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:
- Mechanical
- Noise
- Flame retardance
- Chemical composition
- Electrical Safety
- Sanitation
- Radiation
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.
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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 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.
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).
Hi
We are looking to buy wooden train tracks from china.
They will be made from beech wood and will have no paint varnish or other finish just bare wood.
They will be solid wood so no choking hazards etc.
Would they still need to be tested before I import them as they are EN71 Compliant as per factory and will be their own brand.
If needed can you advise a decent lab for testing before importing.
Thank you in advance
John
Hi John,
Yes you still need to base your conformity assessment on something (not only the supplier’s word). You may not need very extensive lab testing though.
Hi fredrik,I have a few questions you may be able to help me with
Ive had barbie dolls manfactured in China,im making my own clothes for the dolls to sell would I be classed as a importer or a manfacture? Aslo,
Can I use their en71 certificate for the dolls im in the UK
Can I create my own barcodes
Thanks
Hi Chantell,
1. No you need to buy barcodes from GS1 UK
2. No, you cannot use a supplier EN 71 test report. You need to arrange lab testing according to the current British standard (and issue a DoC, technical file, and user manual most likely)
Thanks fredrick,
Would i require barcodes or item code on my products/packaging? Planing to sell online
Hi Chantell,
The product name/model/SKU likely needs to be present on the product and the packaging.
Hello – thanks for this article. Can I find out if EN71 is still applicable to the UK post-brexit? I am looking at importing baby teethers to the UK from China which are EN71 certified. Do I need to pay for further testing? Thank you.
Hi Lulu,
We don’t follow the developments in the UK so I cannot say
china supplier sent me EN71 certified but testing period is two years ago in 2019, oct so do manufacturer needs to test product every years? so many chinese suppliers have a old cerfitication .
Hello Rachael,
I don’t think you can use old test reports for anything other than assessing if the supplier has experience manufacturing products in compliance with the relevant EN 71 standards.
Hi,
I was doing some background reading on the EN71 Safety standards and came across this site, https://ec.europa.eu/docsroom/documents/37686 which shows 4 different types of EN 71-1 for Safety of toys – Part 1: Mechanical and physical properties. May I ask what is the difference between these 4 standards:
EN 71-1:2011+A2:2013
EN 71-1:2011+A3:2014
EN 71-1:2014
EN 71-1:2014+A1:2018
Thank you!
I don’t know the difference between these specific EN 71 standards, but most likely they cover different types of products.
Thanks for the reply Frederik.
If we want to sell our products worldwide (ship to customers and retailers worldwide), is the CE mark enough or do we need to do testing specific to each region?
CE marking is only for the EU. CE marking doesn’t mean your product is compliant with regulations in the United States, Australia, or other countries around the world.
Same standard, different years of publishing. The “A” means Addenda to the published standard.
Hi, are the toy regulations different for all EU countries (ex Germany,UK )
thank you
Hi Zevi,
No, the Toy Safety Directive is applicable in all EU countries
Hi Fredrik,
We are preparing a direct marketing campaign and wish to send a wooden promotional toy to business people across Europe. Can we add disclaimer copy about this is for marketing promotion purpose, Not for Children? Not for resale etc. The Chinese factory has shared a document to say it it is EN71 compliant. But, what’s the onus on us to get the wooden ‘toy’ reviewed and tested here in the UK and do we have to send documentation with the toy?
Hello Steve,
Promotional products are not exempt from safety standards.
Hi Fredrik,
I got EN71 tested for a ODM SKU that I’ve been selling on UK Amazon.
I am about to place my second order from the same manufacturer. Do I need to do EN71 test again? I don’t know if my second order were produced from the same batch as my first order.
Hi Xavier,
That depends. Are you making changes to the design, materials or colors?
How can I declare that my toy is not a toy? and is only for the use of +14 years old?
Thanks
Hello, thank you for this, got question regarding importing frame and specific clay (it’s not a toy). Would I still need for Europe testing? As Far as I understand that their EN 71 test is not enough? So how can I bypass this, because truth is paying additional for test is too costly. Plus it’s not a toy.
Hi Jake,
Is this product used by children at all?
Hi Fredrik,
We are importing 25 toy skus from our parent company based in the US into the UK and had each one EN71 tested and each one passed. The tested items included various colours of polyethylene plastic beads and polystyrene boards. I am now considering expanding the range to include more colours of beads and different shaped boards and the manufacturer has said the process and materials are the same. The question is do i need to have every colour bead and shaped board tested which would be prohibitively expensive? Can I assume compliance of new based on the compliance of old and only test new if i am specifically requested to do so?
Thanks for your assistance.
Jeremy
Hi Jeremey,
I think you will need to get the other colors tested too.
Hello Frederik,
Are there accredited test agencies in China that can test on behalf of a European agency and issue EN71 certificates? Do these agencies also have a notified body number that is approved within Europe? Or when we need to fulfill the EN71 testing, we need to find an agency within Europe?
Thank you in advance for your reply.
Hi MM
I don’t think the testing company has to be a notified body inside the EU. But I am honestly not 100% sure.
Either way, SGS, Bureau Veritas, and Intertek should be able to arrange EN 71 testing.
Is the “country of origin” required on the product or package in order to comply with EN71
Hello Bob,
No, country of origin is not required in the EU, only in the United States. Notice that EN 71 is an EU regulation.
Hi Fredrik how are you??
We are importing a toy from china and we are planning to check and test the product, but we are having issues with the D.O.C Declaration of Conformity, they wont accepted the documents from China
Hi Emzo,
You need a DoC, test report and technical file, all issued in your name.
Who doesn’t accept your DoC?
Hi Fredrik
so we need the EN 71 in our name ?? we can use the manufacturer EN 71 ???
Hi Fredrik and thank you for your time
ok so we need the EN 71 in our name,? we can’t use the manufacturer EN 71?
Correct, you need it in your name, including the test reports.
Hello,
What about accessories?
If you sell an electrcial toy, that comes with a micro USB cable to charge the product, does the cable need to be EN71 certified as well?
Thanks
Hi Steve,
Well, the EN 71 substance restrictions would, in that case, also apply to the cable
Hi Fredrik, is it possible to self certify a painted wooden toy for EN71, parts 1 and 2, and get a third party lab to test only part 3? It could be a good way for getting costs down.
Also, is it a requirement to also test for REACH requirements for the same toy, even though I’ll have met EN71? Total Phthalate and Total Cadmium seem to be coming up….
Thanks, José
Hi José,
1. That should be possible, assuming you have the equipment and expertise to properly test the product and document the process.
2. Yes, REACH is also applicable
Thanks Fredrik, that’s very helpful. How can I find out exactly which REACH to test for, for importing into the UK? Or do I have to test for all?
Hi José.
You don’t need to keep track of the REACH substances. The lab will make that assessment for you.
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
Hi Jo,
That depends. Did you make any changes to the design, colors or materials since the last order?
Hi Fredrik,
I went through the FAQ and I’m still wondering something.
May we consider wooden musical instruments as toys for children ?
Moreover, am I understanding properly, EN71 test report leads to CE mark right ? Meaning that if I have the CE mark, I inherently passed the EN71 test successfully ? In case of control, can I show the declaration of conformity only ?
Thank you
Hi there,
are these musical instruments especially for children? It’s difficult to reply your question without having more details about the product
As for CE mark, it’s pretty much the opposite of what you said: You can only CE mark you product if you are sure that your product is compliant with the CE Toys Safety Directive. I mean, we are talking about chemical and phisical properties; adding a mark doesn’t make the product compliant!
The Declaration of Comformity serves a goal that is similar to the CE mark: it says that the seller/importer deems the product to be compliant. In case of control, you will most likely be asked to show test reports, techical file, and DoC
Take a look here at guide 10: https://ec.europa.eu/growth/sectors/toys/safety/guidance_en
I don’t agree with the classifications but the EU authorities would consider a lot of musical instruments to be toys. Instruments will have great trouble complying with the sound pressure requirements for toys.
Hi Antony,
Thank you for sharing.
I also checked your website. Interesting company you work for.
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
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.
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?
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.
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.
Hi, looking at importing teaching aids from china to Ireland, do they need the required certificates.
Thanks
Ger
Hi Ger,
That depends. If it’s a “toy”, then EN 71 is applicable.
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.
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.
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
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!
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
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.
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
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
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
Hi Aaron,
Yes, EN 71 is applicable to all toys / children’s products in the EU (more or less)
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
Sure. Please send me an email to fredrik@chinaimportal.com and I will send you contact details
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
Hi Nuno,
Yes, all toys are within the scope of EN 71
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
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/
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!
Hi Kate,
No, EN 71 is not applicable to pet product
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?
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.
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
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.
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?
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.
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.
Hi. Is there anywhere where I can get a copy of the EN71 for free? Thanks.
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/
Thank you Fredrik!
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!
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).
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).
Dear friend ,only the toys have pass the test of EN71 in a test organization or lab,can you get a EN 71 copy.
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
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?
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.