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The new guidance document No. 191 for soother holders was published by the European Commission (EC) on 26 September 2019. It helps differentiating between toy and non-toy soother holders by providing indicative criteria with various examples.
Being commonly used for newborns, infants and toddlers, many soother holders are designed in such a way that they also have a play value. Instead of falling into the scope of the General Product Safety Directive (GPSD), such soother holders are within the scope of the Toy Safety Directive (TSD) as they are considered as “soother holders and toys at the same time”.
Safety standard EN 125862 defines soother holder as “article that enables a soother to be secured to a child’s garment etc.”. Besides child’s garment, there are also soother holders that are intended to be fastened to other objects such as cloths and plush toys. Soother holders that are also classified as toys have to fulfil the requirements of the TSD and comply with the toy standard EN 71 series. Both toy and non-toy soother holders must be safe for children from the first month of life (“0 M+”).
Summary for product classification
Soother holders intended to be fastened to garment
Coloured simple beads of uniform shapes;
Coloured simple shaped elements (e.g. moon, stars, hearts);
Components with child appealing printed images but provide no/low play value;
Small and hard animal-shaped fastener.
Plush (soft-filled) toy fastener;
With intended interaction (e.g. movable beads and rings);
Highly varying shaped elements (e.g. cars, flowers) in strap with beads;
With rattle effect;
3D figurine (e.g. animal, child) built of various elements;
With an attached plush (soft-filled) toy / wooden toy;
With possibility to change to teether toy if sold as combined product with teether part.
Soother holders NOT intended to be fastened to garment
Simple cloth without child appealing elements;
Mainly 2D cloth with child appealing elements.
With 3D plush toy.
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