kSIST-TP FprCEN/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
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.
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
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.
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.
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.
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 wit
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