EU Toy Safety Product safety training for buyers and sourcing professionals Shanghai, Guangzhou and Shunde August-September 2014. Katleen HENDRIX European Commission, Directorate-General Enterprise and Industry Internal Market and its International Dimension.
European Commission, Directorate-General Enterprise and Industry
Internal Market and its International Dimension
A toy is a product:
according to the Toy Safety
Some products are not toys
Some toys are not covered by the Toy Safety Directive
=> Standards are notmandatory in the EU!
= swallowing or inhalation
of small parts
cf the "small parts cylinder"
Small parts are banned:
Guidance on "whichcanbeplaced in the mouth" availablehttp://ec.europa.eu/enterprise/sectors/toys/documents/guidance/index_en.htm
Q&A http://echa.europa.eu/support/qas-support/qas select "Restrictions"
Product developed, produced and sold entirely within the EU.
Product developed and sold within the EU by an EU Operator, but
Developed & Domestic
produced outside the EU.
Unaltered product developed by a supplier, then sold within the
3rd Party & Domestic (
EU by an EU Operator
Supplier product specifically modified (see point 3 below) for or by
3rd Party & Domestic (
an EU Operator and sold within the EU.
Developed product (by a Non-EU Operator) sold outside of the
Direct Import / FOB
EU for Direct Import by an EU Operator.
Developed product (by EU Operator) sold outside of
Direct Import/FOB - manufacturer is
the EU for Direct Import by an EU Operator. *5
an EU entity
Developed product (by EU or Non-EU Operator) sold outside of
the EU by an EU or Non-EU sales agent, for Direct Import by an
3rd Party (Sales Commission) FOB
Product sold by a contracted representative of a Non-EU
Operator to hold (but not draw up) Technical File.
Representative in EU
Product developed exclusively for EU retailer and bought outside
Retailer own Brand Product
the EU.What type of economic operator am I / is the entity for which I am sourcing?
TSD explanatory guidance document Rev 1.7 at http://ec.europa.eu/enterprise/sectors/toys/documents/guidance/index_en.htm , p. 137
Each economic operator has different obligations, according to his
role in the supply and distribution chain
Manufacturer (EU or non EU)
Design and manufacture in accordance with therequirements
Importer (only EU)
Place only compliant toys on the EU market
Act with due care in relation to the applicable requirements
An importer or distributor is considered to be a manufacturer if:
level of responsibility
1. Conformity assessment by the manufacturer himself ("self-certification")
Manufacturer: Design and prototyping (continued)Latest publication of references of harmonised standards: OJ C 181, 13.6.2014, p. 1 http://ec.europa.eu/enterprise/policies/european-standards/harmonised-standards/toys/index_en.htm
2. Conformity assessment by a Third Party ("Notified Body")
"EC-typeexamination" => "EC-typeexaminationcertificate"
List of Notified Bodies: http://ec.europa.eu/enterprise/newapproach/nando/index.cfm?fuseaction=directive.notifiedbody&dir_id=140521
If the conformityassessmentprocedure shows that:
Draw up the EC Declaration of Conformity:
Draw up the technical documentation:
The manufacturer must
the Toy Safety Directive
Declaration of Conformity for 10 years
The manufacturer must:
The importer must:
EU toy safety homepage
Text of the ToySafety Directive (includingChineseversion!)
Guidance (including some Chinese versions!)
Amendments of the Toy Safety Directive