EU: European Commission publishes new classification guidance for toys under and over 3 years of age

FEBRUARY 2023 - TOYS AND CHILDREN'S PRODUCTS

The EU Commission and the Expert Group on Toy Safety draw up guidance documents to assist toy companies and enforcement authorities in the interpretation and application of the Toys Safety Directive. The aim is to have a more consistent interpretation of requirements across the EU.

The Commission has recently published an extensive update¹ to Guidance document No. 112 for “toys intended for children under 36 months of age or of 36 months and over”, and now includes a wider range of toy categories. In addition to puzzles, dolls, soft and stuffed toys, there are twelve more categories.

The CEN report CR 14379 "Classification of toys – Guidelines", which was the main background document for the 2009 version of the Guidance document, has been withdrawn in 2016.

CEN ISO/TR 8124-8:2016² “Safety of toys – Part 8: Age determination guidelines” is considered in this updated version.

The product categories and criteria given in the new Guidance document No. 11 are summarised in the table below.

S.N.	Product category	Important criteria in determining the suitability for a particular age category (non-exclusive)	Examples of toys
1	Puzzles	Number of pieces Size of the pieces Theme/details of the drawing Interlocking or loose pieces	Hopscotch game puzzles, puzzles in the shape of a clock, mosaic puzzles, puzzle cubes, 3D animal puzzles.
2	Dolls	Design Level of realism Interaction involvement The accompanying accessories provided	Baby and fashion dolls, backpack with a non-removable doll.
3	Soft and stuffed or partially stuffed toys	Design Weight Level of realism Interaction involvement The motor skills required Any additional features and functions	Squishes, plush, soft toys attached to a key ring, purses, backpacks, trolleys, hair ribbons, snap bracelets, animal-shaped products (e.g., sleeping bags, hot water bottle cover, height gauges, cushions, etc.)
4	Fidget toys	Design Level of realism Bright and contrasting colours Size (easy to grasp or too large to handle) The motor skills required Any additional features and clear game function	Pop-it fidgets in different shapes, bubble board games, stress toy keyrings.
5	Modelling clay/dough, slime, soap bubbles	Easiness to handle Able to mould and knead Reusability Bright and contrasting colours The accompanying accessories provided Can be swallowed easily	Traditional modelling clay, bouncing putty, magnetic clay, and soap bubbles that sold alone and with accessories.
6	Movable/wheeled toys	Design Spinnable wheels Realistic details Proportional to an adult’s vehicle Easiness of grasping and pushing Degree of cause and effect The motor skills required Any additional features and functions	Simple toy cars, remote-controlled cars, battery-operated puppies.
7	Play scenes, constructed models and construction toys	Design Realistic details Number of parts/accessories Level of assembly work Connection system	Detailed/simple designed play scenes, building blocks, construction sets.
8	Game sets and board games	Design Bright and contrasting colours Number of parts/accessories The play duration, rules and/or strategies Number of players The motor skills required	Matching games, dominos, memory games, dice and draw games, fishing games.
9	Toys intended to be entered	Design Size Level of details Realistic activities The accompanying accessories provided Place of use	Tipi, pop-up tents, playhouses, crawling tubes/tunnels.
10	Toys intended to bear the mass of a child	Whether child can stabilise the toy by using feet Whether the toy can be stabilised by itself Number of wheels/legs for balancing Any extra features or designs such as pedals Any extra skill required to have a high level of balance	Balance bikes, riding horses, ride-on toys, bouncy balls.
11	Toy sports equipment and balls	Design Weight Easiness to handle Able to grasp/grip/squeeze Imitation of sports Any games with play rules The motor skills required	Throwing rings game, bowling cone sets, plastic/foam balls, inflatable balls.
12	Hobby horse/stick horse	Design Level of realism Child-appealing colours Strength to handle Size and weight	Different models of hobby horses with bridles/straps and wheels.
13	Push-pull toys and pull along toys	The design complexity Realistic details Imitation devices used by adults Strength to handle Whether to provide stability while learning to walk Any additional features and functions	Lawnmowers, dolls and toys; carriages, toy buggies/strollers, wagons, boats with wheels
14	Audio/visual equipment	The complexity of rhythm or melody or stories Number of buttons to operate The motor skills required Whether to play with brand toy figures or licensed toys	Musical teddy bear, plushie night lights, water toys, storytelling and interactive audio players.
15	Toy figures and other toys	Design Realistic details Level of articulation required Any sophisticated accessories, shooting projectiles The motor skills required	Detailed and simple figures, lids for drinking cups, squishes, kitchen sets, magnetic garden, stacking toys, developmental play cubes.

[1] Guidance document No. 11, dated 1 February 2023

[2] CEN ISO/TR 8124-8:2016

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EU: European Commission publishes new classification guidance for toys under and over 3 years of age

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