CEN/TR 18240:2025
(Main)Safety of toys - Mechanical and physical properties - Guidance on the requirements for food-imitating toys in EN 71-1
Safety of toys - Mechanical and physical properties - Guidance on the requirements for food-imitating toys in EN 71-1
This proposed TR gives guidance on the requirement for toys which may be a realistic food imitation under the meaning of the prEN 71-1 clause 4.28, in order to assist users of the EN 71-1 standard.
This document is only to assist users in distinguishing whether a toy product that imitates food in some way should be considered a realistic food imitation. It does not address products that are not toys.
Leitlinien zu den Anforderungen an lebensmittelnachahmendes Spielzeug in EN 71-1
CEN TR XXXXX : Sécurité des jouets - Propriétés mécaniques et physiques - Recommandations sur les exigences relatives aux jouets imitant les aliments dans l'EN 71-1
Varnost igrač - Mehanske in fizikalne lastnosti - Navodilo o zahtevah za igrače, ki so podobne živilom, v standardu EN 71-1
General Information
Standards Content (Sample)
SLOVENSKI STANDARD
01-september-2025
Varnost igrač - Mehanske in fizikalne lastnosti - Navodilo o zahtevah za igrače, ki
so podobne živilom, v standardu EN 71-1
Safety of toys - Mechanical and physical properties - Guidance on the requirements for
food-imitating toys in EN 71-1
Leitlinien zu den Anforderungen an lebensmittelnachahmendes Spielzeug in EN 71-1
CEN TR XXXXX : Sécurité des jouets - Propriétés mécaniques et physiques -
Recommandations sur les exigences relatives aux jouets imitant les aliments dans l'EN
71-1
Ta slovenski standard je istoveten z: FprCEN/TR 18240
ICS:
97.200.50 Igrače Toys
2003-01.Slovenski inštitut za standardizacijo. Razmnoževanje celote ali delov tega standarda ni dovoljeno.
FINAL DRAFT
TECHNICAL REPORT
FprCEN/TR 18240
RAPPORT TECHNIQUE
TECHNISCHER REPORT
July 2025
ICS
English Version
Safety of toys - Mechanical and physical properties -
Guidance on the requirements for food-imitating toys in
EN 71-1
CEN TR XXXXX : Sécurité des jouets - Propriétés Leitlinien zu den Anforderungen an
mécaniques et physiques - Recommandations sur les lebensmittelnachahmendes Spielzeug in EN 71-1
exigences relatives aux jouets imitant les aliments dans
l'EN 71-1
This draft Technical Report is submitted to CEN members for Vote. 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, France, Germany, Greece, Hungary, Iceland, Ireland, Italy, Latvia, Lithuania, Luxembourg, Malta, Netherlands, Norway,
Poland, Portugal, Republic of North Macedonia, Romania, Serbia, Slovakia, Slovenia, Spain, Sweden, Switzerland, Türkiye and
United Kingdom.
Recipients of this draft are invited to submit, with their comments, notification of any relevant patent rights of which they are
aware and to provide supporting documentation.
Warning : This document is not a Technical Report. It is distributed for review and comments. It is subject to change without
notice and shall not be referred to as a Technical Report.
EUROPEAN COMMITTEE FOR STANDARDIZATION
COMITÉ EUROPÉEN DE NORMALISATION
EUROPÄISCHES KOMITEE FÜR NORMUNG
CEN-CENELEC Management Centre: Rue de la Science 23, B-1040 Brussels
© 2025 CEN All rights of exploitation in any form and by any means reserved Ref. No. FprCEN/TR 18240:2025 E
worldwide for CEN national Members.
FprCEN/TR 18240:2025 (E)
Contents Page
European foreword . 3
Introduction . 4
1 Scope . 4
2 Normative references . 4
3 Terms and definitions . 4
4 Background for the requirements . 4
4.1 Incident data . 4
4.2 Global legislation . 5
4.3 Children’s behaviour and attitude towards food-imitating toys . 5
4.4 The CASP (Coordinated Activities on the Safety of Products) Child appealing (including food
imitating) products report 2021 . 5
5 Development of requirements . 6
5.1 Hazards addressed . 6
5.2 Addressing gels, liquids, powders and modelling clays . 6
5.3 Behavioural processes . 6
5.4 Realism of imitation . 7
5.5 Sweets and candies . 7
6 Evaluation of samples . 7
6.1 Review process . 7
6.2 Samples reviewed . 8
Annex A (Informative) Interrogation of United States Consumer Product Safety Commission
National Electronic Injury Surveillance System (NEISS) . 36
Annex B (Informative) Relevant extracts from published research papers on children’s behaviour
towards imitation foods . 38
FprCEN/TR 18240:2025 (E)
European foreword
This document (FprCEN/TR 18240:2025) has been prepared by Technical Committee CEN/TC 52 “Safety of
toys”, the secretariat of which is held by DS.
This document is currently submitted for vote on TR.
FprCEN/TR 18240:2025 (E)
Introduction
The purpose of this document is to assist users of FprEN 71-1:- with the requirements for food-imitating toys
under Clause 4.28 of that standard.
This document explains the processes that were used in developing the requirements so that users of that
standard can use the same thought processes in order to assess individual toys on a case-by-case basis.
The examples appearing in this document are intended to facilitate decision-making on whether a particular
toy is a realistic food imitation. This document does not presuppose the conformity of the represented products.
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.
1 Scope
This document gives guidance on the requirements for toys, which can be considered a realistic food imitation,
to assist users of FprEN 71-1:-.
This document is only to assist users in distinguishing whether a toy product, that imitates food in some way,
can be considered a realistic food imitation in accordance with clause 4.28 of that standard.
This document does not aim to address whether a product is a toy or not and does not attempt to identify any
hazard associated with a particular toy.
2 Normative references
The following documents are referred to in the text in such a way that some or all their content constitutes
requirements of this document. For dated references, only the edition cited applies. For undated references, the
latest edition of the referenced document (including any amendments) applies.
FprEN 71-1:- , Safety of toys — Part 1: Mechanical and physical properties
3 Terms and definitions
For the purposes of this document, the terms and definitions given in FprEN 71-1:- apply.
ISO and IEC maintain terminology databases for use in standardization at the following addresses:
— ISO Online browsing platform: available at https://www.iso.org/obp/
— IEC Electropedia: available at https://www.electropedia.org/
4 Background for the requirements
4.1 Incident data
There is very little evidence of injuries or incidents occurring due to food-imitating toys.
Data of injuries involving consumer products is comprehensively collected in the United States of America by
the United States Consumer Product Safety Commission. A data search covering a ten-year period yielded only
4 possible food-imitating toy incidents. Information on these incidents and further information regarding this
search can be found in Annex A.
Accident data collection within Europe is not comprehensive so there is a potential data gap. It is possible that
incidents are not registered correctly or are not being recognized (both in Europe and in the United States of
Under preparation. Stage at the time of publication: FprEN 71-1:2025.
FprCEN/TR 18240:2025 (E)
America). However, this is not a novel, emerging issue but one that has been recognized (and legislated) for
over 35 years. On the balance of probabilities, it would seem that failure to recognise or categorise incidents
concerning food-imitation toys on a large scale is unlikely, and incidents are low in both frequency and
seriousness.
4.2 Global legislation
The legislation governing products which imitate food in the European Union is Regulation (EU) 2023/988 on
general product safety. This repeals the previous Council Directive 87/357/EEC, concerning products which,
appearing to be other than they are, endanger the health or safety of consumers.
It appears that the UK had been the first to enact legislation in 1985, in The Food Imitations (Safety) Regulations
1985.
No other legislation was found in any other global jurisdiction.
4.3 Children’s behaviour and attitude towards food-imitating toys
Based on searches conducted, it would seem there is little relevant research available to establish the behaviour
of children in relation to imitation foods. However, it is a reasonable presumption that the more food-like
attributes a toy has then the more likely it would be mouthed. There are also indications that as children get
older, they become more capable at identifying real vs. imitation foods.
Some noteworthy research papers were identified, and extracts are referenced in Annex B.
These articles only offer insights into how children approach, recognize and respond to apparent foodstuffs.
Recognition of foodstuffs increases from that of a very young child’s exploration of everything by the mouth to
more sophisticated “adult like” recognition of foodstuffs as a child ages.
It is however, unclear the age at which non-food items are readily rejected and how this sophistication develops
with age. This makes a clear age grade distinction difficult to establish and so for the purpose of the standard
all products intended for children over the age of 3 years were considered within scope (the risk of choking for
toys intended for children under the age of three already being addressed by existing requirements).
Since 2012 incidents of children ingesting laundry soap pods has been well documented. However, the SCCS
opinion in Annex B states that there is no data available that cosmetics with a sweet smell and strong colours
are ingested more often than others, appears contradictory. The SCCS opinion pre-dates the soap pods incidents
so that is a possible cause of the apparent contradiction, but it is difficult to draw defined conclusions from
these two different product categories and it is certainly an area that would benefit from greater research and
understanding.
For the purpose of the standard, it was agreed to take a precautionary, common-sense approach and toys that
closely resemble small candy/sweets in form, colour, texture, smell etc., would, on the balance of all likelihoods,
be more readily mouthed by young children.
4.4 The CASP (Coordinated Activities on the Safety of Products) Child appealing (including
food imitating) products report 2021
In developing the EN 71-1 requirements the “Child appealing (including food imitating) products - Final report”
and the “Handbook for stakeholders” were considered as highly relevant and useful texts.
In particular, the Handbook for stakeholders recognizes the challenges of subjectivity in evaluating imitation
foods and therefore the inconsistencies in approaches by enforcement.
The handbook also makes it clear that imitation food itself is not prohibited and that looking like food alone
does not necessarily lead to confusing with food and placing in the mouth.
The handbook explains the various attributes considered when evaluating the imitating product regulations
(form, odour, colour, appearance, packaging/labelling, volume and size) which the EN 71-1 text closely
references.
FprCEN/TR 18240:2025 (E)
5 Development of requirements
5.1 Hazards addressed
FprEN 71-1:- addresses only physical and mechanical hazards related to toys that are realistic food imitations.
It does not address other hazards. Significantly the toxicological hazards associated with swallowing objects or
fluids is not addressed in the requirements in 4.28 of FprEN 71-1:-.
Aside from chemical hazards, the most significant hazard with inedible products being placed in the mouth is
that of choking. The requirements of clause 4.28 therefore address choking as the primary hazard. As choking
hazards for all toys intended for children under the age of 36 months are already captured elsewhere within
EN 71-1, 4.28 does not need to consider food-imitating toys intended for children aged less than 36 months.
The requirements in clause 4.28 focus on the risks of injury brought about by confusion with real food. They do
not address the scenario of mouthing of products with a similar appearance to food, but where there is no
confusion with real food. For example, a child playing with a food-themed toy or creative set understands the
item is not real food but can bring the item to their mouth in role-play
5.2 Addressing gels, liquids, powders and modelling clays
Since the requirements of 4.28 have a focus on choking hazards, gels, liquids, powders and modelling clays were
considered in a slightly different way to the solid food imitation objects. These materials are exempt from the
choking hazard requirements for children under 36 months since they present a significantly lower risk of
blocking the airway. They are also therefore exempt from 4.28.
Any accessible solid components that are contained within gels, liquids, powders and modelling clays are not
exempt from the requirements of 4.28 since they could indeed cause choking, especially if there is a confusion
with a potable/edible product.
5.3 Behavioural processes
When developing the EN 71-1 text it was recognized that there were a series of “process steps” that a child
would undergo in the act of identifying a potential foodstuff to placing it in their mouths.
The first and simplest of these steps was the visual identification of the item as being a possible foodstuff. In
order for the child to be confused and mistake the item as a foodstuff at this stage there would have to be very
strong visual cues to prompt the child to consider the item is (or could likely be) a foodstuff.
Note that toys that appear to look like food items that are not immediately edible are not considered realistic
food imitations as they would not be directly placed in the mouth by a child due to confusion with real food. For
example, an un-peeled orange or an egg contained within its shell are not immediately edible food items.
Similarly, components of food that are not edible are not considered realistic food imitations (e.g. a stalk on an
apple or the stick of a candyfloss is not an edible component).
Further sensory “process steps” would then rapidly follow once the initial visual confusion was established.
Picking the item up would immediately impart tactile stimuli such as texture, weight, temperature, and
consistency.
Finally, olfactory and taste senses would impart further stimuli.
It was considered that at each step the child would reject any doubtful object that did not meet their expectation
as a foodstuff. Rejection does not necessarily prevent mouthing, but it would almost certainly prompt further
evaluation by the child and significantly reduce the likelihood of an immediate “hand-mouth-swallow” action.
For the simplicity of the standard creation and bearing in mind the uncertainties mentioned above, the visual
and non-visual cues were simplified into two distinct requirements. An item presenting itself as a foodstuff
must be likely to confuse at both these categorized “process” points to have the potential to pose a hazard
caused by imitation of food.
FprCEN/TR 18240:2025 (E)
5.4 Realism of imitation
Considering the behavioural process, it was considered that in order to be subject to the requirement of 4.28 a
toy would have to be a “realistic” food imitation likely to be confused by children and not simply something that
looks similar to food or has food-like attributes. This phrase was therefore selected for use in the requirements.
5.5 Sweets and candies
There was much debate among experts about toys which potentially imitate candy (or sweets in British
English). Some experts expressed concern that any small object with a bright colour had some potential to be
confused with a candy. Indeed, it was noted that some candies deliberately imitated non-food products (e.g.
confectionary in the shape of jewellery). It was agreed that anything imitating common commercially available,
mass-produced candy/sweet confectionary would need to be both visually realistic and importantly, have
further sensory similarities to the specific type of candy being imitated in order to be considered a realistic food
imitation.
It was also noted that virtually any shape could be made using candy, even toys. It was agreed that to be
considered a realistic food imitation the toy would need to imitate commercially available, mass-produced
candy/sweet confectionary rather than any creative artwork.
However, toy items that appeared to look like realistic confectionary that were also packaged in a style closely
resembling real confectionary packaging were considered to present an elevated risk. It was considered that a
child would exercise less doubt and less caution if presented with such a toy and that the immediate “hand-
mouth-swallow” action would be more likely.
6 Evaluation of samples
6.1 Review process
Samples were collected from many different sources and represented a broad range of toys which had food-
imitating properties.
In all, over 200 examples of products were reviewed and assessed and although the review was open to
subjectivity and opinion, there was broad alignment on the types of items that had the potential to be confused
with real food.
The following is a selection of examples from the samples reviewed and are given here to aid the assessment of
individual toys on a case-by-case basis.
The items were grouped based on their attributes and the opinion of the experts.
Group 1: Toys that do not have an appearance that is likely to lead a child to be confused into thinking
it looks like a real and immediately edible food.
This was the most significant group of items both in terms of number and general agreement. It was clear that
many items with food like attributes are not at all likely to be confused with real foodstuffs.
Group 2: Toys that have an appearance that is likely to lead a child to be confused into thinking it looks
like a real and immediately edible food but no other food-like attribute that would ensure confusion
persists.
Although opinion varied on the visual attributes being realistic enough to be confused with real foodstuff these
items were considered as unlikely to be confused with foodstuffs as they did not have any other food like
attributes. That is, even if a child confused the item with looking like real foodstuff, on picking it up they would
immediately realize it was not actual foodstuff and confusion would end.
Group 3: Toys that have an appearance that is likely to lead a child to be confused into thinking it looks
like a real and immediately edible food and at least one other food-like attribute that could ensure
confusion persists.
FprCEN/TR 18240:2025 (E)
This group prompted the greatest discussion and was perhaps the most open to subjective opinion. There was
a consensus among experts that the items in this group were visually realistic, but there was less agreement
about other attributes. However, items were placed in this group because they had a strong visual food-like
appeal and one other attribute that can lead to confusion, thus making them a realistic food imitation according
to the requirements in FprEN 71-1:-.
Group 4: Toys where consensus could not be reached.
During the development of this report some examples prompted greater discussion than others and opinions
differed greatly between experts. Where consensus was not easily reached items were placed “on hold” into
this fourth group. The intent was to move these into one of the other groups when consensus could be reached
after further discussion.
All but one of the examples that were initially placed in this group were moved to one of the other groups
One example remains in group 4 as consensus among experts could not be reached. It is included here along
with the basis of the difference of opinion to help illustrate some of the difficulties in making a clear assessment
and to reflect the unavoidable subjectivity of the requirements.
The final decision on whether a product is a realistic food-imitation will need to be determined by users of EN
Fpr71-1:- on a case-by-case basis.
6.2 Samples reviewed
Table 1 — Group 1: Toys that do not have an appearance that is likely to lead a child to be confused
into thinking it looks like a real and immediately edible food.
Ref. Image Attributes, Reasoning and Discussion
1.01 Form: Modelling clay
Colour: Brown
Volume: NA
Size: Container approximately 5 cm diameter, 5,5
cm high
Odour: Scented (but not like food)
Taste: Salty
Texture/feel: Soft clay. Malleable but holds form
under its own weight.
Packaging/container/labelling:
Plastic container
Does not have the appearance of real and
immediately edible food.
Not packaged or labelled or contained in a way that
is likely to lead a child to be confused into thinking
it looks like a real and immediately edible food.
(Note that gels, liquids, powders and modelling clays
are exempt from 4.28 of FprEN 71-1:-)
FprCEN/TR 18240:2025 (E)
Ref. Image Attributes, Reasoning and Discussion
1.02 Form: Chocolate themed plush
Colour: Brown, red, dark brown
Volume: NA
Size: Approximately 22 cm tall
Odour: None
Taste: NA
Texture/feel: Soft plush
Soft plush toy has no similar appearance to real
food.
1.03 Form: Ice cream & dessert themed creative
modelling clay set. Contains several roughly
cylindrical packets of modelling clay
Colour: Various bright colours
Volume: NA
Size: Each clay is approximately 5 cm long and 2
cm in diameter
Odour: Faint, musty cinnamon
Taste: Salty
Texture/feel: Soft clay. Malleable but holds form
under its own weight
Packaging/container/labelling:
Card retail box with ice-cream theme. Clays are in
individual plastic wrappers.
Does not have the appearance of real and
immediately edible food.
(Note that gels, liquids, powders and modelling clays
are exempt from 4.28 of FprEN 71-1:-)
1.04 Form: Food themed characters in a fridge styled
display
Colour: Various
Volume: NA
Size: Miniatures approximately 3 cm tall
Odour: No
Taste: No
Texture/feel: Soft elastomeric polymer (softer
and more flexible than a typical eraser)
FprCEN/TR 18240:2025 (E)
Ref. Image Attributes, Reasoning and Discussion
Caricaturised miniatures of food.
Each have a sucker shape attached, character faces.
Smaller than real food.
1.05 Form: Miniature replicas of food containers
Colour: Various
Volume: NA
Size: Approximately 3-5 cm tall
Odour: No
Taste: No
Texture/feel: Hard polymer
Do not appear like immediately edible food.
Small size.
1.06 Form: Plastic miniatures of lollies
Colour: Bright colours with a matt finish
Volume: NA
Size: The assembled 3-piece lolly has a greatest
dimension of approximately 4,5 cm tall (stick
included)
Odour: No
Taste: No
Texture/feel: Soft polymer (harder than a typical
eraser)
FprCEN/TR 18240:2025 (E)
Ref. Image Attributes, Reasoning and Discussion
Miniature in size.
Lack realistic appearance in texture or sheen.
1.07 Form: Plastic fruit-themed tokens as you might
see on a key chain or fob
Colour: Bright colours with a matt finish
Volume: NA
Size: Approximately 2 cm across, 3 cm in thickness
Odour: No
Taste: No
Texture/feel: Soft polymer (harder than a typical
eraser)
Two-dimensional non-realistic images of fruit.
Miniature in size.
Small metal rings attached.
Non-edible attachments are very strong indicators
of a non-food item.
1.08 Form: Miniature food themed items
Colour: Various
Volume: NA
Size: <5 cm
Odour: No
Taste: No
Texture/feel: Various hard and soft polymers
Miniature in size.
Lack realistic appearance in texture or sheen.
Some of the items have components permanently
attached which are not imitating food items (e.g.
dish and spoon).
Non-edible attachments are very strong indicators
of a non-food item.
FprCEN/TR 18240:2025 (E)
Ref. Image Attributes, Reasoning and Discussion
1.09 Form: Food themed character pencil toppers
Colour: Bright colours, matt finish
Volume: NA
Size: Miniatures approximately 3-4 cm tall
Odour: No
Taste: No
Texture/feel: Soft polymer (harder than a typical
eraser)
Caricaturised miniatures of food items.
Each have a hole in their underside and character
faces.
Smaller than real food.
1.10 Form: One wooden and one plastic cookie
Colour: Brown
Volume: NA
Size: Approximately 4 cm across (similar to real
cookies)
Odour: No
Taste: No
Texture/feel:
Wood is hard, smooth and painted. Polymer is
rippled slightly and has a glossy surface with a
slightly soft texture (but harder than a typical
eraser).
FprCEN/TR 18240:2025 (E)
Ref. Image Attributes, Reasoning and Discussion
Do not have the course surface texture and visual
detail of a real cookie.
(Note that although they are smaller than normal
cookies, some small cookie varieties are available,
so in this case size is considered a sufficient
reason)
1.11 Form: Small candy themed plastic
Colour: Various. The painted parts are glossy. The
underside (which is flat and undecorated) is matt.
Volume: NA
Size: Approximately 2 cm
Odour: No
Taste: No
Texture/feel: Hard polymer
Caricatures of candy items in their wrappers.
Do not imitate real and immediately edible candy.
1.12 Form: Small pizza themed plastic
Colour: Tan base with red painted toppings
Volume: NA
Size: Approximately 4,5 cm across (much smaller
than real pizza)
Odour: No
Taste: No
Texture/feel: Hard polymer
Smaller than real pizza without a realistic surface
texture, colour or sheen.
The separable section adds to the lack of realism.
FprCEN/TR 18240:2025 (E)
Ref. Image Attributes, Reasoning and Discussion
1.13 Form: Foam squishy with the size and shape of a
banana
Colour: Bright yellow with bright green painted
stalk
Volume: NA
Size: Approximately 20 cm long (similar to a real
banana)
Odour: No
Taste: No
Texture/feel: Foam squishy
Not an immediately edible food.
The yellow foam skin is semi-realistic but without
any darker markings usually seen on a real banana.
On closer view it is clearly foam.
The stalk is bright green and less similar to a real
banana.
It has a metal keyring attached.
Keychains and similar non-edible attachments are
very strong indicators of a non-food item.
1.14 Form: Miniature hard plastic tea and dinner sets
Colour: Flat, matt, monotone colours that are
relatively muted
Volume: NA
Size: The tray is approximately 10 cm long
Odour: No
Taste: No
Texture/feel: Hard polymer
Only a very passing similarity to food.
Miniature in size.
Fixed to accessories that do not imitate food.
Non-edible attachments are very strong indicators
of a non-food item.
FprCEN/TR 18240:2025 (E)
Ref. Image Attributes, Reasoning and Discussion
1.15 Form: Sweet scented modelling compound
Colour: Single colours in faded tones
Volume: Approximately 25 cm
Size: Container is approximately 4,5 cm diameter,
3 cm high
Odour: Purple is similar to an artificial sweet
grape scent. Yellow is sweet with a faint biscuity
smell.
Taste: No
Texture/feel: Malleable but holds form under its
own weigh
...
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