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Your regular update for technical and industry information

EU: European Commission Published New Toy Guidance Document for Decorative Products


The new guidance document No. 20 for decorative products and collectibles1 was published by the European Commission (EC) on 17 May 2021. It helps to differentiate between toys and non-toys by providing indicative criteria with various examples on the correct classification of a product before placing it on the market on a case-by-case basis.

The declaration by the manufacturer of the intended use is one of the criteria to be considered. However, the reasonably foreseeable use should prevail over the declaration of intended use by the manufacturer. If the manufacturer marks products with “This is not a toy”, he or she must be able to support this claim and reflect it in the technical documentation. The EC also advises making use of other guidelines on grey zone products and age determination to facilitate the decision making. 

According to the guidance document, decorative products can be divided into two categories: 

  • Decorative products which are toys with dual functions; or
  • Decorative products which are not toys but can be confused with toys.
In the case of child appealing decorative products, the standards for toys could be used to ensure their safety in the absence of specific standards for these products.


For collectables, they are not usually considered as toys, provided that the product or its packaging bears a clear indication that it is intended for collectors of 14 years of age and above. However, they could be considered as toys if they meet the criteria provided in this guidance document.


Summary for product classification:


Product categories
Criteria for classification
Examples of toy 
Toy Non-toy
Dolls, animals, figures
  • 3D shaped
  • (Partly) soft filled
  • (Partly) for cuddling
  • Easy to handle
  • Product is completely or mainly made of hard and easily breakable material (e.g. porcelain, glass)
  • Low play value
  • 2D shaped
  • Not easy to handle due to the weight, the dimensions, or a combination thereof
  • Soft filled toy (e.g. napkin holder, audio speaker); 
  • Soft toy filled with sand.
Products for interior decoration
  • Play value
  • Removable/reusable: intended to be put on and taken off by children
  • Permanent fixed to, e.g. wall, bed, door
  • No play value
  • Stickers; 
  • Pillow in animal shape; 
  • Easter art and craft that can be dressed up; 
  • Christmas bear with stocking.
  • Designed for children
  • Movable arms
  • Soft filled
  • Fragile materials, e.g. glass
  • Attractive to adults
  • Relation to the place visited
  • Detailed
  • Plush toys with suction cups
Party novelties for celebrations / parties
  • Play value (similar to disguise costumes)
  • Possible use like similar toys
  • Role play
  • Only for decoration, e.g. garlands fixed on the ceiling/out of children’s reach
  • Crowns and basic hats; 
  • Rollers, whistles, party blowers; 
  • Party masks; 
  • Birthday train with movable wheels; 
  • Balloons in shape of animals or child appealing characters.
Other, various and dual use products
  • 3D shaped
  • Play value
  • 2D shaped
  • No/Low play value
  • 3D magnets and/or puzzles for refrigerator; 
  • Plush or doll attached to a key ring.

Products for adult collectors:

  • Detailed and faithful scale models;
  • Folk dolls, decorative dolls and other similar products
  • Low price
  • Not traditionally dressed / painted
  • Shaped like a toy
  • Made of hard material
  • Fixed on, or provided with, a pedestal.
  • Detailed
  • Traditionally dressed / painted
  • High price
  • Place of selling
  • Limited number edition
  • Numbered, certificate of authenticity, display packaging (packaging serves as a display)
  • Sophisticated and elaborated dress clothes
  • Dollhouse furniture for children to play with; 
  • Doll with removable clothes and movable limbs, which are sold at low price and are mass produced.


[1]  No. 20 – Guidance document for decorative products


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