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Toy safety certification and children's goods

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A few facts

The age line sets the tests, the directive sets the file

Below 36 months the test plan changes. Whatever the grading, the Toy Safety Directive decides what the file holds and how long you keep it.

  • 36 months Age grading below which the EN 71-1 small-parts test and the strictest EN 71-3 limits apply
  • 19 Elements whose migration EN 71-3 limits, lead, cadmium, chromium VI and aluminium among them
  • 10 years Keep the safety assessment in the technical file under Directive 2009/48/EC
  • 4–12 Weeks per market, typical timeline

Source: Directive 2009/48/EC on the safety of toys, and the EN 71 series

How it works

Five steps from an inquiry to a registered certificate

Typical timeline4 to 12 weeks per market

  1. You send the request

    Product name, HS code and technical data, enough for us to scope the route.

    Your part
  2. We confirm the route

    A specialist confirms the regulations that apply and the document type your product needs.

    Our part
  3. Documents and contract

    You send the supporting documents; we sign a contract with fixed scope and timeline.

    Both sides
  4. Testing and inspection

    Laboratory testing, factory inspection and customs clearance, coordinated by us.

    Our part
  5. You receive the certificate

    Issued, registered, and delivered. We close the project.

    Your part
  • One named specialist One person owns your file from the first email to the registered certificate.
  • Route fixed before testing Scheme, standard and laboratory are settled before a sample is tested, which is where most re-testing starts.
  • Registered documents Certificates and declarations issued by accredited bodies and entered in the official register, where customs can look them up.
  • Measured by the document The engagement ends when the certificate is issued and registered, whatever the hours took.
The short answer

Your age grading sets the tests

Toy safety certification turns on one decision the manufacturer makes: the age grading. A toy graded for under 36 months faces the small-parts test of EN 71-1 and the strictest migration limits of EN 71-3; the same toy graded higher does not. Everything follows from it, in the EU under the Toy Safety Directive 2009/48/EC, in the US under ASTM F963 and CPSIA, and in the Eurasian Economic Union under TR CU 008/2011, where toys are certified by an accredited body. Grading a product upward to avoid testing is the most expensive mistake in this category, because market surveillance grades it by how it is marketed.

  • Under 36 months A toy graded for under 36 months faces the EN 71-1 small-parts test and the strictest EN 71-3 migration limits. The same toy graded higher does not.
  • EU and US follow it Everything follows from the grading: in the EU under the Toy Safety Directive 2009/48/EC, in the US under ASTM F963 and CPSIA.
  • EAEU: body certifies In the Eurasian Economic Union, under TR CU 008/2011, toys are certified by an accredited body.
  • Grading up backfires Grading a product upward to avoid testing is the most expensive mistake in this category, because market surveillance grades it by how it is marketed.
  • The age grading

    You set it, and it has to match the packaging imagery, marketing copy, size and play pattern. Under 36 months brings the EN 71-1 small-parts test and the strictest EN 71-3 migration limits.

    A grading the packaging contradicts is treated as the lower grade.

  • Reports by market

    EN 71 under Directive 2009/48/EC, ASTM F963 and CPSIA at a CPSC-accepted laboratory in the US, TR CU 008/2011 certification in the EAEU, the G-Mark on GSO adoptions of EN 71.

    An EN 71 report does not substitute for ASTM F963 in the US.

  • Materials and retests

    EN 71-3 migration limits apply per material, so a new pigment, plasticiser or supplier can invalidate a report on a toy that looks identical. Test shared base materials once and map them across the range.

    Update the bill of materials before mapping a change against the reports.

Already started elsewhere

Toy certification stuck on the age grading or a retest?

The most expensive stop is the age grading. A toy graded above 36 months to skip the small-parts test, with packaging imagery that says otherwise, is assessed at the lower grade and the file fails. Retests follow a change of pigment, plasticiser or supplier that nobody mapped against the reports. Other files were built on an EN 71 report alone and then met ASTM F963 in the US or a Eurasian body that tests its own samples.

An EN 71 report stays useful as technical evidence for TR CU 008/2011, which points to GOST adoptions of EN 71 and ISO 8124, and it is the starting evidence for both G-Mark types. As a Eurasian submission it does not carry: the documents go in Russian and the applicant is registered in a member state. The restricted lists move too, so a file compliant three years ago may not be now.

What to send us

Everything here is something to find before the project starts. The first reply says which of it can go into the file as it is.

  • The age grading, with the packaging artwork and marketing copy behind it
  • EN 71, ASTM F963 or other test reports, with the laboratory named
  • The bill of materials, and any pigment, plasticiser or supplier change since testing
  • Destination markets, and for the EAEU, the applicant registered in a member state

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  • 2010 Year of foundation
  • 1300+ Certification projects
  • 40+ Countries served
  • 15+ Types of certificates

Who decides the age grading, and can it be challenged?

You decide it, and it has to match how the product is presented: packaging imagery, marketing copy, size and play pattern. A toy or a detachable part that fits the small-parts cylinder is a choking hazard for under-threes, and a toy for older children that still carries that hazard must bear the warning "Not suitable for children under 36 months" with the reason stated. A regulator that finds a product obviously appealing to a younger child applies the stricter set regardless of the label, and so should you where a product spans ages.

Which parts of EN 71 apply to my toy?

EN 71 is a series. Part 1 covers mechanical and physical properties: small parts, sharp points and edges, cords, projectiles, and the warnings. Part 2 covers flammability. Part 3 covers migration of 19 elements, lead, cadmium, chromium VI and aluminium among them, with separate limits for Category I dry materials, Category II liquid or sticky materials and Category III scraped-off materials such as paint and plastic. Further parts cover chemistry sets, finger paints and electrical toys.

The Toy Safety Directive 2009/48/EC sits above the standards and carries what they do not: the CE mark, an EU declaration of conformity, a safety assessment in a technical file kept for ten years, traceability marking with the manufacturer's name and address and a type or batch number, and warnings in the language of each market of sale. The Toy Safety Regulation adopted in 2025 replaces the Directive after a transition period and adds a digital product passport.

What does the US require for toys?

ASTM F963 is the mandatory toy standard under CPSIA section 106, and CPSIA adds its own limits: 100 ppm total lead in any accessible part, 90 ppm lead in paint, and 0.1 % for each of eight phthalates under 16 CFR 1307. Testing must be done by a CPSC-accepted third-party laboratory, the importer or manufacturer issues a Children's Product Certificate, and the toy carries a tracking label. An EN 71 report does not substitute for F963, although the two overlap in most of the mechanical tests.

Toys or children's goods: which Eurasian regulation applies?

TR CU 008/2011 covers toys, 21 positions, and takes them through certification: an accredited body, its own samples, and for series certification under scheme 1c an inspection of production. TR CU 007/2011 covers products for children and adolescents, 42 positions from clothing and footwear to prams, feeding bottles and school supplies, split between certification and declaration by position. Children's furniture sits under TR CU 025/2012 instead. A soft toy is 008; a baby carrier is 007; a cot is 025. Each file is different.

The technical content overlaps with EN 71, since TR CU 008/2011 points to GOST adoptions of EN 71 and ISO 8124. The paperwork goes in Russian, the applicant must be registered in a member state, and the scheme decides whether the certificate covers a series or one consignment.

How does the G-Mark treat toys?

In the Gulf, toys are one of the two product groups under the G-Mark. The GSO toy technical regulation splits them into Type 1, self-declared against a technical file, and Type 3, where a GSO notified body issues the certificate; which type applies depends on the toy category the regulation lists. Both rest on the GSO adoptions of the EN 71 series, so an EN 71 report is the starting evidence either way.

Where does retesting come from?

Chemistry. Migration limits apply per material, so a change of pigment, plasticiser or supplier invalidates a report even when the product looks identical, and the restricted lists move: a file that was compliant three years ago may not be now. Where a range shares a few base materials, test those materials once and map them across the range. It works only if the bill of materials is accurate at the point of testing.

Toys by market

MarketLegal basisStandardDocumentThird party
European UnionToy Safety Directive 2009/48/EC; Regulation adopted in 2025 to followEN 71-1, -2, -3EU declaration of conformity, CE markNotified body only without a harmonised standard
United StatesCPSIAASTM F963; 16 CFR 1307 for phthalatesChildren's Product Certificate, tracking labelCPSC-accepted laboratory, always
Eurasian Economic Union, toysTR CU 008/2011 (21 positions)GOST adoptions of EN 71 and ISO 8124EAC certificateAccredited body; production inspection under scheme 1c
Eurasian Economic Union, children's goodsTR CU 007/2011 (42 positions); furniture under TR CU 025/2012By positionCertificate or declaration by positionDepends on position
Gulf statesGSO toy technical regulation, G-MarkGSO EN 71 seriesG-Mark certificateGSO notified body for Type 3

Frequently asked questions

Can we grade a toy for over-threes to avoid the small parts test?

Only if the grading is defensible. Market surveillance assesses how the product is presented and how a child would use it. A grading contradicted by the packaging imagery is treated as the lower grade, and the file then fails against the requirements that apply.

Does an EN 71 report work for the Eurasian Union?

As technical evidence it carries, because TR CU 008/2011 points to GOST adoptions of EN 71 and ISO 8124. As a submission it does not: the accredited body tests its own samples, the documents go in Russian, and the applicant is registered in a member state. Nor does EN 71 replace ASTM F963 in the US; the tests overlap but the reports are not interchangeable.

Do we retest when we change a supplier?

For anything affecting the material, yes. EN 71-3 migration limits and EN 71-2 flammability are properties of the material, so a new pigment or plasticiser can invalidate an otherwise current report even when nothing visible has changed. Update the bill of materials first and map the change against the test reports before deciding what to rerun.

Is a children's product the same as a toy?

Only if it is designed for play. A pram, a feeding bottle or a school bag is a children's product under TR CU 007/2011, a cot is furniture under TR CU 025/2012, and a soft toy is a toy under TR CU 008/2011. In the US, CPSIA applies to every product designed for children twelve and under, while ASTM F963 applies only to toys.

Keep reading

On children's goods

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