CEN/TR 16411:2019

Child care articles - Compiled interpretations of CEN/TC 252 standards

The purpose of this CEN Technical Report is to provide replies to requests for interpretations and clarifications of:
-   EN 1273:2005, Child use and care articles - Baby walking frames - Safety requirements and test methods;
-   EN 1888:2012, Child care articles - Wheeled child conveyances - Safety requirements and test methods;
-   EN 1930:2011, Child use and care articles - Safety barriers - Safety requirements and test methods;
-   EN 12586:2007, Child use and care articles - Soother holder - Safety requirements and test methods;
-   EN 12790:2009, Child use and care articles - Reclined cradles;
-   EN 12221 1:2008, Changing units for domestic use - Part 1: Safety requirements;
-   EN 12221 2:2008, Changing units for domestic use - Part 2: Test methods;
-   EN 1466:2004+A1:2007, Child care articles - Carry cots and stands - Safety requirements and test methods;
-   EN 14350 2:2004, Child use and care articles - Drinking equipment - Part 2: Chemical requirements and tests;
-   EN 1400:2013+A1:2014, Child use and care articles - Soothers for babies and young children;
-   EN 14372:2004, Child use and care articles - Cutlery and feeding utensils - Safety requirements and tests;
-   EN 16120:2012, Child use and care articles - Chair mounted seat;
-   EN 14350-1:2004, Child use and care articles - Drinking equipment - Part 1: General and mechanical requirements and tests;
-   EN 16232:2013, Child use and care articles - Infant swings.

Artikel für Säuglinge und Kleinkinder - Gesammelte Interpretationen der CEN/TC 252-Normen

Articles de puériculture - Compilation des interprétations des normes du CEN/TC 252

Izdelki za otroke - Zbrane interpretacije standardov CEN/TC 252

Namen tega tehničnega poročila CEN je zagotoviti odgovore na zahteve za razlago in pojasnilo naslednjih standardov:
– EN 1273:2005, Izdelki za otroke – Hojce – Varnostne zahteve in preskusne metode;
– EN 1888:2012, Izdelki za otroke – Otroški vozički – Varnostne zahteve in preskusne metode;
– EN 1930:2011, Izdelki za otroke – Varnostne pregrade – Varnostne zahteve in preskusne metode;
– EN 12586:2007, Izdelki za otroke – Držalo dude – Varnostne zahteve in preskusne metode;
– EN 12790:2009, Izdelki za otroke – Sklopne zibelke;
– EN 12221 1:2008, Previjalne mize za domačo uporabo – 1. del: Varnostne zahteve;
– EN 12221 2:2008, Previjalne mize za domačo uporabo – 2. del: Preskusne metode;
– EN 1466:2004+A1:2007, Izdelki za otroke – Prenosne posteljice in podstavki – Varnostne zahteve in preskusne metode;
– EN 14350 2:2004, Izdelki za otroke – Pripomočki za pitje – 2. del: Kemijske zahteve in preskusi;
– EN 1400:2013+A1:2014, Izdelki za otroke – Dude za dojenčke in malčke;
– EN 14372:2004, Izdelki za otroke – Jedilni pribor in posoda za hranjenje – Varnostne zahteve in preskusi;
– EN 16120:2012, Izdelki za otroke – Sedeži, ki se pritrdijo na stol za odrasle;
– EN 14350-1:2004, Izdelki za otroke – Pripomočki za pitje – 1. del: Splošne in mehanske zahteve ter preskusi;
– EN 16232:2013, Izdelki za otroke – Gugalnice za dojenčke.

General Information

• Status: Withdrawn
• Publication Date: 30-Apr-2019
• Withdrawal Date: 13-Apr-2025
• ICS: 97.190 - Equipment for children
• Technical Committee: CEN/TC 252 - Child use and care articles
• Drafting Committee: CEN/TC 252 - Child use and care articles
• Current Stage: 9960 - Withdrawal effective - Withdrawal
• Start Date: 27-Apr-2022
• Completion Date: 14-Apr-2025
• Ref Project: SIST-TP CEN/TR 16411:2019 - Child care articles - Compiled interpretations of CEN/TC 252 standards

Relations

• Replaces: CEN/TR 16411:2014 - Child use and care articles - 2014 compiled interpretations of CEN/TC 252 standards
• Effective Date: 28-Jan-2023
• Replaces: CEN/TR 16411:2014 - Child use and care articles - 2014 compiled interpretations of CEN/TC 252 standards
• Effective Date: 08-May-2019
• Replaced By: CEN/TR 16411:2022 - Child care articles - Compiled interpretations of CEN/TC 252 standards
• Effective Date: 09-Jun-2021

Standards Content (Sample)

SLOVENSKI STANDARD
01-september-2019
Nadomešča:
SIST-TP CEN/TR 16411:2015
Izdelki za otroke - Zbrane interpretacije standardov CEN/TC 252
Child care articles - Compiled interpretations of CEN/TC 252 standards
Articles de puériculture - Compilation des interprétations des normes du CEN/TC 252
Ta slovenski standard je istoveten z: CEN/TR 16411:2019
ICS:
97.190 Otroška oprema Equipment for children
2003-01.Slovenski inštitut za standardizacijo. Razmnoževanje celote ali delov tega standarda ni dovoljeno.

CEN/TR 16411
TECHNICAL REPORT
RAPPORT TECHNIQUE
May 2019
TECHNISCHER BERICHT
ICS 97.190 Supersedes CEN/TR 16411:2014
English Version
Child care articles - Compiled interpretations of CEN/TC
252 standards
Articles de puériculture - Compilation des Artikel für Säuglinge und Kleinkinder - Gesammelte
interprétations des normes du CEN/TC 252 Interpretationen der CEN/TC 252-Normen

This Technical Report was approved by CEN on 8 March 2019. It has been drawn up by the Technical Committee CEN/TC 252.

CEN members are the national standards bodies of Austria, Belgium, Bulgaria, Croatia, Cyprus, Czech Republic, Denmark, Estonia,
Finland, Former Yugoslav Republic of Macedonia, France, Germany, Greece, Hungary, Iceland, Ireland, Italy, Latvia, Lithuania,
Luxembourg, Malta, Netherlands, Norway, Poland, Portugal, Romania, Serbia, Slovakia, Slovenia, Spain, Sweden, Switzerland,
Turkey and United Kingdom.
EUROPEAN COMMITTEE FOR STANDARDIZATION
COMITÉ EUROPÉEN DE NORMALISATION

EUROPÄISCHES KOMITEE FÜR NORMUNG

CEN-CENELEC Management Centre: Rue de la Science 23, B-1040 Brussels
© 2019 CEN All rights of exploitation in any form and by any means reserved Ref. No. CEN/TR 16411:2019 E
worldwide for CEN national Members.

Contents Page
Contents
European foreword . 4
Introduction . 5
1 Scope . 8
2 00252033 – EN 1273:2005, Child use and care articles — Baby walking frames —
Safety requirements and test methods . 9
3 00252059 – EN 1888:2012, Child care articles — Wheeled child conveyances —
Safety requirements and test methods . 11
4 00252051 – EN 1930:2011, Child use and care articles — Safety barriers — Safety
requirements and test methods. 27
5 00252046 – EN 12586:2007, Child use and care articles – Soother holder – Safety
requirements and test methods . 45
6 00252048 – EN 12790:2009, Child use and care articles — Reclined cradles . 63
7 00252049 – EN 12221-1:2008 , Changing units for domestic use — Part 1: Safety
requirements . 68
8 00252050 – EN 12221-2:2008, Changing units for domestic use — Part 2: Test
methods . 71
9 00252054 – EN 1466:2004+A1:2007, Child care articles — Carry cots and stands —
Safety requirements and test methods . 72
10 00252032 – EN 14350-2:2004, Child use and care articles — Drinking equipment —
Part 2: Chemical requirements and tests . 75
11 00252089 – EN 1400:2013+A1:2014, Child use and care articles – Soothers for
babies and young children – Safety requirements and test methods . 77
12 00252024 - EN 14372:2004, Child use and care articles — Cutlery and feeding utensils
— Safety requirements and tests . 99
13 00252065 – EN 16120:2012, Child use and care articles - Chair mounted seat . 102
14 00252023 – EN 14350-1:2004, Child use and care articles - Drinking equipment -
Part 1: General and mechanical requirements and tests . 104
15 00252058 – EN 16232:2013, Child use and care articles – Infant swings . 108
Annex A (informative) Interpretation 3 on 3.9 and 5.1.4.2 in EN 12586:2007, Child use and
care articles — Soother holder — Safety requirements and test methods (WI
00252046) . 111
A.1 Introduction . 111
A.2 Examples of possible ventilation holes in more recent models of soother holders . 112
Annex B (informative) Reply to interpretation 3 on 3.9 and 5.1.4.2 in EN 12586:2007, Child
use and care articles — Soother holder — Safety requirements and test methods (WI
00252046) . 114
Annex C (informative) Reply to interpretation 1 on 5.1.10 in EN 12586:2007 Child use and
care articles — Soother holder — Safety requirements and test methods
(WI 00252046) . 116
C.1 Ventilation holes in fastener (5.1.10) . 116
C.2 Discussion . 116
C.3 Final Interpretation . 121
Bibliography . 122

European foreword
This document (CEN/TR 16411:2019) has been prepared by Technical Committee CEN/TC 252 “Child
care articles”, the secretariat of which is held by AFNOR.
Attention is drawn to the possibility that some of the elements of this document may be the subject of
patent rights. CEN shall not be held responsible for identifying any or all such patent rights.
This document supersedes CEN/TR 16411:2014.
Introduction
This Technical Report contains replies to requests for interpretation and clarifications with regard to
the understanding of clauses in the standards elaborated within the CEN/TC 252. The replies concern
those requests which have resulted in an interpretation or the decision that no action is necessary.
An interpretation does not have the same status as the text of the standard, nor can it overrule the text
of the standard. However, following an interpretation should give assurance that the relevant clause of
the standard has been correctly applied. An interpretation will only be regarded as a clarification of the
meaning of the standard.
a) Disclaimer:
The interpretations and clarifications have been derived by expert groups of CEN/TC 252. The
information contained herein is for guidance only and does not reflect the formal approval by CEN or
CEN member bodies. It should be noted that the interpretations are neither part of any standard nor
have been referenced in the Official Journal of the European Union.
b) Requests for interpretation:
Requests for interpretations may be submitted by a CEN member body through its national committee
or by a CEN/TC 252 liaison (but not directly by an individual or a company) – in accordance with the
interpretation protocols agreed by CEN/TC 252. The requests are then channelled to the relevant
CEN/TC 252 working group which will deal with the request.
A request for an interpretation may lead to:
1) an interpretation of the standard:
this should reflect a reasonable interpretation of how the standard should be used, while taking
into account:
i) the wording of the standard;
ii) the rationale of the standard;
iii) the history of the standard;
2) a no-action decision:
this is applicable when it is agreed that the standard appropriately specifies how a child care article
should be assessed;
3) a proposal for an amendment of the standard:
this is applicable when it is agreed that the standard is deficient in some way.
NOTE Interpretations are published in CEN/TR 16411, which will be updated on a regular basis.
Proposals for amendments will be progressed as new work item proposals in accordance with CEN
rules.
c) Answers to requests for interpretations:
Since requests for interpretations are submitted through a CEN member body, it is assumed that the
member body will keep itself informed about decisions concerning the request and its progress and will
itself inform the originator of the request as appropriate.
1 Scope
The purpose of this CEN Technical Report is to provide replies to requests for interpretations and
clarifications of:
— EN 1273:2005, Child use and care articles — Baby walking frames — Safety requirements and test
methods;
— EN 1888:2012, Child care articles — Wheeled child conveyances — Safety requirements and test
methods;
— EN 1930:2011, Child use and care articles — Safety barriers — Safety requirements and test methods;
— EN 12586:2007, Child use and care articles — Soother holder — Safety requirements and test
methods;
— EN 12790:2009, Child use and care articles — Reclined cradles;
— EN 12221-1:2008, Changing units for domestic use — Part 1: Safety requirements;
— EN 12221-2:2008, Changing units for domestic use — Part 2: Test methods;
— EN 1466:2004+A1:2007, Child care articles — Carry cots and stands — Safety requirements and test
methods;
— EN 14350-2:2004, Child use and care articles — Drinking equipment — Part 2: Chemical
requirements and tests;
— EN 1400:2013+A1:2014, Child use and care articles — Soothers for babies and young children;
— EN 14372:2004, Child use and care articles — Cutlery and feeding utensils — Safety requirements
and tests;
— EN 16120:2012, Child use and care articles — Chair mounted seat;
— EN 14350-1:2004, Child use and care articles — Drinking equipment - Part 1: General and
mechanical requirements and tests;
— EN 16232:2013, Child use and care articles — Infant swings.

2 00252033 – EN 1273:2005, Child use and care articles — Baby walking frames — Safety requirements and test
methods
Table 1 — Summary table of the request for interpretations classified in the order of the clauses/subclauses of EN 1273:2005
Clause/Subclause Title Interpretation n°
6.1.1  1/2013
6.6.2.3  1/2014 (2)
Table 2 — Table of the request for interpretation/clarification for EN 1273:2005
Clause/
Paragraph/
Subclause
N° Figure/ Question Reply
/
Table/Note
Annex
For the tests order shall we follow 6.1.1. but what is the “test order of the
1 6.1.1  standard” ? Is it the order of requirement §5 or order of tests methods §6
?. In one case the §5.9 should be done after §5.14.
Clause/
Paragraph/
Subclause
N° Figure/ Question Reply
/
Table/Note
Annex
In certain designs of baby walking frames (e.g. non-castor wheels in the
back), after the sideways step test in accordance with 6.6.2.3, the product
stops with only one front wheel off the platform and with the rear wheels
almost in the initial position (see picture).
As neither in 6.6.2.3 nor 6.6.3.2 there is
an indication to change the position of
the product from the position where it
has stopped after the test in 6.6.2.3, the
2 6.6.2.3  tip over test in 6.6.3.2 shall be performed

starting from the position in which the
The mirror committee has been made aware of a lab manually moving the
product has stopped after the step test in
product before performing the tip over test in 6.6.3.2 so that one front
6.6.2.3 without changing the position of
wheel and one back wheel will be off the platform.
the product or of its wheels.
Is the intention of the standard to perform the tip over test starting from
the position in which the product has stopped after the step test in 6.6.2.3
(see picture above) or is it correct to move the product between 6.6.2.3
and 6.6.3.2 so that both the front and the rear wheels on one side are
always off the platform?
3 00252059 – EN 1888:2012, Child care articles — Wheeled child conveyances — Safety requirements and test
methods
Table 3 — Summary table of the request for interpretations classified in the order of the clauses/subclauses of EN 1888:2012
Clause/Subclause Title Interpretation
n°
1 Scope 6/2015
3.3 & 3.4 Definitions 12/2015
4.5.1 Protected volume 8/2015
4.5.3 Various requests 2
8.3.1  4/2015
8.3.3 Folding mechanism 13/2016
8.3.3.1.2.4 Locking mechanisms 9, 10 & 11/2015
8.4  17/2018
8.5 Choking and ingestion hazards 14/2017
8.5.2.3 Bite test 16/2017
8;8.1 Parking and braking 15/2017
8.9.1.2.1 Uses of “stop” for parking 3
10.2.6 Marking 7/2015
10.4 Instructions for use 5/2014
Table 4 — Table of the request for interpretation/clarification for EN 1888:2012
Clause/
Subclause
N° Question Reply
/
Annex
No there is no reason for the difference. It’s
just a different wording.
1. There is a difference between the structure of this clause and
The standard makes a clear distinction on the
Clauses 4.5.1 (paragraph 1) and Clauses 4.5.2 (paragraph 1) that begin
2 4.5.3
protected volume for pram bodies designed for
with the words, “The protected volume…”. Is there a reason for the
children less than 6 months (less than 800 mm
difference?
length) and pram bodies designed for older
children (over 800 mm internal length)
No we considered that a pram body with an
internal length less than 800 mm is designed
2. Is the clause applicable for pram bodies having a maximum internal
for children less than 6 month.
2 4.5.3 length of 800 mm combined with a vehicle child conveyance for children
Of course the vehicle may be used for older
older than 6 months?
children, but not in pram use (suitability and
requirements of the seat unit)
Yes the word “only” can be deleted without
3. The Experts Committee recommends that the word “only” be deleted
modifying the purpose of this clause. The
from the first sentence. Will there be any implications by this change?
2 4.5.3 protected volume described here concerns
Are there wheeled child conveyances designed only for children up to 6
pram bodies less than 800 mm long and group
months?
0/0+ car seats mounted on a vehicle
Yes phthalates as other hazardous substances
This clause does not mention nonmetals such as phthalates. Is there a
are already covered by a regulation (REACH)
2 6 reason for that? Is this requirement mentioned in some other required
therefore there is no need to have it into the
source?
standard.
The purpose of the requirement is to avoid
Is there any significance to the location of the connection point of the
free length inside the protected volume that
2 8.4
cord/string/narrow fabric?
will cause a strangulation hazard. We don’t
consider the attachment point of such cords
Clause/
Subclause
N° Question Reply
/
Annex
straps or/ strings/ narrow fabrics, but the
length which is likely to exceed the acceptable
measure inside the protected volume. Seat unit
or pram body.
Does the requirement apply to a connection located outside of the seat Yes it does
unit or pram body that can be pulled into the inside of the seat unit or
Example 1: yes it is considered as a failure.It is
pram body with the force of 25 N?
a loop exceeding 360 mm and there is no detail
Example 1: in the standard on the location of the loop.
There are seat units having a strip, for adjustment of the backrest, located Example 2:
at the rear of the backrest. When pulled into the inside of the seat unit
In English the word “located” means
with a force of 25 N, the length of the strip (the part of it that is now
“attached”.
located inside the seat unit) exceeds 220 mm. Is it considered to be a
2 8.4
The intention of the working group was to take
failure? (see Figure A bellow)
into account the part of any
Figure A
cord/string/narrow fabric that can be found
Example 2: inside the pram body or seat unit, without
being necessarily attached inside the pram
There are seat units having a strip, attended to be attached to the carrier's
body or seat unit.
hand, connected to the vehicle's handle. If a part of that strip penetrates
to the inside of the seat unit or pram body, does the requirement apply to An amendment is needed and will be drafted
that part of the strip? to clarify this requirement.
Clause/
Subclause
N° Question Reply
/
Annex
Figure A
Example 2:
There are seat units having a strip, attended to be attached to the carrier's
hand, connected to the vehicle's handle. If a part of that strip penetrates
to the inside of the seat unit or pram body, does the requirement apply to
Clause/
Subclause
N° Question Reply
/
Annex
that part of the strip?
The principle of the test method is to ensure
the use of a stop has the lowest effect on the
test (possibly no effect)
To our experience there are different interpretations between different
Parking devices shall be engaged first, and
laboratories on this point of the standard. And the confusion seems to be
then the vehicle is placed on the slope.
3 8.9.1.2.1 regarding the way the wheels should be turned after putting on the
brakes, before placing the stroller against the stop. Leading to different
The most onerous condition shall be met (in
results on same product from different laboratories.
accordance with § 4) when allowing the
vehicle to rest against the stop.
The test method shall be amended.
When used in relation to a removable accessory (rain hood) that is
The draft amendment to the clause is aimed so
adjusted by the user and has no moving parts while is normal use.
avoid such questions.
To clearly define and clarify the meaning of the terms
An addition to the draft has been decided as
follows:
1) “potentially hazardous”
For hoods and any similar items such as
2) “rigid part”
canopies, sunshades …etc, the requirement is
Taken from the present std:
applicable to the space between the frame
components; and between any hood
4 8.3.1 1) No test method is specified
tensionner attached to them and the frame
2) The situation on a moving frame is likely to be unrepeatable
components, within a distance of 100 mm
measured from the primary pivot point of the
3) In particular relation to where hood links are fitted on the outside of an
hood.
approved accessory ie rain hood, any threat is only possible while the
user is making an open / closing adjustment. No movement is present
The working group agrees this space is within
when in use.
the protected volume and shall be considered.
4) The fabric / textile shields entry into the potential location from the

inside of the hood.
Clause/
Subclause
N° Question Reply
/
Annex
5) All plastic parts have corner edge radii
As this clarification will impact approx. 50% of branded products offered
in EU under cover of the EN1888:2012,
other UK brands may wish to add further comment or opinion to the
above before presentation at the CEN/TC252 meeting

EN 1888 ‘10.4 Instructions for use’ reads:
".in the form of instruction sheet, instruction manual, leaflet or other No this is not an acceptable support.
similar physical support."
5 10.4
Consumers are not supposed to all have a
Is a USB stick considered ‘similar physical support’? computer.
Would providing such a stick mean you meet the requirement?
Clause/
Subclause
N° Question Reply
/
Annex
The mirror committee has been made aware of the product (a skateboard
One of the function of the product
stroller) shown in the pictures below.
(transportation of a child) falls into the scope
of EN1888: 2012, but further study and risk
assessment shall be conducted to assess its
6 1
safety in accordance with
General Products Safety Directive
2001/95/EC. The product should not claim

compliance with the EN1888 standard.
Does this kind of product/design fall under the scope of EN 1888?
The requirement is clearly applicable to seat
10.2.6 Seat units shall be marked with the following warning:
units
"WARNING Always use the restraint system"
Clarification: YES
For seat units complying with 8.1.1.1.1 b) the warning shall be visible
Amendment of clause 10.2.6 is needed to
only when the vehicle is used as a pushchair.
replace the word "seat unit" by "pushchair"
As the warning needs to be translated in several languages many
7 10.2.6 Modify 10.2.6 to read
companies used to put the label into the shopping basket: it is visible
Pushchairs shall be marked with the following
when the product is in position for use; and there is enough room to have
warning:
all languages
"WARNING Always use the restraint system"
This position has been accepted by laboratories, but others refuse this.
This will be introduced in the draft
Is this position acceptable?
amendment 1.
No, the protected volume shall be measured in
In the clause 4.5.1 Protected volume of seat units, if the product has
accordance with the figure 1 in the standard.
lateral protections (e.g. handrails or side fabrics on the both sides of the
seat), is the access zone (the out of the seat) measured from the upper
Lateral protections are not considered for
8 4.5.1
surface of lateral protections like the picture below?
defining the protected volume unless for the
area located underneath the seat.
Or, whether lateral protections exist or not, is measured according to Fig
1 of the clause 4.5.1.?
The reclining backrest shall be adjusted in all
Clause/
Subclause
N° Question Reply
/
Annex
possible positions.
And, when determining the protected volume, is the adjustable backrest
positioned to fully reclined? Or fully upright?

According to the ii) where both operating devices are intended to be
operated by hand(s) (e.g. for their position, shape, according to the
manufacturer's instructions for use, etc.) they shall both
Yes, both operating devices 1-1 and 1-2 shall
automatically return to their original status and the locking devices
9 8.3.3.1.2.4
reengage automatically.
shall reengage when tested in accordance with 8.3.3.1.2.3. of the b)
of clause 8.3.3.1.1.3 Unintentional release of locking mechanism(s),
I think two operating devices in the picture 2
Clause/
Subclause
N° Question Reply
/
Annex
(1-1. the operating device is located at the center of the seat and it is
activated by the carer through pulling action,
1-2. side latch type operating device) shall be reengaged automatically,
am I right?
Clauses of the standard shall be considered
independently unless otherwise stated.
During testing in accordance with the clause 8.3.3.1.2.4 Effectiveness of The requirement of 8.3.3.1.2.4 is clearly
locking mechanism(s) on vehicles where the chassis can fold with explained in 8.3.3.1.1.3 as follows:
the pram body or seat unit or car seat installed, applied force raises
During testing in accordance with 8.3.3.1.2.4 the
the frame of the handle, so a gap is occurred between the frame of the
vehicle shall not fold. After testing in accordance
handle and the frame of the rear wheel (picture 1). When remove the
with 8.3.3.1.2.4 the vehicle and the locking
force, a gap is disappeared.
mechanisms shall not be damaged and the
10 8.3.3.1.2.4 vehicle shall still comply with the requirements
Is it applied to c) the application of an external force by the carer of
clause 8.3.1? of 8.2 (entrapment) and 8.7(hazardous edges
and protrusions).
So, is it hazard from moving part?
Therefore, the gap recorded on picture 1
If you determine it is hazard, actually I guess this gap is too hard to be
cannot be considered as a hazard from moving
accessed child's finger when the child is seated, so could you tell me why?
parts (8.3.1) using the method of 8.3.3.1.2.4.
If you determine it is not hazard, could you tell me why?
We cannot on a picture assess if this would
pass or fail 8.3.1 further physical assessment
needs to be done.
Clause/
Subclause
N° Question Reply
/
Annex
picture 1 (a gap is occurred in the red circle during testing in accordance
with 8.3.3.1.2.4)
The 9th paragraph of the clause 8.3.3.1.2.4 Effectiveness of locking
mechanism(s) on vehicles where the chassis can fold with the pram
body or seat unit or car seat installed. For vehicles with 2 or more
Yes when possible each locking device has to
separate and independent operating devices operate each operating
11 8.3.3.1.2.4
be tested separately.
devices such as to disengage each locking devices in turn and apply
force F in the same manner as in (a) and (b) above.
I understood the above paragraph means testing twice.
Clause/
Subclause
N° Question Reply
/
Annex
First, test with one operating device is operated. And then test with the
other operating device is operated.
Am I right ?
3.4 defines a car seat as follows:
The definition of a car seat in the revision of
group 0/0+ child restraint system complying with ECE44
EN1888 (to be published as EN1888-1) will be
An i-size car seat is therefore not a car seat according to EN1888. modified to take into account this new
regulation.
An i-size car seat does fit the definition of a seat unit in 3.3, as follows:
structure which may or may not be adjustable to achieve a reclining or For the application of the current standard an
12 3.3 & 3.4
recumbent position designed to support one or more children i-size child restraint system intended for
children up to 15 months (83 cm) is to be
The above definitions are unchanged in prEN1888: 2014
considered as a group 0+ car seat referring to
Is it the intention that i-size car seats are tested as seat units with a 15kg
ECE44; therefore, test mass F shall be used for
test mass when the manufacturer has designated a maximum weight of
testing.
say, 12kg and ECE44 group 0+ car seats are tested with 13kg?
There are many products on the market, which have a folding strap
“under the buttocks of the child”, which claim to be “not to be to be able to
be operated without taking the child off the seat”.
There is no interpretation and no clarification
→ Generally “Safe”. possible on this subject; the product clearly
fails the requirement of the standard.
Nevertheless, these straps are more or less directly, “free accessible”
“directly” under the child and could, in certain circumstances, be pulled The working group cannot say the product is
13 8.3.3
by the child, which could cause an non-intentional folding of the safe unless a proper risk assessment is carried
pushchair. out.
As discussed within the TC252/WG3, these products do not comply with An amendment to the EN1888-1 has to be
the European standard, even if sold in the US Millions of times and developed.
without any reported incidents.
Question to CEN TC252/WG3:
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Are the below shown “improvements” of the above mentioned folding
mechanisms SAFE, even if they do not comply with the wording the
current EN1888:2012?
1.
Or 2.:
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Following label would be tested according to Torque test and Tensile test
by some accredited labs, but according to others it's excepted from this
requirement. Depending on material of the label, but criteria test or not
test are not clear. Herewith the interpretations we received:
1. NO TEST because it’s made of fabric: Quotation Lab A: “This kind of
labels are usually made of fabric; we do not consider fabric as posing
The current standard (as well as the draft
choking hazard (such as in EN71-1 on toys) and we do not test them. If
EN1888-1) does not exclude any kind of
your label is covered with plastic however, we will test it as a small part”
material from the requirement. Therefore, all
2. TEST Depends on permeability Quotation Lab B: “we use test method types of labels shall be tested, even if made of
14 8.5
for fabric permeability evaluation like defined in EK2 AK2.2 for toys (see paper, fabric or any permeable material.
below) « If a drop of water is not entirely soaked up after 10 seconds, the
The question will be raised to TC252/WG6 for
“fabric” is considered as not enough permeable and is considered as
a common approach on this issue which
hazardous small part.”
concerns all childcare articles standards.

15 8.8.1
In case of a stroller having more than 2 rear wheels/sets of wheels, and The standard is clear: the parking device has to
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the parking device engages simultaneously (with a single action) only on engage simultaneously on ALL wheels/sets of
the two outermost wheels\ sets of wheels, does this configuration comply wheels. This product shown on the picture
with the requirement of clause 8.8.1 in the standard? does not meet the requirement of 8.8.1
A specific example which we came across with is as follows: The parking
device of the stroller in the following picture engages simultaneously
(with a single action) only on the two outermost sets of wheels, but not on
the middle set of wheels. Does this parking device comply with the above
requirement of the standard?
How to interpret “pinch the materials of the bumper bar between finger
and thumb and attach the bite tester…”
This interpretation is correct. The standard
clearly says that the materials shall be pinched
Our understanding is that clause explicitly requires the tester to pinch the
between thumb and forefinger.
materials between the thumb and forefinger and then apply the bite
tester. We have experience with labs that only use the bite tester to
16 8.5.2.3
The method used by the laboratory is not
determine the “smallest amount” and they do this by opening the bite
correct. This method has been developed and
tester slightly and then pushing it into the material until a small amount
validated by the TC252/WG6 and introduced
of material is between the teeth after which they close the tester and
in all relevant standards.
perform the test. We believe that this method is both not realistic and in
non-conformance with the test method. Additionally, we have experience
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with labs that do perform this method according to our interpretation
which causes confusion and inconsistency.
We would like to know what the commission says and how this method
should be interpreted.
We are asking in prEN 1888-1 to look also for cords and loops which
originate outside of the occupant space but can be brought inside the
occupant space by pulling them with a force of 25N.
No it was not the intention of the working
Is the intention of this requirement to fail stroller bags like these two
group to consider and fail such handles. The
represented below (imagine the first picture with the seat unit instead of
main reason is that they are not part of the
the carry cot)?
17 8.4
product.
If we want to keep the measurement approach, shouldn’t we define that if
Draft EN1888-1 is modified to clearly exclude
the strap is larger than xx mm than it is not to be considered a cord
those handles
anymore? In fact we speak about narrow fabrics in 8.4.1, but we do not
give any specification of what narrow means…
Can we please discuss this during the next WG3 meeting in June?
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4 00252051 – EN 1930:2011, Child use and care articles — Safety barriers — Safety requirements and test
methods
Table 5 — Summary table of the request for interpretations classified in the order of the clauses/subclauses of EN 1930:2011
Clause/Subclause Title Interpretation
n°
6.2.2.3 & 6.2.2.6  2/2017
6.2.2.3 & 6.5.1.2  10/2017
6.3.1  4/2017
6.4.1.1  5/2017
6.4.1.3.  1/2012
6.4.1.3 & 6.4.2.2  9/2017
6.5.1.1  3/2017
6.6.1 & 6.6.2  11/2017
6.7  8/2017
6.12.1  6/2017
6.12.2  7/2017
Table 6 — Table of the request for interpretation/clarification for EN 1930:2011
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WG4 experts have discussed 6.4.1.3. and make the
following clarification:
The standard specifies in the test for barriers with a closing
system with a mechanism that closes the system without the The automatic mechanism shall always close and lock
intervention of the user that the tester shall operate the opening throughout the whole range of opening (from 0° and
1 6.4.1.3.
and closing system 10 times from the maximum and minimum above) without the intervention of the user.
opening positions. The question was how the maximum and
Minimum and maximum openings may not be the most
minimum opening positions are determined.
onerous condition therefore intermediate positions
shall be checked.
A foothold exists on a continuous structure if four triangles It was the intention of the Committee that the four
marked on the template are completely obscured by the triangles on the template should be in direct contact
structure being checked. with the structure being measured in order for it to be
considered a foothold. During the revision of the
Using either the left or right hand template, place the template
standard, this will be addressed.
with its marked face on any continuous structure inclined at an
6.2.2.3 &
angle of less than 55° to the horizontal. Orientate either
6.2.2.6
template, Figure 2, to check whether any four triangles are
obscured indication a foothold; see figure 16 for examples.
Question:
We have a lower catch on a gate with a curved top see below
image:
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Is this top surface considered a foothold?
This is being interpreted differently across laboratories.
The requirements of this clause are as shown in Figure 16
intended for flat surfaces.
When the template is placed on top of a curved surface such as
this the triangles cannot be filled.

By ‘opening’, the Committee intended to describe a
Please could you clarify clause 6.5.1 Finger entrapment. A lab
completely bounded circular opening, in line with work
has applied toe test of clause 6.5.1.2 to a gap between a plastic
being done in TC 252/WG6 and other Working Groups in
3 6.5.1.1 handle located on the barrier and plastic on the frame of the gate
other revisions.
shown in the figure below. The lab has failed the product to this

clause.
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7 mm diameter probe inserted between handle and frame
Please confirm if the gap depicted above is covered by the
requirement of clause 6.5.1.
1) The intention of the Committee was to refer to
1) Finger entrapment
bounded openings that could stop the supply of blood
(DIN EN 1930:2012 clause 6.5.1.1)
to the finger in line with the rationale of TR 13387-
3:2015. Figure 15 specifically excludes gaps and
There shall be no openings between 7 mm and 12 mm unless the
openings of the dimensions given in this example.
depth of penetration is less than 10 mm when tested in
accordance with DIN EN 1930:2012 clause 6.5.1.2.
4 6.3.1
2) The test should be conducted in accordance with the
test method in the standard. The force applied should
Issue:
be 30N applied only once.
A test lab performed the test as follows:
The Committee did not view this as an interpretation
as the standard is clear, it just has not been followed.
At the bars lying one after the other there is an opening at which

the penetration depth of 7 and 12 mm of finger is greater
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10 mm.
In the upper area of Strength to the penetration (12 mm of
finger) 27. 6 N measured
In the middle area of Strength to the penetration (12 mm of
finger) 3. 4 N measured
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Question:
Should such gap have been tested as one of the dimensions is
larger than 12 mm (CEN TR 13387-3:201). If such gap is to be
tested, the force below 5N in the middle should allow the child to
remove his finger, thus not being an issue.
2) When tested in accordance with DIN EN 1930:2012 clause 6.3.2
there shall be no gap within the safety barrier or between the safety
barrier and the side of the test frame or between the safety barrier
and the floor/base of the test frame that allows the hip probe to pass
through from either side of the safety Barrier
Requirement: 30 N
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Issue:
A test lab performed the test as follows:
the hip probe can be pushed through at 58 N between the frame of
the safety gate (bottom) and the test rack (aluminium).
- After the test the whole safety gate lift about 6 mm

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- If a second test is carried out, the hip probe can be pushed through
the safety gate with a force of 24.4 N
Question: Is this test correctly done?

1) Please could you clarify clause 6.4.1.1. Unintentional opening. 1) Clause 6.4.1.1 refers to the opening and closing of
the barrier and does not apply to non-opening barriers.
A non-opening safety barrier contains two plastic buttons that
fix the two wooden elements of a gate. These buttons can be This mechanism is for assembly of the barrier only.
5 6.4.1.1
screwed/unscrewed manually. If unscrewed, the two wooden
2) It is the view of the Committee that this barrier
elements still hold together but can be removed with push/pull technically meets the requirements of the standard due to
there being two consecutive actions required to unlock it.
movements, as shown on the video.
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Does clause 6.4.1.1. apply for this gate, meaning that it shall
conform to one of the following conditions:
- at least two consecutive actions are required to release the
opening system, the operation of the second being dependent on
the first having been carried out and maintained; or
- at least two separate but simultaneous actions are required
to release the opening system operating on different principles.
If this is the case, do you consider unscrewing and shaking the
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elements as shown in the video to be two consecutive
movements.
2) Unintentional opening
(EN 1930:2011 clause 6.4.1.1)
Safety barriers shall conform to one of the following conditions:
a) at least two consecutive actions are required to release the
opening system, the operation of the second being dependent on
the first having been carried out and maintained; or
b) at least two separate but simultaneous actions are required to
release the opening system operating on different principles.
Components for fitting the safety barrier into an opening that
are not intended to be removed or released for allowing access
are excluded from this requirement.
Issue:
A test lab performed the test as follows:
The Safety barrier can be opened according to method a).
1. Press the release lever with the foot
2. Press the grid down from the top
Then the door is unlocked and shall be lift to open.
When the release lever is actuated, only a very small force is
needed to press down the safety barrier (24 N). If A child steps
on the release lever and holds on to the top safety barrier, it is
not unlikely that the barrier unlocks.
...