CEN/TR 15371-1:2017

Safety of toys - Interpretations - Part 1: Replies to requests for interpretation of EN 71-1, EN 71-2, EN 71-8 and EN 71-14

The purpose of this Technical Report is to provide replies to requests for interpretations of EN 71-1:2014, Safety of toys - Part 1: Mechanical and physical properties, EN 71-2:2011+A1:2014, Safety of toys - Part 2: Flammability, EN 71 8:2011, Safety of toys - Part 8: Activity toys for domestic use and EN 7- 14:2014, Safety of toys - Part 14: Trampolines for domestic use.

Sicherheit von Spielzeug - Interpretationen - Teil 1: Antworten auf Anfragen zur Interpretation von EN 71-1, EN 71-2, EN 71-8 und EN 71-14

Sécurité des jouets - Interprétations - Partie 1: Réponses aux demandes d’interprétation de EN 71-1, EN 71-2, EN 71-8 et EN 71-14

Varnost igrač - Razlaga - 1. del: Odgovori na zahteve po razlagi standardov EN 71-1, EN 71-2, EN 71-8 in EN 71-14

Namen tega tehničnega poročila je zagotoviti odgovore na zahteve po interpretaciji standarda EN 71-1:2014, Varnost igrač – 1. del: Mehanske in fizikalne lastnosti, EN 71-2:2011+A1:2014, Varnost igrač – 2. del: Vnetljivost, EN 71 8:2011, Varnost igrač – 8. del: Igrače za prostočasne aktivnosti za domačo uporabo in EN 7-14:2014, Varnost igrač – 14. del: Trampolini za domačo uporabo.

General Information

• Status: Withdrawn
• Publication Date: 23-May-2017
• Withdrawal Date: 13-Apr-2025
• ICS: 97.200.50 - Toys
• Technical Committee: CEN/TC 52 - Safety of toys
• Drafting Committee: CEN/TC 52/WG 11 - Interpretations and proposals for improvements of EN 71-1, EN 71-2 and EN 71-8
• Current Stage: 9960 - Withdrawal effective - Withdrawal
• Start Date: 28-Apr-2021
• Completion Date: 14-Apr-2025
• Ref Project: SIST-TP CEN/TR 15371-1:2017 - Safety of toys - Interpretations - Part 1: Replies to requests for interpretation of EN 71-1, EN 71-2, EN 71-8 and EN 71-14

Relations

• Replaces: CEN/TR 15371-1:2015 - Safety of toys - Interpretations - Part 1: Replies to requests for interpretation of EN 71-1, EN 71-2, EN 71-8 and EN 71-14
• Effective Date: 19-Oct-2016
• Replaced By: CEN/TR 15371-1:2021 - Safety of toys - Interpretations - Part 1: Replies to requests for interpretation of EN 71-1, EN 71-2, EN 71-8 and EN 71-14
• Effective Date: 05-May-2021

Standards Content (Sample)

SLOVENSKI STANDARD
01-julij-2017
1DGRPHãþD
SIST-TP CEN/TR 15371-1:2016
9DUQRVWLJUDþ5D]ODJDGHO2GJRYRULQD]DKWHYHSRUD]ODJLVWDQGDUGRY(1
(1(1LQ(1
Safety of toys - Interpretations - Part 1: Replies to requests for interpretation of EN 71-1,
EN 71-2, EN 71-8 and EN 71-14
Sicherheit von Spielzeug - Interpretationen - Teil 1: Antworten auf Anfragen zur
Interpretation von EN 71-1, EN 71-2, EN 71-8 und EN 71-14
Sécurité des jouets - Interprétations - Partie 1: Réponses aux demandes d’interprétation
de EN 71-1, EN 71-2, EN 71-8 et EN 71-14
Ta slovenski standard je istoveten z: CEN/TR 15371-1:2017
ICS:
97.200.50 ,JUDþH Toys
2003-01.Slovenski inštitut za standardizacijo. Razmnoževanje celote ali delov tega standarda ni dovoljeno.

CEN/TR 15371-1
TECHNICAL REPORT
RAPPORT TECHNIQUE
May 2017
TECHNISCHER BERICHT
ICS 97.200.50 Supersedes CEN/TR 15371-1:2015
English Version
Safety of toys - Interpretations - Part 1: Replies to requests
for interpretation of EN 71-1, EN 71-2, EN 71-8 and EN 71-
Sécurité des jouets - Interprétations - Partie 1: Sicherheit von Spielzeug - Interpretationen - Teil 1:
Réponses aux demandes d'interprétation de EN 71-1, Antworten auf Anfragen zur Interpretation von EN 71-
EN 71-2, EN 71-8 et EN 71-14 1, EN 71-2, EN 71-8 und EN 71-14

This Technical Report was approved by CEN on 18 April 2017. It has been drawn up by the Technical Committee CEN/TC 52.

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: Avenue Marnix 17, B-1000 Brussels
© 2017 CEN All rights of exploitation in any form and by any means reserved Ref. No. CEN/TR 15371-1:2017 E
worldwide for CEN national Members.

Contents Page
European foreword . 5
0 Introduction . 6
0.1 Interpretations and no-action decisions . 6
0.2 Requests for interpretation . 6
0.3 Answers to requests for interpretations . 7
1 Scope . 8
2 EN 71-1:2014, Safety of toys – Part 1: Mechanical and physical properties . 8
2.1 3.5 Ball (interpretation) . 8
2.2 3.12 Cord (no action decision) . 10
2.3 3.30 F uzz (no action decision) . 10
2.4 3.33 Large and bulky toy (interpretation) . 11
2.5 3.47 and and 3.48 Projectile toys (no action decision) . 13
2.6 3.47, 3.48 and 7.7 Projectile toys (no action decision) . 13
2.7 4.3 Flexible plastic sheeting (no action decision) . 14
2.8 4.4 Toy bags (no action decision) . 15
2.9 4.5 Glass (no action decision) . 16
2.10 4.9 Protruding parts (interpretation) . 16
2.11 4.10.1 c) folding and sliding mechanisms (no action decision) . 17
2.12 4.10.3 Hinges and rationale A.13 (interpretation) . 18
2.13 4.11 Mouth-actuated toys and other toys intended to be put in the mouth
(interpretation) . 18
2.14 4.14.2 Masks and helmets (no action decision) . 19
2.15 4.15.1.2 Warnings and instructions for use (no action decision) . 20
2.16 4.15.1.4 Stability (interpretation) . 21
2.17 4.15.1.4; 8.23.1 Stability (interpretation) . 21
2.18 4.15.1.6 c) Transmission and wheel arrangement (no action decision) . 24
2.19 4.15.1.6 d) Transmission and wheel arrangement (no action decision) . 25
2.20 4.15.5.7 Toy scooters – protruding parts (interpretation) . 26
2.21 4.17 Projectiles (no action decision). 26
2.22 4.18 Aquatic toys and inflatable toys (no action decision) . 28
2.23 4.18 Aquatic toys and inflatable toys (interpretation) . 29
2.24 4.19 Percussion caps (no action decision) . 29
2.25 4.20 Acoustics (Re: percussion toys) (no action decision) . 29
2.26 4.20 Acoustics (interpretation) . 30
2.27 4.20 Acoustics (interpretation) . 31
2.28 4.20 Acoustics (interpretation) . 32
2.29 4.20 Acoustics (no action decision) . 33
2.30 4.20 Acoustics (interpretation) . 34
2.31 4.20 Acoustics (interpretation) . 34
2.32 4.20 Acoustics (interpretation) . 35
2.33 4.20 Acoustics (interpretation) . 35
2.34 4.20 Acoustics (interpretation) . 37
2.35 4.20 Acoustics (interpretation) . 37
2.36 4.20 Acoustics (interpretation) . 38
2.37 4.20 Acoustics (interpretation) . 39
2.38 Clause 5 Toys intended for children under 36 months (re: inflatable toys)
(interpretation) . 40
2.39 5.1 General requirements (re: small parts) (interpretation) . 41
2.40 5.1 General requirements (re: small parts) (interpretation) . 41
2.41 5.1 General requirements (re: fuzz) (no action decision) . 41
2.42 5.1 General requirements (re: plastic whiskers) (interpretation). 42
2.43 5.1 General requirements (no action decision) . 42
2.44 5.1 General requirements (no action decision) . 43
2.45 5.1 General requirements (no action decision) . 44
2.46 5.1 General requirements (interpretation) . 44
2.47 5.1 e) General requirements (re: glued wooden toys) (no action decision) . 46
2.48 5.1 e) General requirements (re: varnish) (interpretation) . 46
2.49 5.2 Soft-filled toys and soft-filled parts of a toy (no action decision) . 46
2.50 5.4 Cords, chains and electrical cables in toys (no action decision) . 47
2.51 5.4 Cords, chains and electrical cables in toys (interpretation) . 48
2.52 5.4 g) Cords, chains and electrical cables in toys (interpretation) . 49
2.53 5.7 Glass and porcelain (interpretation) . 51
2.54 5.8 Shape and size of certain toys (re: accessibility) (interpretation) . 52
2.55 5.8 Shape and size of certain toys (interpretation) . 52
2.56 5.8 Shape and size of certain toys (re: squeeze toys) (no action decision) . 52
2.57 5.8 Shape and size of certain toys (interpretation) . 53
2.58 5.8 Shape and size of certain toys (no action decision) . 53
2.59 5.10 Small balls (no action decision) . 54
2.60 5.12 Hemispheric-shaped toys (no action decision) . 57
2.61 Clause 6 Packaging (no action decision) . 58
2.62 7.1 Warnings, markings and instructions for use – General (no action decision) . 58
2.63 7.1 Warnings, markings and instructions for use – General (no action decision) . 59
2.64 7.2 Toys not intended for children under 36 months and 7.3 latex balloons (re:
warning) (no action decision) . 60
2.65 7.12 Liquid filled teethers (interpretation) . 60
2.66 8.4.2.2 Tension test - Seams and materials (interpretation) . 61
2.67 8.4.2.2 Tension test - Seams and materials (interpretation) . 61
2.68 8.5 Drop test and 8.7 Impact test (interpretation) . 62
2.69 8.13 Flexibility of metallic wires (no action decision) . 63
2.70 8.18.2.b) Folding or sliding mechanisms – Toy pushchairs and perambulators
(interpretation) . 63
2.71 8.23.1 Stability – Toys intended to bear the mass of a child (no action decision) . 63
2.72 8.25.1.1 Plastic sheeting - apparatus (interpretation). 64
2.73 8.28.2 Test procedures (re: acoustics) (no action decision) . 66
2.74 8.28.2.1.3, 8.28.2.2.3, 8.28.2.3.3, 8.28.2.11.3 Operating conditions and
measurements (re: acoustics) (interpretation) . 67
2.75 8.28.2.2.3, 8.28.2.5.3 Operating conditions and measurements (re: acoustics) (no
action decision) . 67
2.76 8.28.2.7.3 Operating conditions and measurements (re: acoustics) (interpretation) . 68
2.77 8.28.2.9.3 Operating conditions and measurements (re: acoustics) (no action
decision). 68
2.78 8.28.2.11 Voice toys (re: acoustics) (Interpretation) . 69
2.79 8.28.2.11.4 Voice toys – measurement results (interpretation) . 71
2.80 General interpretation and guidance document for the application of the acoustic
requirements from EN 71-1:2014. 72
2.80.1 Acoustic interpretations . 72
2.80.2 Explanation of requirements for time-averaged sound . 72
2.80.3 Explanation of requirements for peak sound. 77
2.80.4 Particular cases . 78
3 EN 71-2:2011+A1:2014, Safety of toys — Part 2: Flammability . 78
3.1 Applicability of Subclauses 4.1 to 4.2.5 . 78
3.2 4.2.2 Beards, moustaches, wigs etc., . (interpretation) . 85
3.3 4.2.5 Flowing elements of toys . and 4.3 Toy disguise costumes . (interpretation) . 85
3.4 4.3 Toys disguise costumes and toys intended to be worn by a child in play
(interpretation) . 86
3.5 4.4 Toys intended to be entered by a child (interpretation) . 86
3.6 5.4.1 Preparation of test sample (no action decision) . 88
3.7 5.4.1 Preparation of test sample (interpretation) . 89
3.8 5.4.1 Preparation of test sample (interpretation) . 90
4 EN 71-8:2011, Safety of toys — Part 8: Activity toys for domestic use . 91
4.1 3.7 Forced movement (no action decision) . 91
4.2 4.2.1 Barriers and handrails preventing the child from falling down (no action
decision) . 91
4.3 4.3.1 Head and neck entrapment . 92
4.4 4.3.1 a) Head and neck entrapment (no action decision) . 92
4.5 4.3.2 Entrapment of clothing and hair (no action decision) . 92
4.6 4.6.7 Suspension connectors and swing devices (no action decision) . 93
4.7 4.6.8.3 Geometry and design of swing elements (no action decision) . 95

European foreword
This document (CEN/TR 15371-1:2017) has been prepared by Technical Committee CEN/TC 52 “Safety
of toys”, the secretariat of which is held by DS.
Attention is drawn to the possibility that some of the elements of this document may be the subject of
patent rights. CEN [and/or CENELEC] shall not be held responsible for identifying any or all such patent
rights.
This document supersedes CEN/TR 15371-1:2015.
CEN/TR 15371, Safety of toys — Interpretations, is currently composed with the following parts:
— Part 1: Replies to requests for interpretation of EN 71-1, EN 71-2, EN 71-8 and EN 71-14;
— Part 2: Replies to requests for interpretation of the chemical standards in the EN 71-series.
0 Introduction
0.1 Interpretations and no-action decisions
This Technical Report contains replies to requests for interpretations concerning the understanding of
clauses in EN 71-1:2014, EN 71-2:2011+A1:2014, EN 71-8:2011 and EN 71-14:2014. The replies
concern those requests that have resulted in an interpretation or a decision that no action is required as
the standard is sufficiently clear.
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 should only be regarded as a clarification of
the meaning of the standard such that stakeholders can apply it correctly in a conformity assessment.
An interpretation is not an assessment of the requirement in the standard - it is only a strict
interpretation of the meaning of the text.
Disclaimer:
The interpretations have been derived by expert groups of CEN/TC 52. 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.
0.2 Requests for interpretation
Requests for interpretations may be submitted by a CEN member body through its national committee
or by a CEN/TC 52 liaison (but not directly by an individual or a company) - in accordance with the
interpretation protocols agreed by CEN/TC 52. The requests are then channelled to the relevant
CEN/TC 52 working party, which will then deal with the request.
A request for an interpretation may lead to:
a) An interpretation of the standard:
This should reflect a reasonable interpretation of how the standard should be used, taking into
account:
1) the wording of the standard;
2) the rationale of the standard;
3) the history of the standard.
b) A no-action decision:
This is applicable when it is agreed that the standard appropriately specifies how a toy shall be
assessed.
c) A proposal for an amendment of the standard:
This is applicable when it is agreed that the standard is deficient in some way.
NOTE Interpretation and no-action decisions are published in the CEN/TR 15371 series, which will be
updated on a regular basis.
Proposals for amendments will be progressed as new work item proposals in accordance with CEN
rules.
0.3 Answers to requests for interpretations
Since requests for interpretations are submitted through a CEN member body or a CEN/TC 52 liaison, it
is assumed that they will keep themselves informed about decisions concerning the request and its
progress and will themselves inform the originator of the request as appropriate.
1 Scope
The purpose of this Technical Report is to provide replies to requests for interpretations of
EN 71-1:2014, Safety of toys — Part 1: Mechanical and physical properties, EN 71-2:2011+A1:2014,
Safety of toys — Part 2: Flammability, EN 71-8:2011, Safety of toys — Part 8: Activity toys for domestic
use and EN 71-14:2014, Safety of toys — Part 14: Trampolines for domestic use.
2 EN 71-1:2014, Safety of toys – Part 1: Mechanical and physical properties
2.1 3.5 Ball (interpretation)
Question
The definition of a ball according to Clause 3.5 is:
“Spherical, ovoid or ellipsoidal object, usually but not always designed or intended to be thrown, hit
kicked, rolled, dropped or bounced”.
There is an additional note explaining the ball definition includes multisided objects formed by at least
48 connecting planes into a generally spherical, ovoid or ellipsoidal shape.
What about spherical, ovoid or ellipsoidal objects having small protrusions or projections?
See below some examples of toys intended for children under 3 years of age that have a generally
spherical, ovoid or ellipsoidal shape but in addition have protrusions or projections.
Should they be considered as balls?

a) b)
Figure 1
Ratio: minor/major axes = 90 % (green protrusion not counted) or 97,5 % (green protrusion counted)
Figure 2
Ratio: minor/major axes = 87 % (green protrusion not counted) or 75,5 % (green protrusion counted)

Figure 3
Ratio: minor/major axes = 74 % (yellow ends elements considered to be part of the whole shape)
Reply
The three toys as presented here would fall under the definition of balls and are subject to the
requirements for small balls per EN 71-1. In the case of the tomato and purple strawberry the
protrusions are on one side only and they are small. They appear to make no difference in the
assessment of the ratio between minor and major dimensions mentioned in the informative annex. For
the lemon shape the small end elements are considered to be part of the overall ellipsoidal shape. This
interpretation is only valid for the toys evaluated under this request.
REQ 156-15 (NEN, Netherlands)
2.2 3.12 Cord (no action decision)
Question
The question relates to 3.12 “cord” of EN 71-1.
The standard defines cord as:
“length of flexible textile or non-textile material including elastic material, monofilament polymeric
material, tape, ribbon, rope, strap, woven and twisted material and string as well as certain weak and
long springs”
Soft filled parts of a soft filled toy are not included by the definition of cord. Therefore, the requirements
of 5.4 shall not be applied to those parts.
In the example provided, the tail of Figure 1 and the toy of Figure 3 are soft filled, while the tail of
Figure 2 is not soft filled, therefore 5.4 is applicable only to the tail of Figure 2. Is it correct?

Figure 4 Figure 5 Figure 6
Reply
Standard is clear. Soft-filled parts of toys are not cords as defined in the standard. The tail of the toy in
Figure 2 is considered a cord because there is not stuffing material inside.
REQ 104-12 (UNI, Italy)
2.3 3.30 F uzz (no action decision)
Question
The question relates to 3.30 “fuzz” of EN 71-1.
Some soft filled toys may have fur with long hairs, even longer than 50 mm. We do know that such hairs
are not to be considered as monofilament fibres.
If the toy loses these hairs when pet (as per foreseeable use), as in the attached picture, even in great
amount, is it correct to consider these hairs included in the definition of fuzz, therefore excluding them
from the requirements of 5.1?
Figure 7 Figure 8
Reply
Standard is clear. It is correct to consider the described fibres as fuzz (which is excluded from 5.1
requirements).
REQ 105-12 (UNI, Italy)
2.4 3.33 Large and bulky toy (interpretation)
Question
How do you measure the volume of large and bulky toys as defined in 3.33 of EN 71-1:2014?
Here are two possible ways. Option A or Option B (see drawings below)?

OPTION A: GLOBAL VOLUME CALCULATION

OPTION B : follow the shape to calculate volume

Toy 1
Interpretation
The volume is considered to be smallest imaginary box that would contain the toy after having removed
minor appendages which actually is option A above.

Minor appendages would be the wooden elements on the sides of toy 1.
REQ 134-13 (BSI, United Kingdom)
2.5 3.47 and and 3.48 Projectile toys (no action decision)
Question
EN 71-1 has the below definitions of projectiles with or without stored energy:
3.47
projectile toy with stored energy
toy with a projectile propelled by means of a discharge mechanism capable of storing and releasing
energy
3.48
projectile toy without stored energy
toy with a projectile discharged by the energy imparted by a child
An example - a toy where the energy is imparted by e.g. a spring or an elastic band and the launching is
entirely controlled by the child, as the toy has no mechanism for holding back the projectile and storing
the energy for a prolonged time. Such a toy could be interpreted not to be included in 3.48. However,
the toy is obviously also not within 3.47 because we interpret 3.47 so that the toy shall be capable to
accumulate and store the energy for a prolonged period of time without involvement of a child.
We would like to have a confirmation that a projectile toy, which cannot accumulate and store energy is
within 3.48 even if a spring is used in launching the projectile.

Figure 9
Reply
Standard is clear. In this case, the energy is not stored and released by a discharge mechanism but the
energy is imparted by the user. In consequence, this toy is regarded as a “projectile toy without stored
energy”
REQ 064-06 (DS, Denmark)
2.6 3.47, 3.48 and 7.7 Projectile toys (no action decision)
Question
Even if we are aware of the ongoing discussion about the revision on projectiles requirements, we ask
to give an official interpretation of the following issue to interpret correctly the current version of the
standard.
a) EN 71-1 defines as projectile an “object intended to be launched into free flight or a trajectory in the
air”
1) does this include toys like boomerang or frisbee?
2) does this include small toys designed in such a way that hitting their base, they make a little
jump, rotating on themselves? (to figure them think about a spoon on a table: hitting its
extremity you can have it make this kind of jump)
3) does it include objects launched by catapult toys?
b) If a toy has a spring or an elastic band, but no mechanism to hold the projectile in the “charged”
condition (this means that as soon as you release the projectile, it is launched, like in a bow), is it
considered “projectile toy with stored energy” (the spring and elastic are considered as discharge
mechanisms) or as a “projectile toy without stored energy” (the energy of the projectile depend
upon how much the child put the projectile into the toy, like a bow, even if, differently form bows, in
this case usually there is an “end of stroke” and the maximum projectile energy is defined)?
c) 7.7 defines two warnings: not to use different projectiles from the supplied ones and not to aim at
eyes or face.
We consider the first one applicable to all the projectile toys from which a generic projectile may be
launched (for example projectile toy with stored energy or bows), but not applicable for toys without
stored energy like catapults (4.17.2 does not give any reference to 7.7).
Instead we consider the second warning (“Aim at face”) applicable only to projectiles toys with stored
energy or bows with a kinetic energy greater than 0,08 J.
Is it correct?
Reply
a) 1) Standard is clear those toys enter into the projectiles definition.
a) 2) Standard is clear those toys enter into the projectiles definition.
a) 3) Standard is clear those toys enter into the projectiles definition (provided those “catapults” do not
enter into the exclusion list as outlined into EN 71-1 Scope).
b) Standard is clear this is a “projectile toy without stored energy” (see 3.48 definition) provided the
described item is not regarded as a catapult and therefore enters into the exclusion list as outlined into
EN 71-1 Scope.
c) Standard is clear for projectile toys with stored energy in 4.17.3 c). If a discharge mechanism is able
to discharge an object other than that provided with the toy, then labelling according to 7.7.1 is
required. If a toy is capable of discharging a projectile with a kinetic energy greater than 0,08 J, labelling
according to 7.7.2 is required. If a toy meets both conditions then the two labelling are required.
Bows and arrows shall only bear “Warning. Do not aim at eyes or face” under the conditions outlined in
4.17.4 c)
REQ 076-07 Part 1 (UNI, Italy)
2.7 4.3 Flexible plastic sheeting (no action decision)
Question 1
4.3 applies only to plastic sheeting having dimensions greater than 100 mm X 100 mm. If a plastic bag
has a dimension of 100 mm X 80 mm, as it is, does the requirement apply?
Question 2
If we consider the plastic bag, its dimension is less than 100 mm X 100 mm, but if we consider the
plastic sheeting, cutting the plastic bag along two edges, we can get a 100 mm X 160 mm (80 mm X 2).
But, especially if the toy is intended only for children over 36 months of age, it is not required to apply
any cutting.
And, if the toy is intended for children under 36 months of age, and we apply the tension test to the bag,
before to break it into a plastic sheet, it is foreseeable that the applied 90 N force will elongate the
plastic sheeting and thus will also make it having a thinner thickness.
Moreover, the test method of 8.25.1.2 reads ”For plastic bags, cut along the seams without stretching
the bag so that two single sheets are produced.”.
But this test method is referred both by 4.3 and by Clause 6 (which does not apply to toy bags which
have a play value in the toy).
In our opinion the need to cut the bag along the seams is referred to packaging bags, and not to plastic
sheeting addressed by 4.3. The reason for this interpretation is that in case of bags with an opening
perimeter greater than 380 mm (as required by Clause 6), the child can put his head inside the bag and
so it can have on his nose and mouth just one sheet of the twos forming the bag.
But if 4.3 is not applicable to plastic bags, but to plastic sheeting only, we can have plastic bags with an
opening perimeter less than 380 mm and with a thickness of less than 0,038 mm both for packaging and
for bags having a play value (4.4 does not require a minimum thickness and Clause 6 defines a
minimum thickness only for plastic bags with an opening perimeter greater than 380 mm).
The reason for this may be that bags (in which the child cannot put his head), having a double layer, are
less foreseeable to become attached to a child's face in such a way to cause asphyxiation, differently
from single layer plastic sheeting (this is just a supposition). Thus, one of the following should apply:
1) If the sheet is in a form of a plastic bag, its whole area shall be measured (not the area of the plastic
bag, and thus the area which is the sum of the two layers area). The measurements are performed
before any mechanical test.
2) For plastic bags only the area of the plastic bag (double layer) shall be taken into account. The
measurements are performed before any mechanical test.
3) The area and the thickness of the plastic bags shall be measured after the mechanical tests (which
ones, especially in the case of toys intended for children above 36 months of age?).
Which one is the correct one?
Reply
To question 1: The requirement does not apply
To question 2: Option 2 is the correct one
REQ 090-09 (UNI, Italy)
2.8 4.4 Toy bags (no action decision)
Question
In EN 71-1 there is a specific requirement for toy bags (4.4), which applies to toy bags with an opening
perimeter greater than 380 mm and having a drawstring as means of closure.
But what shall be done if the bag has a perimeter smaller than 380 mm and it is made of a plastic sheet?
Reply
4.4 is not applicable and 4.3 should be considered.
REQ 089-09 (UNI, Italy)
2.9 4.5 Glass (no action decision)
Question
4.5 states that accessible glass may only be used for toys for children over 36 months where it is
necessary for the function of the toy (e.g. optical toys, glass light bulbs, glass in experimental sets).
Traditionally there are some creativity sets where glass is used, but where it is not clear whether the
glass is functional or not.
1) Should we consider the glass used in candle making set as functional?
2) What about a glass painting set intended to decorate glass objects?

Figure 10
Reply
The nature and use of this product (involving candles) means that EN 71-1 cannot address the safety. If
this product were sold as a toy, it would need to be EC Type examined.
The same may apply to glass painting sets but much would depend on the nature of each product.
REQ 057-05 (AFNOR, France)
2.10 4.9 Protruding parts (interpretation)
Question
An example is given below where wheel axles have been exposed when the wheel has come off. For
guidance also some other reference information is given.

Figure 11
For toys intended for children over 3 years:
Q1: Shall a wheel on a wheel axle (which, if exposed, can present a puncture hazard) be considered to
be a protective component and thus subjected to 8.4.2.3 (tension test, protective components)?
Q2: If the answer to question 1 is “Yes”, shall the potential puncture hazard of the axle be assessed after
removing the axle from the toy and after placing the axle in a reasonably foreseeable position, or shall it
be assessed when still in the toy and in a reasonably foreseeable position?
Q3: If the answer to question 1 is “No”: Shall any force at all be applied in an effort to remove/detach a
wheel from a wheel axle in order to thereafter check the potential puncture hazard presented by the
remaining exposed axle?
Reply
Q1: No, it shall not be considered as a protective component since the presence of the wheel is not to
protect the end of the axle. Protective components are those which are intended to protect from a
potential hazardous protrusion.
Q3: No, according to the standard and for over 3 toys, there is no requirement asking for the application
of such a force.
REQ 129-12 (SIS, Sweden)
2.11 4.10.1 c) folding and sliding mechanisms (no action decision)
Question
The below toy is an ironing board made of plastic material with a height of 25 cm. It is intended to be
used on a table (child is then standing up) or can also be placed on the ground (the child is sitting in
front of the table). The legs of the ironing board are folding ones and present a scissor like action.
Are the requirements from 4.10.1 c) required for this type of toy?

Figure 12
Reply
Standard is clear, 4.10.1 c) applies since the legs of the ironing board are folding ones and present a
scissor like action.
REQ 085-08 (AFNOR, France)
2.12 4.10.3 Hinges and rationale A.13 (interpretation)
Question
Balance bikes made of wood have in several designs introduced a hazard of having fingers crushed in
the squash/squeeze points along the hinge line assembling the “front fork” and “bike frame” at the front
end.
These squash/squeeze points as shown below between the two hinged parts are not common on other
traditional ride-on toys and toy bicycles with traditional head tubes and fittings making this hinge
encapsulated.
The Toy Safety Directive states in Annex II Particular Safety Requirements, Point 3 the following:
“Toys shall be designed and manufactured in such a way as not to present any risk or only the minimum
risk inherent to their use which could be caused by the movement of their parts.”
Shall the below hinged part conform to the requirement in EN 71-1, 4.10.3, despite the remarks made in
the informative rationale A.13 of 4.10.3?

Figure 13
Reply
The purpose of the requirement in 4.10.3 is to address possible crushing hazard related to varying
clearances along a hinge line as stated in the first sentence of the rationale A.13. Therefore, hinged part
of the toy as described above shall comply with this requirement.
REQ 132-12 (DS, Denmark)
2.13 4.11 Mouth-actuated toys and other toys intended to be put in the mouth
(interpretation)
Question
Which toys shall be considered as intended to be put in the mouth according to EN 71-1, 4.11?
It is clear that mouth-actuated toys, whistles and peashooters are intended to be put in the mouth but
what about other toys like toy cups, toy spoons, toy forks, toy toothbrushes and toy lipsticks as in the
following images?
Figure 14 Figure 15 Figure 16 Figure 17
And what about toys intended to be placed in the doll’s mouth but that, for imitation, also the child may
put in his mouth (like toy feeding bottle, toy soother, etc.)?

Figure 18 Figure 19 Figure 20
Reply
Toys which are miniatures of real products (e.g. cutlery, feeding bottles, soothers, toothbrush) and
intended for use with dolls, etc. are not considered to be intended to be put in the mouth and are not
covered by 4.11 requirements.
Toys which are copies of real products and which might be used by children for their real purpose
during play are covered by 4.11 requirements if that leads to them being put in the mouth.
Toys which are copies of real products and which are just intended to be put to the lips (e.g. lipsticks,
cups) should not be regarded as toys intended to be put in the mouth and are not covered by 4.11
requirements.
REQ 106-12 (UNI, Italy)
2.14 4.14.2 Masks and helmets (no action decision)
Question
1) 4.14.2 of EN 71-1 states about masks the following:
“4.14.2 Masks and helmets
Mask and helmets shall conform to the following requirements:
a) Masks and helmets that fully enclose the head and which are made of impermeable material shall
or more through at least two holes at least 150 mm
provide a total ventilation area of 1 300 mm
apart or through any equivalent single ventilation area.”
We understand reading this point that the requirement apply to all types of masks.
Nevertheless, there are several types of masks in the market according to their design and their
material:
Masks that fully enclose the head (generally the area of the face with polymeric flexible material
and the rest with textile material with or without hair). Masks that enclose the head but not fully
(generally the area of the face with polymeric flexible material and the rest with textile material
with or without hair).
Masks that only enclose the face.
The last ones have several designs, ones fit in the form of the face and others are more or less flat
and are made of flexible material, polymeric half-rigid material and even cardboard.
Taking into account that establishing the safety requirements to address risks is the target of the
standard (in this specific case, the risk of asphyxiation that could happen to the children when
using the masks), we have a doubt regarding the below type of masks, which enclose only the face,
because it is likely that not all the mentioned masks could present the risk of asphyxiation.
Therefore, there could be masks like the below ones that could not need to fulfil the requirements
on 4.14.2 a)
Figure 22
2) Regarding the ventilation area required, we have a doubt about what has to be included in the
mentioned area, i.e. does the ventilation area only include the holes at the level of the nose and the
mouth, or include the holes at the level of the eyes too?
Reply
1) Requirements in 4.14.2 a) only apply to masks that fully enclose the head and which are made of
impermeable material therefore masks that cover the face and for which pictures are given are not
covered by this requirement.
2) All holes are to be taken into consideration whatever their position knowing that if only eye, nose
and mouth holes were considered the 150 mm requirement would conflict with the normal
positioning of those holes for a correct use and should never been fulfilled.
REQ 048-04 (AENOR, Spain)
2.15 4.15.1.2 Warnings and instructions for use (no action decision)
Question
4.15.1.2 indicates:
“Electrically-driven ride-on toys and/or their packaging, and their instructions for use, shall carry a
warning regarding protective equipment (see 7.10.3). This warning is not required on electrically-
driven ride-on toys that are equipped with a seat, and are either covered by the requirement in 4.15.1.4
or have a maximum design speed of less than 8,2 km/h when tested according to 8.29 (determination of
maximum design speed of electrically-driven ride-on toys).”
7.10.3 applies when the electrically-driven ride-on toys are equipped with a seat but are not covered
either by the requirement in 4.15
...