges

• Small parts

• Structural integrity

4.2 EN 71-2: Flammability

Ensures materials do not ignite or spread fire excessively.

4.3 EN 71-3: Migration of Certain Elements

Tests the migration of 19 specific chemical elements from toy materials.

4.4 Additional EN 71 Parts

Depending on product type, additional testing may include:

• EN 71-7: Finger paints

• EN 71-4 / EN 71-5: Chemistry and chemical toys

The laboratory determines the final test program based on materials and functions.

5. REACH Chemical Compliance

In addition to EN 71, toys sold in the EU must comply with REACH regulations.

Common REACH Testing Items

• REACH Phthalates

• REACH Cadmium

• REACH PAHs

• REACH Organic Tin Compounds

• REACH Benzene

📌 Test items are selected by the laboratory according to material composition.

Conclusion

For toys and board games intended for children under 14, EU compliance requires far more than a CE logo. Manufacturers must ensure:

• Correct application of CE marking

• Full EN 71 testing under the Toy Safety Directive

• REACH chemical compliance

• Proper documentation and traceability

Early compliance planning and cooperation with experienced manufacturers and accredited laboratories are essential to avoid customs delays, recalls, or legal penalties.