When you buy a toy do you check for a CE mark? Do you know what the CE mark stands for? One of my proudest achievements as a craft business is completing the CE certification of my first collection of handmade wooden toys. Never mind testing the toys, going through the process really tested me. I’d like to share that experience with you.
All toys sold in the UK must legally comply with the Toys (Safety) Regulations 2011. These Directives apply equally to the big toy manufacturers and small scale makers like me.
However, finding out how to comply isn’t straightforward. An email to my local trading standards office produced a reply saying yes, I needed to comply and a link to a guidance page telling me broadly what documentation was required but not how to go about it.
I was left scratching my head for a few months until I had a conversation with a member of my local craft group who told me about a Facebook support group for people who wanted to certify their toys themselves.
I joined the group and started to learn about the world of self certification. It was a steep learning curve and I can never thank the members of that group, and the one I joined later specifically for wooden toys, for their help, advice and support during the whole process.
The Facebook group led me to the CE Marking Handmade Toys Collective website. I joined the collective and was able to download a clearly written CE marking guide which helped me decifer the legal documentation I’d been reading so far.
I learned I had to comply to EU Toy Safety Directives 2009/48/EC, harmonised standards and EN71. The relevant EN71 standards for wooden toys are EN71-1: Mechanical and Physical Properties and EN71-3: Migration of Certain Elements. You can self-certify EN71-1 but you need laboratory test results for EN71-3.
EN71-3 means ensuring and proving the materials and components you use don’t contain any of the toxic metals listed above the required threshold levels. I was able to obtain the relevant certificates of compliance from the manufacturers of the paints and finishes I use. For the wood there was no option but to send a sample of each away to be tested in a lab. This might seem a bit ridiculous. Is wood likely to contain chromium? However, you aren’t allowed to make that judgement. You must have proof.
With natural materials, like wood, the material is not as controllable as a man made material, like plastic, however, I’m not able to have every wood delivery tested due to expense. A lot of the compliance relies on the maker showing ‘due diligence’. Basically, I decide when I need to get my wood retested, for example if I change my supplier.
Proving compliance to EN71-1:Mechanical and Physical Properties involves performing a series of physical tests in a specific order. It took a while to source items like ‘a 4 mm thick steel plate with a 2 mm thick coating of Shore A hardness (75 ± 5)’ as well as ‘a metallic weight with a mass of (1 ± 0,02) kg, distributed over an area with a diameter of (80 ± 2) mm’. These are direct quotes from the documentation which did take time to unpick and work out. I also had to some make test rigs and templates.
Below is the video evidence taken of testing the Gnosi Wooden Rattle. They’re listed in test order. There was also a decibel test, a soak test, a sharp edges test and a small parts test.
Once testing was complete I moved onto labelling and tracability. There are as many requirements to meet for this as for testing, so it took a while to come up with a solution that met the requirements but also satisfied my own Eco friendly criteria.
Legally, at point of sale, toys must be labelled with:
- the CE mark, at no less than 5mm in height.
- Manufacturer / company business name
- Traceable manufacturer’s address
- Model / batch number
Required in relation to traceability, so if the toy itself is customised or named specifically and recognisable as an individual unit.
- Relevant warnings if applicable
- Care instructions
To reduce waste and for practicality I decided to brand the CE mark directly onto my toys (see featured image at the top of the page). Branding also means the CE mark’ll still be there if the toy’s passed on. The rest of the required information is printed onto the cotton bags that my toys come in. I decided to package my toys in reusable bags instead of cardboard boxes as this reduces waste and they can be used to keep the toys clean and safe for years to come. For the toys too small to be branded, I’ve designed a tag, printed on recycled card, with all the relevant information, including the CE mark.
Once this was done I compiled all my evidence and documentation into a technical file. This is a live document which means any changes to the design, the making process or the materials must be documented in it. The technical file contains:
- A Full Product Description
- Claim of Compliance
- Manufacturing Location & Storage
- Product & Packaging – Product images, description and packaging, including images.
- Materials and Components – Outline all materials and components used in all variations of your toy.
- Manufacturing Process – Outline your manufacturing process, step by step.
- Show your Labelling & Traceability
- Testing Checklists & Photographic Evidence
- EN71-3 Test Results & Evidence
- Declaration of Conformity
Oh yes, and each toy must have it’s own technical file. Phew!
If you’re still reading, you can now see why I’m so proud of myself. I deciphered the legal jargon, figured out what tests were needed, paid for chemical analysis, creating test apparatus, conducting the tests and creating a mountain of paperwork.
It’s not surprising given all of that time, effort and expense, that a huge amount of wooden toys being sold are not CE marked. So why bother you might ask?
As well as the fact that it is a legal requirement I want to prove that my toys are completely safe. The thought of selling potentially dangerous toys to babies and small children is not one I care to entertain.
Although the self certification process is complex and needs to be completed for each new toy or change in design, it gives me total confidence in the safety of my toys. That for me as a mother and a toy maker is the most important thing.
If you are looking to CE mark your toys please visit the Handmade Toy Collective’s website for further help and guidance.