• EN 71 & Toy Safety When Importing from China

    Posted on 44 Comments

    EN 71

    Click Here to Get the
    Starter Package: Children’s Products

    EN 71 compliance is mandatory when importing toys to the European Union. Yet, many Importers fail to understand that EN 71 compliance is more complex than a printed CE mark.

    In this article, we explain what EN 71 really is, and what you must do to ensure that your imported toys are compliant. The alternative is not an option.

    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.

    toy safety

    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’

    The Manufacturer is always responsible for ensuring that toys, sold in the EU, are EN 71 compliance. Some Importers take this as a signal that they can simply trust their Chinese supplier to sort this out for them.

    This is absolutely not the case.

    First of all, if your products carry your brand, or are based on your product design, the Importer is automatically defined as the Manufacturer. Hence, the Importer must always take full responsibility for ensuring EN 71 compliance.

    If, however, you Import a Chinese toy brand, which is almost unheard of, then you must still request request test reports and EN 71 documentation from the supplier. That said, it’s very unlikely (less than 0.1%) that the supplier actually have all mandatory test reports and documents.

    Can’t I use a test report provided by my supplier?

    No, you cannot use your suppliers EN 71 test report for the following reasons:

    • The test report must be held by your company, not the supplier
    • The test report is only valid for a specific product. It doesn’t apply to products manufactured at any other time (or other SKU for that matter)
    • Even if you do buy ‘the same product’ as specified on test report, you cannot prove that the two batches are made of the same materials and components

    Market surveillance authorities in the EU know very well how to read and assess a test report. Just showing supplier owned test report is not a shortcut, even if many Importers wish that was the case.

    Further, a test report is not the only thing you will need, as I will explain further down in this article.

    teddy bear

    How do I find compliant suppliers?

    First of all, there are no ‘compliant suppliers’. Compliance can only be achieved on a product level.

    There is no such thing as an EN 71 certificate, valid for a certain company or product facility.

    It’s not your Chinese suppliers responsibility to ensure EN 71 compliance, as they are not experts in this area. Instead, it’s up to you to ensure that the products design, components and materials are compliant with all applicable EN standards.

    This in turn requires that you do a proper review of the EN 71 terms, and apply them.

    That said, you should still inform your supplier that the product must comply with EN 71, and that it will be subject to lab testing before shipment.

    How can we ensure compliance with EN 71?

    Ensuring EN 71 compliance is more complex than just getting a lab test report and be done with it. There are 4 steps involved that each SKU (Product / Model) must go through.

    a. Technical Compliance

    The first step is to assess applicable EN 71 parts. There are, as explained, more than one.

    Not all EN 71 parts apply to all products. Hence, it’s up to you to confirm which parts do apply.

    It’s crucial that you, as an EU toy importer, fully understand the technical requirements specified in all applicable EN 71 parts, as you must verify that the product design and materials are actually compliant.

    b. CE Marking

    Toys sold in the EU must carry the CE mark. You must submit a CE mark file to your supplier, and specify the dimensions, print position and color.

    Notice that additional labeling requirements may also apply.

    c. Documentation

    All products that must carry a CE mark, including toys, must come with the following documentation:

    • Declaration of Conformity
    • User Manual
    • Technical File (i.e., design drawings, bill of materials and other documents)

    You will not get these from your supplier. Instead, you must issue then by yourself – before the goods are placed on the market in the EU.

    As a Toy importer, the authorities will likely require that you present both the Declaration of Conformity and a valid and verifiable test report. This request may come when the goods are being cleared for customs, or several months after you’ve started selling your products.

    In other words, compliance is not just a simple matter of ‘getting your stuff through customs’.

    d. Test Reports

    A test report is used to prove that your product is compliant with EN 71. To obtain one, you must submit a batch sample to an accredited lab testing company (not any testing company will do).

    Once the lab test is done, you will receive a digital document, stating if the product is compliant or not.

    If your product fail EN 71 lab testing, it’s illegal to import and sell the product. Hence, it’s crucial that you understand if the product is technically compliant, before you order a lab test.

    EN 71 lab tests start from around $500, per product. Products made of several colors and materials are more expensive to test, as more material samples are needed.

    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 recall 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 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.

  • We help eCommerce companies import quality products from Asia

    Book Free Consultation
  • 44 Responses to “EN 71 & Toy Safety When Importing from China

    1. gope 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

      1. Fredrik Grönkvist 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?

      2. Annie 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 at 2:50 pm

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

      1. Fredrik Grönkvist at 3:55 pm

        Hello Izzie,

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

        1. Izzie at 10:57 am

          Thank you Fredrik!

        2. Ivo at 1:18 pm

          Hi,

          The link provided is great source of new information and I also find another one:

          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!

          1. Fredrik Grönkvist 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).

            1. Ivo 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).

      2. Annie 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 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 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 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 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

      1. ChinaImportal 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 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?

      1. ChinaImportal 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 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!

      1. ChinaImportal at 11:36 am

        Hi Kate,

        No, EN 71 is not applicable to pet product

    9. aizat 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

      1. ChinaImportal at 5:46 am

        Hi Aizat,

        You need to work directly with a manufacturer, and manage the EN 71 process on your own.

        I don’t think there are any agents that can ensure EN 71 compliance

        You can learn more here: https://www.chinaimportal.com/children-products/

    10. Nuno Miguel Serrano Almeida Conceição Carvalho 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

      1. ChinaImportal at 12:02 pm

        Hi Nuno,

        Yes, all toys are within the scope of EN 71

    11. Aaron at 8:46 am

      Hi Fredrik,

      Do you know if acrylic paint, watercolor paint, colored pencils etc are required to undergo EN71 testing to be able to sell in the UK/EU?

      I’m not sure if these classify as toys.

      Thank you

      1. Fredrik Gronkvist at 11:52 am

        Hi Aaron,

        Yes, EN 71 is applicable to all toys / children’s products in the EU (more or less)

        1. Aaron at 1:02 pm

          Hi Fredrik,

          Thanks for the reply. Do you have any contacts of lawyers who specialize in this type of thing? I currently sell these products online without official tests being done under my current brand name. I am looking for legal advice on what exactly I am required to do by law.
          Thanks again

          1. Fredrik Gronkvist at 5:21 am

            Sure. Please send me an email to fredrik@chinaimportal.com and I will send you contact details

    12. Angie at 4:38 am

      Hello,
      Does anyone have any idea of what certifications are needed for Australia?
      I guess if FN71 is European there is no need for it in Australia. And does the supplier have to provide them all or do you need to take care of it from your end ( if I’m talking for toys for kids 3+ years old)
      Thanks a lot in advance

      1. Fredrik Gronkvist at 7:33 am

        Hi Angie,

        Yes, EN 71 is only for the EU. And no, the supplier will not provide any document. It’s up to the importer to do that.

        You can find more info about Australian children’s product regulations here: https://www.productsafety.gov.au/products/babies-kids/toys

    13. Darrell Yeo at 10:34 am

      Hi Fredrik,

      I would like to know what is the difference between EN71 and EN 1400. I am trying to import silicon jewellery biting toys/teethers from China and sell in the EU. Is it necessary to have both test? Thank you.

      1. Fredrik Gronkvist at 11:44 am

        Hi Darrell,

        EN 71 is applicable to toys / children’s products, while I am not familiar with EN 1400.

        However, I found this:

        In this case, both standards might actually be applicable.

      2. Miles.ding at 7:34 am

        Dear Darrell,
        I could answer you these questions.I am working in TUV-SUD China office,i know these test standard .
        EN 71 is applicable to toys / children’s products.
        EN 1400 is applicable to children pacify.
        Silicon jewellery biting toys/teethers belong to children”s toy product.You only need to test EN 71.

        But I am not sure if the biting toys are pacify.You can send me picture about this product.
        miles.ding@tuv-sud.cn

        Thanks

        1. Fredrik Gronkvist at 12:24 pm

          Hi Miles,

          Thank you for responding to comments here. Let me know if TUV-SUD China is interested in being featured in an interview on our website!

          1. Jean at 11:04 pm

            Hi Frederik i want to ask if my supplier/factory have EN-71 this mean i have CE certification and i can import and sell this toys in Europe ? Or what i should need to do when my factory have EN-71 how i can get CE declaration of conformity for custom house.

            Thanks for your answer

            1. Fredrik Gronkvist at 4:41 am

              Hi Jean,

              A factory cannot be EN 71 certified. It doesn’t work like that.

              Instead, you need to submit your specific product for EN 71 testing.

    14. GER LOWE at 12:05 am

      Hi, looking at importing teaching aids from china to Ireland, do they need the required certificates.

      Thanks
      Ger

      1. Fredrik Gronkvist at 3:48 pm

        Hi Ger,

        That depends. If it’s a “toy”, then EN 71 is applicable.

    15. Matthew at 11:34 pm

      Hi, we are importing our game to the UK from China and plan to have it tested here before it goes to market to make sure it is CE compliant. Do we need to have it tested before it enters the UK? It needs to come to us before it goes to market anyway as we need to repackage it for our kickstarter backers.

      1. Fredrik Gronkvist at 2:20 pm

        Hello Matthew,

        Yes, it should be lab tested before you bring the products to the UK. Not only because the product may be seized by the customs, but because you must verify whether the product is EN 71 compliant BEFORE you pay your factory. If you do testing in the UK, and it turns out to fail, then you have a major problem as you cannot return goods to the supplier in China.

    16. Mark at 11:10 pm

      Hi Fred,

      I’m importing (on behalf of a client) a jar/bottle cap (for food) which is shaped like a character head (a horse and a dinosaur) each head is made from a single piece of plastic and is not designed as a toy but simply a method of closing the top of the jar/bottle it’s attached to, the head hinges open so that the food in the jar/bottle can be poured from it’s mouth. We have tested and approved it for the regulations for “direct food contact” packaging but the client is asking if they need EN17 which I don’t believe they do given this is food packaging and is not designed as a toy and if the bottle has printed on it “This is not a toy” and “Not suitable for children under X years of age”. What are your thoughts please and what age restriction should they put on the label (does it have to be over 14 as given it’s not made of multiple parts I would’ve thought age 5 would possibly be acceptable)? Thanks

      1. Ivan Malloci at 2:00 pm

        Hello Mark,

        generally speaking, a bottle shall not follow into “EN 71”, unless is specifically designed for Children. However, it’s difficult for us to make a full assessment without knowing more details.

      2. Fredrik Gronkvist at 6:47 pm

        Hello Mark,

        I don’t think labeling the product differently will change whether or not EN 71 is applicable in this case. Is this supposed to be sold to children?

    17. Jo Hansen at 11:11 pm

      Hi,

      We had EN71 testing done on a soft toy Feb 2018, if we are re-ordering from same factory, do we need to repeat the testing?

      Thank you

      1. Fredrik Gronkvist at 6:30 pm

        Hi Jo,

        That depends. Did you make any changes to the design, colors or materials since the last order?

    Leave a Reply

    Your email address will not be published. Required fields are marked *

    * Checkbox GDPR is required

    *

    I agree

    [i]
    [i]