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EN 71 & Toy Safety When Importing from China

EN 71 Toy Safety Directive

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As a child, I was afraid of dolls (also known as Pediophobia). While those pieces of plastic don’t scare me much these days, the influx of toxic and otherwise dangerous (and sometimes lethal) toys does. Luckily, there are strict regulations in place all over the world. In this week’s article, we introduce you to the European Union Toy Safety Directive – EN 71.

What is EN 71?

EN71 is a set of European Product Safety standard that applies to all toys sold in the European Union. EN 71, which is also a part of the CE directive, has been put in place to ensure that all toys sold in the EU meet certain minimum safety standards on the following factors:

Product safety is always a big deal, but even more so when it regards products that are (exclusively or not) used by children. In order to make things a bit more complicated, the EN 71 directive is not made up of only one part, but thirteen:

  • 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 labelling
  • 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

The number of EN 71 parts that apply to a certain product depends on the products nature. Click here for a more detailed description of each part.

Is EN 71 compliance mandatory when importing toys to the European Union?

Yes. Whether the product is imported from China, or manufactured within Europe, makes no difference. It’s still a legal requirement. However, sometimes it’s hard to determine whether a product is considered as a toy. The most common definition is that any product for use in play and intended for children under 14 years, shall be classified as a toy – and is therefore required to be EN 71 compliant.

The importer responsibilities are listed below. However, these are regulations that might change tomorrow. Always contact your local authorities before ordering toys from a Chinese supplier.

  • Ensure that the supplier is compliant with the EN 71 directive. You can read more about what this means here
  • Ensure that your company name and address is printed on the product or its packaging
  • Ensure that the EN 71 compliance is not affected by the storage or transportation of the product
  • Ensure that samples of each batch are being lab tested
  • Keep a register of product related complaints
  • Inform the local authorities of any non-compliance
  • Keep a copy of any related documents (such as certificates of compliance) for a minimum of 10 years
  • Ensure that the products bears the CE mark (may also be printed on the product packing in case the product is not suitable for printing)
  • Ensure that the product is accompanied by a user instruction manual

Most Chinese toy manufacturers are not EN 71 compliant!

Far from all Chinese manufacturers are compliant with EN 71. Prior to writing this post, I did some research on how many Chinese suppliers market their products as EN 71 compliant, on B2B websites such as Alibaba.com. The result is quite scary. Less than 12% of the suppliers market products as EN 71 compliant. Since we didn’t verify the compliance of these suppliers, this figure also includes fake and expired certificates. The actual EN 71 compliance rate might be as low as 3 – 5%.

Does this mean that the European market is flooded with non-compliant, and thus potentially dangerous toys? The answer is yes, and no. Noncompliant toys are present on the EU market, and there has been a number of forced withdrawals in recent years. Especially after the introduction of the latest EN 71 directories in 2011.

However, there’s a reason the compliance rate is low among Chinese manufacturers. Most of them are NOT exporting to the European Union at all. Mainly because manufacturing EN 71 compliant products require a certain degree of sophistication. Compliance requires a tight grip on the subcontractors and extensive testing of incoming components and materials. These quality management systems are expensive to put in place. Besides, EN 71 compliance is an EU standard and thus not a legal requirement in China.

The only reason for a supplier to ensure EN 71 compliance is if they are exporting toys to the EU. Broadly speaking, it’s only the top 5% of the Chinese toy manufacturers that are able to comply with the EN 71 toy safety directives. Yet, non-compliant suppliers in China are still more than willing to sell their products to European buyers.

Keep in mind that the importer (be it a company entity or an individual) is legally responsible for ensuring compliance with the relevant EN 71 directive. This responsibility can never be shifted to the Chinese supplier. Importing toys or other children’s products that are not in compliance with the applicable EN 71 directive is illegal and may result in a forced recall or serious fines.

It’s critical that you only deal with suppliers able to show previous compliance. Sounds complicated? We can help. When you order a Starter Package right here on Chinaimportal.com, we help you confirm which directive apply to your product – and source suppliers able to show previous compliance with EN 71. Click here to watch a demonstration video.

How can we ensure compliance with EN 71?

This is a two step process. To begin with, you shall never even think about purchasing toys from a supplier that cannot prove previous compliance with EN 71. No promise in the world (and especially not one made by a Chinese supplier) compares to extensive proof of previous compliance. This means that a supplier shall be able to produce a large number of compliance certificates and product test reports from previous batches.

One or two such documents are not enough. Working with suppliers that have produced only one or two EN 71 compliant batches is too much of a risk. Compliance must be part of the supplier quality management process, and its engineers shall understand the EN 71 directive inside out.

The 2nd step is ensuring that your products are compliant. Previous EN 71 compliance is not enough. This might sound strange at first, but manufacturing is not a science. In fact, it’s a fragile process and even Toyota mess things up from time to time. That’s why lab testing of each batch is mandatory when importing toys from China. This doesn’t mean that every single unit shall be lab tested, but at least a few.

There are several companies that do EN 71 compliance testing. Among them are SGS, Bureau Veritas (read their white paper on EN 71 here) and TÜV. All of these companies are present in China and can test your products before they are shipped to the Port of Destination.

What can happen if my products are non-compliant?

Authorities in the EU don’t negotiate with importers of non-compliant toys. EN 71 compliance is always mandatory. Selling such products will always result in a forced withdrawal from the market – or a lawsuit, in case anyone is injured by your products. Neither is the EU compensating importers of non-compliant products, even if the Chinese supplier caused the problem.

Keep in mind that the EN 71 directive is frequently updated. New chemicals are continuously restricted. This article may become outdated with short notice. However, I can assure you that the requirements are not going to be relaxed anytime soon (and for very good reasons).

Do you need help to ensure compliance with all mandatory safety standards?

We know how hard it can be to get a grip on product safety standards, labeling, documents and lab testing. To help startups get a grip on the process, and avoid crippling fines and forced product recalls – we created the Starter Package:

a. An overview of product safety standards in the United States, Europe, Australia & more

b. Mandatory document sample files

c. Product labeling template files

d. Checklists that guide you step-by-step through the entire compliance process

In addition, you can also book quality inspections, lab testing and shipping directly from the platform. Click here to learn more.

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    25 Responses to “EN 71 & Toy Safety When Importing from China”

    1. gope September 6, 2014 at 10:10 am #

      greetings,
      my friend bought some toys from yiwu and guangdong,
      they gave him en 71 cetificate copy,
      however the spain authorities asking for ce certificate,
      what is the meaning of that,
      thanks,
      regards,
      gope

      • Fredrik Grönkvist September 7, 2014 at 6:17 pm #

        Hello Gope,

        EN71 is part of the CE directive. Where you asked by the Spanish customs to present these documents, or by another government body?

      • Annie September 28, 2015 at 8:20 am #

        Dear gope,
        My name is Annie ,from China’s leading test and inspection lab named CTI,very nice to answer your this question.

        CE certificate is like a declaration of conformity ,it declears the goods has passes some test or meet some standard.Different products has different standard to get a CE certificate.

        For toy,if the toy has passed the test of EN71 part1,part2,part3,then the test lab can give you a CE certificate.As your friend has got a en 71 cetificate copy,it means the toy can meet CE standard,you can explain to the authorities,or turn to the lab for a CE.

    2. Izzie March 4, 2015 at 2:50 pm #

      Hi. Is there anywhere where I can get a copy of the EN71 for free? Thanks.

      • Fredrik Grönkvist March 4, 2015 at 3:55 pm #

        Hello Izzie,

        There’s plenty of information about EN 71 on various EU websites, such as this one: http://ec.europa.eu/growth/single-market/european-standards/harmonised-standards/toys/index_en.htm

        • Izzie March 11, 2015 at 10:57 am #

          Thank you Fredrik!

        • Ivo July 8, 2015 at 1:18 pm #

          Hi,

          The link provided is great source of new information and I also find another one:
          http://ec.europa.eu/growth/sectors/toys/placing-on-eu-market/index_en.htm

          That link however, does not mention EN71 but only talks about CE markings on the product. I have a producer who claims to have these certificates: EN71, 6P, CPSIA, CD. I bought their product on eBay and they don’t have any such text printed on the original packaging, only the CCC mark.

          I cannot get definite answer on wether I can sell such toys in European Union or not. Would you be able to shed some more light on the subject?

          Thank you!

          • Fredrik Grönkvist July 8, 2015 at 1:25 pm #

            Hi Ivo,

            No, if it’s only CCC marked then it’s made for the domestic Chinese market. That is, very often, the case for products sold in small volumes online. Simply printing a CE mark isn’t enough. The product must also be certified (e.g. a Declaration of Conformity, with the relevant attachments, including a technical file and test reports).

            • Ivo July 8, 2015 at 1:34 pm #

              That would be my guess as well and all I want is to find where exactly is that written in paper. Full response from manufacturer is:

              “We have EN71,6P,CPSIA,CD test report. It can be sold in Eastern Europe. If in Western European,some customer can sell,some cannot. But in Eastern and Southern part,no problem.”

              Kind of dubious answer, unless it is meant EU vs. non-EU (e.g. Switzerland).

      • Annie September 28, 2015 at 8:23 am #

        Dear friend ,only the toys have pass the test of EN71 in a test organization or lab,can you get a EN 71 copy.

    3. Nomi April 5, 2015 at 2:45 pm #

      Hello,

      Is it possible to give me the top 5 toy manufacturing companies that also trade with South Africa. We want to choose a company that will manufacture the toys for us and also ensuring that they meet all the quality standards in South Africa.

    4. neha July 21, 2015 at 6:27 am #

      hi
      i want to know the rules and regulations for importing toys and kids apparel from china in india.
      also the maufacturers talk about the license and the marketing rights…can u please throw some light on these in india for toys n clothing.
      i am an eneterprenuer with a start up with import and export code.
      Thanks
      neha.

    5. Badar December 24, 2015 at 12:26 am #

      Tja Fredrik,

      Quick question here!
      Am I to understand it correct that if a product has a CE mark on it, then it also includes a EN-71. I want to customize PVC pipes into a children toy manufactured from China. The supplier has CE certification. Would that be enough documentation for me to put on the package of the product?

    6. Shimmy mitt August 4, 2016 at 5:01 am #

      Gretat Article Thanks,
      If the manufacturer have a En71 is there something i as a importer need to do?
      And which Company name and address need to be printed, importer? Or manufacturer?
      Thanks

      • ChinaImportal August 8, 2016 at 10:13 am #

        Hi Shimmy,

        As the importer, you must not only provide a Declaration of Conformity, but a Technical file.

        The short answer is therefore no… that is not enough.

    7. Joan February 7, 2017 at 7:10 pm #

      Thank you so much for this helpful information!

      How long is an EN71 test report valid? Do they expire? Also, if a Chinese manufacturer has an EN71 test report, can that be used to verify compliance if the product is sold in the US?

      • ChinaImportal February 12, 2017 at 7:55 am #

        Hi Joan,

        I don’t think the test reports every expire. That said, they are only valid for a specific batch of products.

        And no, EN 71 is not valid in the US. Then again, it can be used to verify previous compliance. A supplier that can make an EN 71 compliant product can also make a CPSIA compliant product, for example.

    8. Kate March 6, 2017 at 4:27 pm #

      Hi, I was wondering about the Pet products – like the dog chew toys or ropes. They do not resemble the children toys and do not require CE certification. Do they still fall within the scope of EN 71? Is they do, why?

      Thank you for your answer in advance!

      • ChinaImportal March 12, 2017 at 11:36 am #

        Hi Kate,

        No, EN 71 is not applicable to pet product

    9. aizat June 5, 2017 at 7:43 am #

      hey
      I wanna send toys from Yiwu to Israel, and i should have EN-71, cause there is so big checking.
      I already bought toys begore, so now i have no idea how these goods will arrive Israel port, and ehat will I show to customers.
      So maybe somebody can help me, give me some contacts of agents, who is working about complete EN-71 Standard the latest edition near Yiwu, Zhejiang province
      thx
      best regards,
      Aizat

    10. Nuno Miguel Serrano Almeida Conceição Carvalho August 18, 2017 at 12:07 am #

      HI,

      I was wondering about the Float pool products. they still fall within the scope of EN 71?
      Thank you for your help information!
      Regards

      • ChinaImportal August 20, 2017 at 12:02 pm #

        Hi Nuno,

        Yes, all toys are within the scope of EN 71

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