Section2 Image

TOY Selling in UK and EU- Things to Understand

If you are planning to import and sell toys in the European Union or the United Kingdom, the following key things need to follow by the importer. They are toy safety standards, documentation, and labeling requirements, including EN 71, CE marking, REACH, RoHS Directive, and electronic toys’ standards

This is applicable for all the categories Toys as follows.

  • Wooden toys
  • Plastic toys
  • Soft toys
  • Educational toys
  • Electronic toys
Vector Image

Detailed Toy Safety Compliance Procedure

STEP 1:

Test your toy in an approved Lab and get EN 71 Certification

The first step in the compliance process is to test your toys as per the EU directive (Based on Toy Safety Directive 2009/48/EC ) or UK Regulation(Toys (Safety) Regulations 2011 (UK). This is often a lab test with the International standards called EN 71 . EN 71 specifies safety requirements for toys. It may also apply to other child-related products available within the European Union and the UK.

EN 71 standards contain 13 sections that cover various aspects of toys and other children’s products, such as physical properties, flammability finger paints, and many more. Furthermore, EN 71 also regulates the use of graphic symbols and another labeling for toys.

EN 71 Parts

Here is an overview of the 13 EN 71 standards:

EN 71-1: Mechanical and physical properties
EN 71-2: Flammability
EN 71-3: Specification for migration of certain elements
EN 71-4: Experimental sets for chemistry and related activities
EN 71-5: Chemical toys (sets) other than experimental sets
EN 71-6: Graphical symbols for age warning labeling
EN 71-7: Finger paints
EN 71-8: Swings, slides, and similar activity toys for indoor and outdoor family domestic use
EN 71-9: Organic chemical compounds – Requirement
EN 71-10: Organic chemical compounds – Sample preparation and extraction
EN 71-11: Organic chemical compounds – Methods of analysis
EN 71-12: N-nitrosamines and N-Nitrosatable Substances
EN 71-13: Olfactory board games, cosmetic kits, and gustative games

For most Toys, more than one EN 71 part will be applicable. Our testing company will assess the product and analyze which all parts need to be tested and certified.

EN 71 Lab Testing

Your toys will be tested with TÜV Rheinland Lab in China. This is one of the popular and accepted labs worldwide and their lab tests are accepted worldwide including Amazon and Walmart. Note that EN 71 test report is critical for importing to the EU and UK and to sell in Amazon and similar marketplaces. Without the proper certificates, your product might not be cleared by customs or banned from Amazon.

EN 71 Testing Cost

We charge a flat fee of £600 for testing one model of your toy. Most of the competitors are not transparent about pricing and they charge high amounts and take a lot of turnaround time. We provide reports within 14 days without any hidden charges.

STEP 2:

Mark your products with CE or UKCA

Every EN 71-compliant product must be CE/UKCA-certified. Manufacturers and importers must issue a Declaration of Conformity (DoC) along with a user’s guide, and an information file. For more information, see below.

CE Marking

UKCA Marking

As previously mentioned, toy products must be branded with the CE/UKCA label to show the conformity of the product. The CE/UKCA logo is required to be permanently attached to the packaging, product, and user’s guide.

CE/UKCA label file

It is your responsibility to ask your supplier to produce the CE/UKCA label file for your toys even if they’re conscious that the product is scheduled to export into the UK or the European Union or the UK. Instead, you must supply a digital CE/UKCA Label file that is with the following format .ai as well as .eps format, with the following information below:

Dimensions
Position
Color
Type of printing
It’s possible to incorporate this CE mark in your product’s user manual and packaging, too.

Download the required CE image files here.

You can download the required UKCA image files here.

STEP 3:

Create EC/EU Declaration of conformity

A Declaration of conformity (DoC) is a contract written by a manufacturer or authorized person that confirms that the product is placed on the market in Great Britain (England, Wales, and Scotland) conforms to applicable UKCA(UK Conformity Assessed) criteria. The UKCA marking came into effect on 1st January 2021 but until 1st January 2023, the products with CE marking also can be sold inside Great Britain. This is the transitioning time given to companies because most of the goods covered by CE are still similar to the UKCA standards.

The circumstances in which you can use self-declaration of conformity for UKCA marking are the same as for CE marking. The manufacturer assumes full responsibility for goods complying with all relevant UKCA rules by drafting and signing the Declaration of Conformity. To confirm that the Declaration of Conformity meets all necessary standards, you should review applicable legislation. You must use the UKCA marking from 1 January 2023.

You can still use the CE marking until then. But it’s a good idea to have the UK Declaration of conformity for all the products as soon as possible.

At the very least, the DoC should include the following information:

  • Name and complete business address of the manufacturer or an authorized representative
  • The serial number, model, or even another unique product identifier of the product
  • Declare that the new buyer or manufacturer accepts ultimate responsibility for the proclamation
  • Product identification methods that allow for traceability
  • The legal requirements that the product complies with, as well as any harmonized standards or other techniques used to demonstrate conformity
  • Details of the competent authority (name and number) that carried out the conformance assessment process, when applicable, and references to issued certificates
  • Name, Signature, and Signing Position
  • The declaration’s issuance date

When asked, the DoC should be delivered in a non-editable format (for example, PDF) and acknowledged by an authorized manufacturing employee (containing the employee’s printed name and position).

STEP 4:

Create User Manual

A user’s manual is required for toys that are sold in the European Union. The manual for users should contain details such as:

  1. How to set up the product
  2. A summary of the most relevant parts and parts names for the product
  3. Safety Instructions.
  4. Guides for how you can use the product
  5. Instructions on how to recharge or recharge the product
  6. Guidelines on disposing of the item in an eco-safe method

It is possible that there is not enough space to put your CE marks or symbols for your product. In this scenario, it is normal to add this CE symbol in your user’s manual instead.

STEP 5:

Draw a Technical File.

  1. Obligations of Economic Operators

The Toy Safety Directive requires toy makers to prepare the required technical documentation and preserve it for a period of 10 years following the product has been put in the marketplace. Our EU Toy Technical Documentation Services can make sure that your toys are equipped with all the documentation required prior to putting them on the market.

The technical documentation must contain the relevant data used by toy manufacturers to ensure compliance, including:

A detailed description of the design and manufacture, including:

  • Product identification, picture, age grading, copy of the packaging
  • BOM/BOS (Bill of materials and substances used in toys)
  • Material safety data sheets (SDS) on chemicals
  • A safety assessment for each toy
  • A description of the conformity assessment procedure
  • A copy of the EC declaration of conformity (DoC)
  • Test reports
  • Manufacture and storage addresses
  • A copy of the EC type-examination certificate (if applicable)
STEP 6:

Sell the products in retail market and keep the above documents for 10 years.

All done. Now you are all set. Once you have all the required documents you can import your toys to UK/UK and sell them. The Toy Safety Directive requires toy manufacturers to draw up the necessary technical documentation and keep it for 10 years after the toy has been placed on the market.

Steps to make your products Toy Safety Compliant to sell in EU and UK

Vector Image

We've helped 60 products and 30 companies to test their products and get their EN71 certificates for UKCA and CE Markings.

Icon
Icon

Blogs

Icon

Useful Information

What exactly is UKCA Marking?

The UKCA marking is an important signal (but not proof) of such a product’s adherence to British health, security, and environmental guidelines and regulations.

Earlier CE Marking was used inside the UK also when the UK was part of the EU. Following Brexit, the CE designation was changed to UKCA. The UKCA (UK Conformity Assessed) label is a new UK product marking used for items sold in the United Kingdom (England, Wales, and Scotland). It applies to most goods that typically require CE marking, called ‘new approach’ products.

When to use the UKCA marking

You only need to use the new UKCA marking before 1 January 2023 if all of the following apply. Your product:

is for the market in Great Britain

is covered by legislation that requires the UKCA marking

requires a mandatory third-party conformity assessment

conformity assessment has been carried out by a UK conformity assessment body

Amazon Sellers Must Meet UKCA Marking Requirements.
  • All products must entirely comply with national product rules, according to Amazon. This means that in the UK, a wide range of products must be UKCA labeled.
  • All products offered by Amazon’s third-party sellers must meet product safety regulations and labeling laws in each marketplace. As a result, to sell on Amazon’s European marketplaces, products that need UKCA marking in Great Britain must be UKCA marked.

Amazon requires UKCA labeling for products that fall under the purview of one of the “UKCA marking rules.” Here are a couple of such Product areas covered by the UKCA marking.

  • Toy safety
  • Pyrotechnics
  • Recreational craft and personal watercraft
  • Simple pressure vessels
  • Electromagnetic compatibility
  • Non-automatic weighing instruments
  • Measuring instruments
  • Lifts
  • ATEX
  • Radio equipment
  • Pressure equipment
  • Personal protective equipment
  • Gas appliances
  • Machinery
  • Equipment for use outdoors
  • Ecodesign
  • Aerosols
  • Low voltage electrical equipment
  • Restriction of hazardous substances
  • Products covered by the UKCA marking but have some special rules:
  • medical devices
  • rail interoperability
  • construction products
  • civil explosives
REACH

REACH is applicable to all consumer products, including toys, that are sold within the European Union. REACH sets limits and regulates the use of harmful substances in all consumer products including heavy metals, chemicals, and pollutants. It is unlawful to import and market toys or other items in the European Union that do not conform to REACH.

Here are some examples of substances that are regulated:

Lead

Cadmium

Mercury

Hydrazine

Acrylamide

Substances of Very Great Concern (SVHC)

The European Chemicals Agency (ECHA) introduces new substances to the list of SVHC without a set timetable. Importers aren’t required to check the list regularly. Instead, testing companies from third parties will verify the products in compliance with current regulations for substance use.

Electronic Toys

If you’re considering importing electronic toys, such as remote-controlled automobiles, there are additional safety standards that could be in place for you to consider, such as LVD, EMC, RoHS, and RED. Note that these rules are alongside EN 70 and other regulations discussed in the article.

Low Voltage Directive (LVD)

The LVD is applicable to electronic products which include electronic toys. When your toys are fitted with an input or output voltage that is between 50 and 1000 volts AC and up to 75-150 volts DC then you have to adhere to LVD.

AC Adapters

For AC adapters that have an input voltage of 110 and 240 V as well as an output voltage that is 5V For instance, it is necessary to conform to the AC adapters requirements as stated within the LVD. AC adapters are commonly utilized to power video game consoles, RC toys, as well as other related products.

RoHS Directive

The Restriction of Hazardous Substances Directive (RoHS) regulates the use of certain substances, such as heavy metals in electronic devices. The prohibited substances are:

 

Lead (Pb)

Mercury (Hg)

Cadmium (Cd)

Hexavalent chrome (Cr6+)

PBB stands for Polybrominated Biphenyls. (PBB)

Polybrominated diphenyl ether (PBDE)

Bis(2-Ethylhexyl) the phthalate (DEHP)

Butyl benzyl phthalate (BBP)

Dibutyl phthalate (DBP)

Diisobutyl Phthalate (DIBP)

These prohibited substances can be present in batteries, paint, and other metallic components of toys.

RoHS Components

It is essential to mention RoHS conformity to the supplier before to manufacturing process. The reason for this is they will only be able to utilize RoHS-certified components to make your product.

Radio Equipment Directive (RED)

The Radio Equipment Directive (RED) governs all radio-enabled gadgets, which may comprise certain kinds of electronic toys. If your toys include options like RFID, Wi-Fi, Bluetooth 3G LTE, or 5G compatible devices they also fall under the Radio Equipment Directive.

Devices

Wi-Fi enabled toys

Bluetooth-enabled toys

3G-enabled toys

4G/LTE-enabled toys

5G-enabled toys

Toys equipped with RFID devices

Amazon Europe Toy Safety Requirements

Toys must comply with all the mandatory directives on products as well as certification and labeling specifications to sell on Amazon.

We suggest that you study the specifications for the appropriate toy on Amazon Seller Central before importing them into the European Union.

How do Amazon verify the compliance of toys?

Amazon could demand EN 70 test reports, Declaration of Conformity, or even photos to be reviewed. If you don’t have an acceptable EN 71 test reports and DoC it is likely that Amazon could suspend your current listings or refuse to accept the creation of a new listing. Furthermore, Amazon generally also requires that test reports and DoC are owned by the same entity that is selling on their marketplace, not a manufacturer or different importer.

What happens If we make toys that aren’t compliant on Amazon?

Amazon can take your listings off Amazon when you cannot prove that you are in compliance (e.g. by sending documents such as an EN 71 test report and DoC). They may even deactivate accounts if they consider that action to be necessary.

The selling of goods to customers in Great Britain requires UKCA from 1 January 2023.

The UKCA marking is applicable to all items that were previously subject to CE marking. It is also applicable to aerosols that had previously required the reverse epsilon marking. It is important to note that the technical specifications (‘essential necessities’) you must meet and the conformity evaluation procedures and standards that could be used to show conformity are mostly identical to those used in the case of those who have the CE marking.

The conditions under the circumstances where you can self-declare of conformity to UKCA marking are exactly similar to the CE marking. If you could self-declare conformity to CE marking, then the same can be done for CE marking, you’ll be in a position to do similar with respect to UKCA marking. UKCA marking.

It is mandatory to utilize the UKCA marking as of January 1, 2023. You are able to utilize the CE mark until that date. The CE mark is only valid for Great Britain for areas where GB and EU rules are the same. If the EU modifies the rules it applies to and then the product you CE stamp your products in accordance with the new rules of those rules, you won’t be permitted to apply the CE marking to sell it in Great Britain, even before the 31st December of 2022.

Designated Standards

Specific standards help manufacturers prove that their products, services, or processes are in compliance with GB law. If they adhere to specified standards, companies may claim “presumption” that their products are in conformity (which can be countered by proof) in accordance with the relevant essential standards. These standards cannot take the place of the primary requirements and the manufacturers are responsible to ensure that the applicable GB law is adhered to.

The term “designated standard” refers to a normative created by consensus that is recognized by the authorities in whole or in whole by publishing its information to GOV. The UK with a formal announcement of publication.

The prefixes for designated standards are “BS”, “EN”, “EN ISO”, or “EN IEC”. “EN” or “EN” prefix signifies that the standard was adopted by an international European body for standardization.