SIST-TP CEN/TR 15371-1:2021
(Main)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
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 document is to provide replies to requests for interpretations of EN 71 1:2014+A1:2018, Safety of toys - Part 1: Mechanical and physical properties, EN 71 2:2020, Safety of toys - Part 2: Flammability, EN 71 8:2018, Safety of toys - Part 8: Activity toys for domestic use and EN 71 14:2018 and 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
Der Zweck dieses Dokuments ist, Antworten auf Anfragen zu Interpretationen von EN 71 1:2014+A1:2018, Sicherheit von Spielzeug — Teil 1: Mechanische und physikalische Eigenschaften, EN 71 2:2020, Sicherheit von Spielzeug — Teil 2: Entflammbarkeit, EN 71 8:2018, Sicherheit von Spielzeug — Teil 8: Aktivitätsspielzeug für den häuslichen Gebrauch, und EN 71 14:2018, Sicherheit von Spielzeug — Teil 14: Trampoline für den häuslichen Gebrauch, bereitzustellen.
Sécurité des jouets - Interprétations - Partie 1: Réponses aux demandes dinterprétation 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
General Information
Relations
Standards Content (Sample)
SLOVENSKI STANDARD
01-julij-2021
Nadomešča:
SIST-TP CEN/TR 15371-1:2017
Varnost igrač - Razlaga - 1. del: Odgovori na zahteve po razlagi standardov EN 71-
1, EN 71-2, EN 71-8 in EN 71-14
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 dinterprétation
de EN 71-1, EN 71-2, EN 71-8 et EN 71-14
Ta slovenski standard je istoveten z: CEN/TR 15371-1:2021
ICS:
97.200.50 Igrače Toys
2003-01.Slovenski inštitut za standardizacijo. Razmnoževanje celote ali delov tega standarda ni dovoljeno.
CEN/TR 15371-1
TECHNICAL REPORT
RAPPORT TECHNIQUE
April 2021
TECHNISCHER BERICHT
ICS 97.200.50 Supersedes CEN/TR 15371-1:2017
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 19 April 2021. 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, Turkey and
United Kingdom.
EUROPEAN COMMITTEE FOR STANDARDIZATION
COMITÉ EUROPÉEN DE NORMALISATION
EUROPÄISCHES KOMITEE FÜR NORMUNG
CEN-CENELEC Management Centre: Rue de la Science 23, B-1040 Brussels
© 2021 CEN All rights of exploitation in any form and by any means reserved Ref. No. CEN/TR 15371-1:2021 E
worldwide for CEN national Members.
Contents Page
European foreword . 5
0 Introduction . 6
1 Scope . 8
2 Normative references . 8
3 Terms and definitions . 8
4 EN 71-1:2014+A1:2018, Safety of toys – Part 1: Mechanical and physical properties . 8
4.1 3.6 Ball (interpretation) . 8
4.2 3.13 Cord (no action decision) . 9
4.3 3.36 Fuzz (no action decision) . 10
4.4 3.38 Hinge line and 4.10.3 Hinges (no action decision) . 11
4.5 3.39 Large and bulky toy (interpretation) . 12
4.6 3.54 and 3.55 Projectile toys (no action decision) . 14
4.7 3.54 and 3.55 Projectile toys (no action decision) . 15
4.8 3.61 Definition of soft filled toys (no action decision) . 16
4.9 4.9 Protruding parts (interpretation) . 16
4.10 4.10.1 c) folding and sliding mechanisms (no action decision) . 17
4.11 Mouth-actuated toys and other toys intended to be put in the mouth (interpretation) . 18
4.12 4.14.2 Masks and helmets (no action decision) . 19
4.13 4.15.1.2 Warnings and instructions for use (no action decision) . 20
4.14 4.15.1.4 Stability (interpretation) . 21
4.15 4.15.1.4; 8.23.1 Stability (interpretation) . 21
4.16 4.15.1.4 Stability (no action decision) . 24
4.17 4.15.1.6 c) Transmission and wheel arrangement (no action decision) . 26
4.18 4.15.5.7 Toy scooters – protruding parts (interpretation) . 27
4.19 4.17 Projectile toys (no action decision) . 27
4.20 4.19 Percussion caps (no action decision) . 28
4.21 4.20 Acoustics (Re: percussion toys) (no action decision) . 28
4.22 Acoustics (interpretation) . 29
4.23 4.20 Acoustics (interpretation) . 30
4.24 4.20 Acoustics (interpretation) . 30
4.25 4.20 Acoustics (no action decision) . 31
4.26 Acoustics (interpretation) . 32
4.27 Acoustics (interpretation) . 33
4.28 4.20 Acoustics (interpretation) . 33
4.29 4.20 Acoustics (interpretation) . 34
4.30 4.20 Acoustics (interpretation) . 35
4.31 4.20 Acoustics (interpretation) . 35
4.32 4.20 Acoustics (interpretation) . 36
4.33 4.20 Acoustics (interpretation) . 37
4.34 Clause 5 Toys intended for children under 36 months (re: inflatable toys)
(interpretation) . 38
4.35 General requirements (re: small parts) (interpretation) . 38
4.36 5.1 General requirements (re: small parts) (interpretation) . 39
4.37 5.1 General requirements (re: fuzz) (no action decision) . 39
4.38 5.1 General requirements (re: plastic whiskers) (interpretation). 39
4.39 5.1 General requirements (no action decision) . 40
4.40 5.1 General requirements (no action decision) . 41
4.41 5.1 General requirements (no action decision) . 42
4.42 5.1 General requirements (interpretation) . 42
4.43 5.1 e) General requirements (re: glued wooden toys) (no action decision) . 44
4.44 5.1 e) General requirements (re: varnish) (interpretation) . 44
4.45 5.2 Soft-filled toys and soft-filled parts of a toy (no action decision) . 45
4.46 5.4.2.1 Cords and chains with the potential to tangle and 5.4.4 Fixed loops, tangled
loops and nooses (no action decision) . 45
4.47 5.7 Glass and porcelain (interpretation) . 47
4.48 5.8 Shape and size of certain toys (re: accessibility) (interpretation) . 47
4.49 5.8 Shape and size of certain toys (interpretation) . 47
4.50 5.8 Shape and size of certain toys (re: squeeze toys) (no action decision) . 48
4.51 Shape and size of certain toys (interpretation) . 48
4.52 5.8 Shape and size of certain toys (no action decision) . 49
4.53 5.10 Small balls (no action decision) . 50
4.54 5.12 Hemispheric-shaped toys (no action decision) . 53
4.55 Clause 6 Packaging (no action decision) . 54
4.56 7.1 Warnings, markings and instructions for use – General (no action decision) . 54
4.57 7.1 Warnings, markings and instructions for use – General (no action decision) . 55
4.58 7.1 and 7.2 Warnings, markings and instructions for use: general and toys not
intended for children under 36 months (no action decision) . 56
4.59 7.2 Toys not intended for children under 36 months and 7.3 latex balloons (re:
warning) (no action decision) . 56
4.60 7.12 Liquid-filled teethers (interpretation) . 57
4.61 8.4.2.2 Tension test - Seams and materials (interpretation) . 57
4.62 8.4.2.2 Tension test - Seams and materials (interpretation) . 58
4.63 8.5 Drop test and 8.7 Impact test (interpretation) . 59
4.64 8.13 Flexibility of metallic wires (no action decision) . 59
4.65 8.18.2.b) Folding or sliding mechanisms – Toy pushchairs and perambulators
(interpretation) . 59
4.66 8.23.1 Stability – Toys intended to bear the mass of a child (no action decision) . 60
4.67 8.25.1.1 Plastic sheeting - apparatus (interpretation). 61
4.68 8.28.2 Test procedures (re: acoustics) (no action decision) . 63
4.69 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) . 63
4.70 8.28.2.2.3, 8.28.2.5.3 Operating conditions and measurements (re: acoustics) (no
action decision) . 64
4.71 8.28.2.7.3 Operating conditions and measurements (re: acoustics) (interpretation) . 65
4.72 8.28.2.9.3 Operating conditions and measurements (re: acoustics) (no action
decision). 65
4.73 8.28.2.11 Voice toys (re: acoustics) (Interpretation) . 65
4.74 8.28.2.11.4 Voice toys – measurement results (interpretation) . 67
4.75 General interpretation and guidance document for the application of the acoustic
requirements from EN 71-1:2014+A1:2018 . 67
4.76 8.40 Length of cords, chains and electrical cables (no action decision) . 74
5 EN 71-2:2020, Safety of toys — Part 2: Flammability . 75
5.1 4.2.2 Beards, moustaches, wigs etc., . (interpretation) . 75
5.2 4.2.5 Toys to be worn on the head . and 4.3 Toy disguise costumes . (no action
decision). 75
6 EN 71-8:2011, Safety of toys — Part 8: Activity toys for domestic use . 76
6.1 3.1 Activity toy (no action decision) . 76
6.2 4.2.1 Barriers and handrails preventing the child from falling down (no action
decision) . 77
6.3 4.3.1 Head and neck entrapment (no action decision) . 78
6.4 4.3.1 a) Head and neck entrapment (no action decision) . 78
6.5 4.3.2 Entrapment of clothing and hair (no action decision) . 78
6.6 4.6.7 Suspension connectors and swing devices (no action decision) . 79
6.7 4.6.8.3 Geometry and design of swing elements (no action decision) . 81
Bibliography . 82
European foreword
This document (CEN/TR 15371-1:2021) 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 shall not be held responsible for identifying any or all such patent rights.
This document supersedes CEN/TR 15371-1:2017.
Some of the previous interpretations and no action decisions have been deleted or modified, as due to
amendments to the corresponding EN 71 standards, answers have become obsolete.
CEN/TR 15371, Safety of toys — Interpretations, is currently composed of 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 document contains replies to requests for interpretations concerning the understanding of clauses
in EN 71-1:2014+A1:2018, EN 71-2:2020, EN 71-8:2018 and EN 71-14:2018. 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 document is to provide replies to requests for interpretations of EN 71-
1:2014+A1:2018, Safety of toys — Part 1: Mechanical and physical properties, EN 71-2:2020, Safety of
toys — Part 2: Flammability, EN 71-8:2018, Safety of toys — Part 8: Activity toys for domestic use and
EN 71-14:2018 and Safety of toys — Part 14: Trampolines for domestic use.
2 Normative references
There are no normative references in this document.
3 Terms and definitions
No terms and definitions are listed in this document.
ISO and IEC maintain terminological databases for use in standardization at the following addresses:
— IEC Electropedia: available at http://www.electropedia.org/
— ISO Online browsing platform: available at https://www.iso.org/obp
4 EN 71-1:2014+A1:2018, Safety of toys – Part 1: Mechanical and physical
properties
4.1 3.6 Ball (interpretation)
Question
The definition of a ball according to 3.6 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)
4.2 3.13 Cord (no action decision)
Question
The question relates to 3.13 “cord” of EN 71-1:2014+A1:2018.
The standard defines cord as:
“narrow piece of flexible textile or non-textile material of which the length is significantly greater than
its thickness and width
EXAMPLES Examples of cords include 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 4 and the toy of Figure 6 are soft filled, while the tail of
Figure 5 is not soft filled, therefore 5.4 is applicable only to the tail of Figure 5. 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 5 is considered a cord because there is not stuffing material inside.
REQ 104-12 (UNI, Italy)
4.3 3.36 Fuzz (no action decision)
Question
The question relates to 3.36 “fuzz” of EN 71-1:2014+A1:2018.
Some soft filled toys may have fur with long hair, even longer than 50 mm. We do not know if such hair
is considered as monofilament fibre.
If the toy loses such hair when petted (as per foreseeable use), as in the attached picture, even in great
amount, is it correct to consider them as 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)
4.4 3.38 Hinge line and 4.10.3 Hinges (no action decision)
Question
A toy truck has a hinged container. The container opens and closes similar to a lid or door. The weight
of the container is more than 250 g. There is a gap along the hinge line where a 5 mm rod can be
inserted, but it does not allow the 12 mm rod to be inserted when closing the container.
Is the gap shown in the red rectangle a hinge line as defined in 3.38?
Is 4.10.3 applicable?
Figure 9
Figure 10
The location of the hinge is indicated below with red dots:
Figure 11
Reply
Standard is clear. 3.38 of EN 71-1:2014+A1:2018 defines a hinge line as:
“line along or parallel to the line projected through the axis of rotation…”
The line in the red rectangle as described in the above pictures is parallel to the line projected through
the axis of rotation and is therefore considered as a hinge line. 4.10.3 of EN 71-1:2014+A1:2018 applies.
REQ 160-18 (NEN - Netherlands)
4.5 3.39 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+A1:2018?
Here are two possible ways. Option A or Option B (see drawings below)?
OptionA: global volume calculation
Option B : follow the shape to calculate volume
Toy 1
Figure 12
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)
4.6 3.54 and 3.55 Projectile toys (no action decision)
Question
EN 71-1 has the below definitions of projectiles with or without stored energy:
3.54
projectile toy with stored energy
toy with a projectile launched by means of a discharge mechanism capable of storing energy
independent from the user and incorporating a mechanism
3.55
projectile toy without stored energy
toy with a projectile launched by the energy imparted by the user or by any means of a discharge
mechanism incapable of storing energy independent of the user
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 3.55. However,
the toy is obviously also not within 3.54 because we interpret 3.54 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 3.55 even if a spring is used in launching the projectile.
Figure 13
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)
4.7 3.54 and 3.55 Projectile toys (no action decision)
Question
a) EN 71-1 defines as projectile an “object intended to be launched, thrown or released 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)?
Reply
a) 1) Standard is clear those toys are covered by the projectile's definition.
a) 2) Standard is clear those toys covered by the projectile's definition.
a) 3) Standard is clear those objects are covered by the projectile's definition (the catapults being
themselves toys excluded from the scope of EN 71-1).
b) Standard is clear this is a “projectile toy without stored energy” (see 3.55 definition) provided the
described item is not regarded as a catapult and therefore enters into the exclusion list as outlined into
EN 71-1:2014+A1:2018, Scope.
REQ 076-07 Part 1 (UNI, Italy)
4.8 3.61 Definition of soft filled toys (no action decision)
Question
Is the definition of a soft-filled toy including for example a foam toy (e.g. a so-called squishy or other
foam toys made out of one material), which is typically unclothed, with soft body surfaces and filled
with a soft material and is compressible with a hand?
Figure 14 Figure 15
Reply
Standard is clear - EN 71-1+ A1 provides the following definitions:
“3.61 soft-filled toy
toy, clothed or unclothed, with soft body surfaces and filled with soft materials, readily allowing
compression of the main part of the toy with the hand“
“3.26 filling
material intended to be wholly contained within a soft-filled toy or within soft-filled parts of a toy“
Since the definition from 3.61 requires a toy is filled with filling to be considered a soft-filled toy, and
since the foam toys described in the above request are made of only one soft material, they are not
regarded as soft-filled toys for the purpose of the EN 71-1:2014+A1:2018 standard.
REQ 166-19 (DS, Denmark)
4.9 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 16
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 toys for children over the age of 3 years, there is no
requirement asking for the application of such a force.
REQ 129-12 (SIS, Sweden)
4.10 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 17
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)
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 71-1:2014+A1:2018,
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 18 Figure 19 Figure 20 Figure 21
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 22 Figure 23 Figure 24
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)
4.12 4.14.2 Masks and helmets (no action decision)
Question
1) 4.14.2 of EN 71-1:2014+A1:2018 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
provide a total ventilation area of 1 300 mm or more through at least two holes at least 150 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 25 Figure 26 Figure 27
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)
4.13 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 4.15.1.4 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).
Where a toy is not required by the requirement of this clause to bear the warning referenced in 7.10.3,
do you remove the reference to protective equipment or the warning as a whole?
Reply
Standard is clear. When the labelling requirement related to protective equipment from 7.10.3 does not
apply, the required labelling is:
“Warning. Not to be used in traffic”.
REQ 124-12 (BSI, United Kingdom)
4.14 4.15.1.4 Stability (interpretation)
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?
Reply
This toy shall be considered as toy where the feet of the child can provide sideways stability and
therefore excluded from the 4.15.1.4 requirements. The fore and aft stability however remains
applicable.
REQ 046-04 (AENOR, Spain)
4.15 4.15.1.4; 8.23.1 Stability (interpretation)
Question (UNI, Italy)
EN 71-1 requires, for the stability test, to “load the toy in the most onerous position with a mass […] on
its standing or sitting surface”.
Our interpretation of this requirement is “Load the toy in the most onerous position on the standing or
sitting surface, in such a way the mass is perpendicular to the standing or sitting surface and that the
vertical projection of the base of the test mass is fully enclosed in the sitting surface. If the standing or
sitting surface is narrower than the test mass, the centre of the test mass shall be positioned along the
axis of the seat.”
Applying this interpretation, a correct position to place the test mass for the front stability is shown in
the following pictures (please, do not consider the position of the toy on the inclined plane, it is just an
example).
a) b) c)
Figure 28
If we do not apply this interpretation every laboratory can try to find any improbable sitting surface like
in the following examples:
a) b) c)
d) e) f)
g) h) i)
Figure 29
We consider that all the above examples represent a not correct way to perform the test: in the first row
example, the mass is not perpendicular to the sitting surface, in the second and in the third rows, the
mass base is outside the sitting surface.
In the third row, someone can argue that the ring allows the placing of the mass without any external
support, but if we consider applying this interpretation, we will again have problems. Actually, EN 71-
1:2014+A1:2018, Figure 29 does not define the sides of the test mass. Since the test mass does not need
to be a perfect cylinder, also the test mass for the dynamic test defined in Figure 32 may be used. Since
the position of the test mass on ride on toys with armrest may be significantly influenced (if we agree
with this interpretation) by the sides of the test mass, we will have for sure different test results,
depending on the kind of the test mass used.
a) b) c)
Figure 30
We can also have even more improbable test conditions like the following:
a) b) c)
Figure 31
According to our opinion, the correct interpretation is “load the toy in the most onerous position on the
standing or sitting surface, in such a way the mass is perpendicular to the standing or sitting surface
and that the vertical projection of the base of the test mass is fully enclosed in the sitting surface. If the
standing or sitting surface is narrower than the test mass, the centre of the test mass shall be positioned
along the axis of the seat”. Thus between the two positions shown in the following examples, in case we
are considering the frontal stability, it is the second (the one with the test mass with its base in contact
with the front edge of the seat) to be considered as the most onerous condition (in the other one, the
test mass is just centred on the seat, and thus this is not the most onerous position). Nevertheless,
allowing laboratories to place the mass with its base outside the sitting surface would lead to have no
more repeatable tests.
a) b) c)
d) e) f)
Figure 32
Question (BSI, United Kingdom)
The clause states “Load the toy in the most onerous position” Can this be clarified as to whether the
weight/mass is loaded in the most onerous position or the toy is placed in the most onerous position
with the test mass located in the “normal” position of use?
Comments/proposal for an answer: Believed that the test mass should be placed on the seat (or
standing position) to the extremity of the seat, but within the confines of the seat, i.e. not overhanging
the seat.
Also, the test mass should remain perpendicular to the plane of the seat, when placed on the 10° slope.
Reply to both the UNI and BSI questions
Before placing the toy on the slope, the mass shall be placed on the sitting or standing surface so that
the main axis of the mass remains as close as vertical as possible without any additional support
between the mass and the sitting or standing surface. If the sitting or standing surface is larger than the
base of the test mass, the test shall be performed placing the mass on the sitting or standing surface in
the most onerous position(s) with reg
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