SIST-TP CEN/TR 15371:2006
(Main)Safety of toys - Replies to requests for interpretation of EN 71-1, EN 71-2, and EN 71-8
Safety of toys - Replies to requests for interpretation of EN 71-1, EN 71-2, and EN 71-8
The purpose of this CEN Technical Report is to provide replies to requests for interpretations of
EN 71-1:2005, Safety of toys - Part 1: Mechanical and physical properties (under publication),
EN 71-2:2006, Safety of toys - Part 2: Flammability,
EN 71-8:2003, Safety of toys - Part 8: Swings, slides and similar activity toys for indoor and outdoor family domestic use.
NOTE The clause references to EN 71-1 are to the 2005-edition. If the clause number is different from the 1998-edition, the clause number of EN 71-1:1998 is also indicated.
The clause references to EN 71-2 are to the 2006-edition. If the clause number is different from the 2003-edition, the clause number of EN 71-2:2003 is also indicated.
Sicherheit von Spielzeug - Antworten auf Anfragen zur Interpretation von EN 71-1, EN 71-2 und EN 71-8
Der Zweck dieses Technischen Berichts des CEN ist, Antworten auf Anfragen zur Interpretation von
EN 71-1:2005, Sicherheit von Spielzeug Teil 1: Mechanische und physikalische Eigenschaften (im Prozess der Veröffentlichung),
EN 71-2:2006, Sicherheit von Spielzeug Teil 2: Entflammbarkeit,
EN 71-8:2003, Sicherheit von Spielzeug Teil 8: Schaukeln, Rutschen und ähnliches Aktivitätsspielzeug für den häuslichen Gebrauch (Innen- und Außenbereich)
bereitzustellen.
ANMERKUNG Die Verweisungen auf die Abschnitte von EN 71 1 stammen aus der Ausgabe von 2005. Ist die Nummer des Abschnittes anders als die der Ausgabe von 1998, ist die Nummer des Abschnittes von EN 71 1:1998 auch angege¬ben.
Die Verweisungen auf die Abschnitte von EN 71 2 stammen aus der Ausgabe von 2006. Ist die Nummer des Abschnittes anders als die der Ausgabe von 2003, ist die Nummer des Abschnittes von EN 71 1:2003 auch angegeben.
Sécurité des jouets - Réponses aux demandes d'interprétation de l'EN 71-1, EN 71-2 et EN 71-8
Varnost igrač – Odgovori na zahteve po interpretaciji standardov EN 71-1, EN 71-2 in EN 71-8
General Information
Relations
Standards Content (Sample)
SLOVENSKI STANDARD
SIST-TP CEN/TR 15371:2006
01-oktober-2006
9DUQRVWLJUDþ±2GJRYRULQD]DKWHYHSRLQWHUSUHWDFLMLVWDQGDUGRY(1(1
LQ(1
Safety of toys - Replies to requests for interpretation of EN 71-1, EN 71-2, and EN 71-8
Sicherheit von Spielzeug - Antworten auf Anfragen zur Interpretation von EN 71-1, EN 71
-2 und EN 71-8
Sécurité des jouets - Réponses aux demandes d'interprétation de l'EN 71-1, EN 71-2 et
EN 71-8
Ta slovenski standard je istoveten z: CEN/TR 15371:2006
ICS:
97.200.50 ,JUDþH Toys
SIST-TP CEN/TR 15371:2006 en
2003-01.Slovenski inštitut za standardizacijo. Razmnoževanje celote ali delov tega standarda ni dovoljeno.
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TECHNICAL REPORT
CEN/TR 15371
RAPPORT TECHNIQUE
TECHNISCHER BERICHT
June 2006
ICS 97.200.50
English Version
Safety of toys - Replies to requests for interpretation of EN 71-1,
EN 71-2, and EN 71-8
Sécurité des jouets - Réponses aux demandes Sicherheit von Spielzeug - Antworten auf Anfragen zur
d'interprétation de l'EN 71-1, EN 71-2 et EN 71-8 Interpretation von EN 71-1, EN 71-2 und EN 71-8
This Technical Report was approved by CEN on 16 April 2006. It has been drawn up by the Technical Committee CEN/TC 52.
CEN members are the national standards bodies of Austria, Belgium, Cyprus, Czech Republic, Denmark, Estonia, Finland, France,
Germany, Greece, Hungary, Iceland, Ireland, Italy, Latvia, Lithuania, Luxembourg, Malta, Netherlands, Norway, Poland, Portugal, Romania,
Slovakia, Slovenia, Spain, Sweden, Switzerland and United Kingdom.
EUROPEAN COMMITTEE FOR STANDARDIZATION
COMITÉ EUROPÉEN DE NORMALISATION
EUROPÄISCHES KOMITEE FÜR NORMUNG
Management Centre: rue de Stassart, 36 B-1050 Brussels
© 2006 CEN All rights of exploitation in any form and by any means reserved Ref. No. CEN/TR 15371:2006: E
worldwide for CEN national Members.
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CEN/TR 15371:2006 (E)
Contents Page
Foreword.3
Introduction.4
1 Scope.5
2 EN 71-1:2005 - Safety of toys – Part 1: Mechanical and physical properties .5
2.1 4.5 Glass (no action decision).5
2.2 4.14.2 Masks and helmets (no action decision).5
2.3 4.15.1.4 Stability (interpretation) .7
2.4 4.15.1.6 c) Transmission and wheel arrangement (no action decision).7
2.5 4.15.1.6 d) Transmission and wheel arrangement (no action decision) .8
2.6 4.17 Projectiles (no action decision) .9
2.7 5 Toys intended for children under 36 months (re: inflatable toys) (interpretation) . 11
2.8 5.1 General requirements (re: small parts) (interpretation). 11
2.9 5.1 General requirements (re: fuzz) (no action decision) . 12
2.10 5.2 Filling materials (interpretation). 12
2.11 5.4 Cords on toys (no action decision) . 12
2.12 5.7 Glass and porcelain (interpretation). 13
2.13 5.8 Shape and size of certain toys (re: accessibility) (interpretation). 13
2.14 5.8 Shape and size of certain toys (interpretation) . 13
2.15 6 Packaging (no action decision). 14
2.16 8.4.2.2 Seams and materials (interpretation) . 14
2.17 8.13 Flexibility of wires (no action decision) . 14
2.18 8.28.1.4 Operating conditions (re: acoustics) (interpretation) . 14
2.19 8.28.2.4.3 Measurement results (re: acoustics) (interpretation) . 15
2.20 8.28.1.3 Mounting (re: acoustics) (no action decision). 15
3 EN 71-2:2006 - Safety of toys – Part 2: Flammability . 15
3.1 4.2.2 Beards, moustaches, wigs etc., . (interpretation) . 15
3.2 4.2.5 Flowing elements of toys . and 4.3 Toy disguise costumes . (interpretation) . 16
4 EN 71-8:2003 - Safety of toys – Part 8: Swings, slides and similar activity toys for indoor
and outdoor family domestic use . 16
4.1 4.3.1 Head and neck entrapment. 16
4.2 4.3.2 Entrapment of clothing and hair (no action decision) . 16
4.3 6.1 Stability (no action decision). 17
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CEN/TR 15371:2006 (E)
Foreword
This Technical Report (CEN/TR 15371:2006) has been prepared by Technical Committee CEN/TC 52 “Safety
of toys”, the secretariat of which is held by DS.
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CEN/TR 15371:2006 (E)
Introduction
Interpretations and no-action decisions
This Technical Report contains replies to requests for interpretation with regard to the understanding of
clauses in EN 71-1, EN 71-2 and EN 71-8. 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 shall only be regarded as a clarification of the meaning of the
standard.
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.
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 TC 52 working party which
will 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
the wording of the standard
the rationale of the standard
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 CEN/TR 15371, which will be updated on a regular
basis.
Proposals for amendments will be progressed as new work item proposals in accordance with CEN rules.
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.
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CEN/TR 15371:2006 (E)
1 Scope
The purpose of this CEN Technical Report is to provide replies to requests for interpretations of
EN 71-1:2005, Safety of toys – Part 1: Mechanical and physical properties (under publication),
EN 71-2:2006, Safety of toys – Part 2: Flammability,
EN 71-8:2003, Safety of toys – Part 8: Swings, slides and similar activity toys for indoor and outdoor family
domestic use.
NOTE The clause references to EN 71-1 are to the 2005-edition. If the clause number is different from the 1998-
edition, the clause number of EN 71-1:1998 is also indicated.
The clause references to EN 71-2 are to the 2006-edition. If the clause number is different from the 2003-edition, the
clause number of EN 71-2:2003 is also indicated.
2 EN 71-1:2005 - Safety of toys – Part 1: Mechanical and physical properties
2.1 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 toys (e.g. optical toys, glass light bulbs, glass in experimental
sets.
Traditionally there are quite 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 a candle making set as functional?
2. What about a glass painting set intended to decorate glass objects?
Reply: The nature and use of this product (involving candles) means that EN 71 cannot address the
safety. If this product was 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)
2.2 4.14.2 Masks and helmets (no action decision)
Question: 1) The standard EN 71-1:1998 – Safety of toys – Part 1 mechanical and physical properties, in
the subclause 4.14.2 states the following about masks:
“4.14.2 Masks and helmets
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CEN/TR 15371:2006 (E)
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
2
shall provide a total ventilation area of 1300 mm minimum through at least two holes at least
150 mm apart or through any equivalent single ventilation area.”
We understand reading this point that the requirements are for application to all types of masks.
Nevertheless, there are several types of masks in the market according to their design and their
material:
a) 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.)
b) 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).
c) Masks that only enclose the face.
The last ones have several designs, some 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 asphyxia that could happen to the children when using
the masks), we have a doubt regarding the last type of masks (mask c )), which enclose only the
face, because it is likely that not all the mentioned masks could present the risk of asphyxia.
Therefore, there could be type c ) masks that could not need to fulfil the requirements on 4.14.2
a)
Examples of type c) masks:
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CEN/TR 15371:2006 (E)
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 clause 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 be fulfilled.
REQ 048-04 (AENOR)
2.3 4.15.1.4 Stability (interpretation)
(4.15.1.3 in EN 71-1:1998)
Question: Is the lateral stability test applicable to a two wheels toy motorbike intended for children over 3
years of age, for which removable stabilizers are provided, considering that the toy can be
operated by the child when stabilizers are removed?
Interpretation: This toy shall be considered as a toy where the feet of the child can provide sideways stability
and is therefore excluded from the 4.15.1.3 requirements.
REQ 046-04 (AENOR) – I EN 71-1 010
2.4 4.15.1.6 c) Transmission and wheel arrangement (no action decision)
(4.15.1.5 c) in EN 71-1:1998)
Question: During testing of a battery operated ride on car (shown below) it was noted that there was a gap
of approximately 6 mm between a wheel and the adjacent motor housing (see illustration).
It is clear from 4.15.1.5 c) of EN 71-1 that the product fails:
Text of Standard
c) Spaces between the wheels and the body or parts of the body (e.g. mudguards) shall, if they
allow a 5 mm diameter rod to be inserted, also allow a 12 mm diameter rod to be inserted.
Is this an accurate understanding of the standard?
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CEN/TR 15371:2006 (E)
View of back of car 5mm plug gauge inserted in gap
The UK committee agreed that the product apparently failed the technical requirements of
clause 4.15.1.5c of EN 71-1:1998 and that that clause was applicable to the toy in question and
has asked me to forward this enquiry to CEN TC52/WG3/TG1 for a further interpretation and
action as necessary.
Reply: The standard adequately treats this case. The 5/12 mm requirement only applies to areas
capable of crushing fingers or other parts of the body if entrapped considering the normal and
foreseeable use of the toy. Reference is made to Annex C, second sentence of clause C.19 for
1998 version and Annex A, second sentence of clause A.20 for the 2005 version : “ .the
requirements…. also refer to hazards involving chain transmissions and wheel arrangements
capable of crushing fingers and other parts of the body if entrapped”
REQ 054-05 (BSI)
2.5 4.15.1.6 d) Transmission and wheel arrangement (no action decision)
(4.15.1.5 d) in EN 71-1:1998)
Question: Clause 4.15.1.5 d) states:
“Tricycles, provided with an attached handle used for pushing the child, shall be constructed in
such a way as to prevent entrapment of the child’s feet in the pedals, etc whilst being pushed,
for example a free-wheeling mechanism or foot rests.”
If a free-wheeling mechanism is present, clause 4.15.1.4 requires a mechanically propelled toy
to have a braking device.
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CEN/TR 15371:2006 (E)
It is very difficult for a manufacturer to add a brake to a tricycle. Therefore, one possible solution
(in my opinion) is to manufacture the tricycle with the option of having the front wheel (with
pedals) set as either a fixed wheel or free-wheeling, with accompanying instructions clearly
informing the parent to set it as free-wheeling if the parent handle is attached, or fixed wheel if
the handle is not attached. (I have seen several like this on the market).
However, clause 4.15.1.4 excludes “toys where the feet provide the motive power to the driving
wheel via direct transmission (e.g. tricycles).”
It is our belief that this exclusion was written prior to the addition of clause 4.15.1.5 d) in the
1998 edition, when all tricycles were of the traditional fixed wheel design. This exclusion is
therefore, in my opinion, not valid if the tricycle has a free-wheel mode.
C.19 also excludes tricycles with pedals on the front wheel, but again, I believe this rationale
was written with only fixed wheel tricycles in mind.
The point here is that a retailer wishes to supply a free-wheeling tricycle with a parent handle
and no brake. If the parent handle is removed, the child will be riding a free-wheeling toy with no
means of braking, usually performed by the child putting his feet on the pedals. (I do not hold
with a suggested view that the child can brake the tricycle by putting his feet on the ground,
since this is likely to lead to foot entrapment by the frame or rear wheels. Remember that clause
4.15.1.5 d) requires a tricycle with a parent handle to have foot rests, for example, for the very
reason of keeping the child’s feet away from moving parts).
Would the group agree that the exclusion in clause 4.15.1.4 is not valid in this instance?
Reply: The standard, as it is currently, adequately addresses this case. This kind of toy would require a
brake. However, TG 1 recommends TC 52/WG 3/TG 6 – Bicycles, scooters and ride-on toys to
consider this request and associated concerns.
REQ 055-05 (BSI)
2.6 4.17 Projectiles (no action decision)
Question: Our question is that whether the toy product said to be DRONE (containing plastic darts with
resilient material point and a plastic target, and the darts are designed to be thrown by hand of a
child upon the target) is considered as a “projectile toy” according to the given definition in EN 71.
Or simply to say that the question is whether a toy intended to be thrown by hand of a child but
not to be launched by a mechanism is considered as a “projectile” according to EN 71.
The following are the relevant clauses of EN 71:
3.28 projectile: Object intended to be launched into free flight, or a trajectory, in the air.
3.29 projectile toy with stored energy: Toy with a projectile propelled by means of a discharge
mechanism cable of storing and releasing energy.
3.30 proje
...
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