Children’s toys sold in the United Kingdom must comply with the Toys (Safety) Regulations 2011, which set safety requirements for such products. This includes physical and flammability requirements, substance restrictions, documentation, labelling, and more.
In this guide, we explain the key requirements of the regulations and address some common questions related to them. Note that this guide does not cover requirements affecting Northern Ireland, as Northern Ireland is generally aligned with the EU requirements for toys.
Content Overview
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What are the Toys (Safety) Regulations 2011?
The Toys (Safety) Regulations 2011 contain safety requirements for children’s toys, in order to protect the health of kids. Companies that import or manufacture such products in the UK must comply with requirements such as the following:
- UKCA marking and other labelling requirements
- Declaration of Conformity
- Technical documentation
- Product testing (e.g. against the requirements of EN 71 standards)
Note that the specific safety requirements would vary according to the product. For example, while some products may pose choking hazards due to small parts, other products may pose flammability hazards. Thus, the relevant requirements and tests would vary according to the product characteristics.
Which products are covered by the Toys (Safety) Regulations 2011?
The regulations cover toys and children’s products with play value designed for children under 14 years old. “Play value” means that the child can be expected to play with the product. An example of non-toy product that has play value could be a furniture item with a slide.
Here are some examples of products covered by the regulations:
- Activity toys
- Functional toys
- Aquatic toys
- Toys in food
- Roller skates
Exempted products
Here are some examples of products that are exempted from the regulations:
- Public playground equipment
- Public automatic playing machines
- Toy steam engines
- Babies’ soothers
- Products for collectors
Designated standards
In order to comply with the requirements of the regulations (e.g. mechanical requirements or substance restrictions), you generally need to comply with the requirements set by “designated standards”. Note that testing is generally required to prove compliance.
Here are the designated standards that we found on the Guidance page “Designated standards: toy safety:
EN 71-1 – Safety of toys – Part 1: Mechanical and physical properties
EN 71-2 – Safety of toys – Part 2: Flammability
EN 71-3 – Safety of toys – Part 3: Migration of certain elements
EN 71-4 – Safety of toys – Part 4: Experimental sets for chemistry and related activities
EN 71-5 – Safety of toys – Part 5: Chemical toys (sets) other than experimental sets
EN 71-7 – Safety of toys – Part 7: Finger paints – Requirements and test method
EN 71-8 – Safety of toys – Part 8: Activity toys for domestic use
EN 71-12 – Safety of toys — Part 12: N-Nitrosamines and N-nitrosatable substances
EN 71-13 – Safety of toys – Part 13: Olfactory board games, cosmetic kits and gustative games
EN 71-14 – Safety of toys – Part 14: Trampolines for domestic use
EN IEC 62115 – Electric toys – Safety
Conformity assessment procedures
In order to ensure that the toys comply with the requirements set by the regulations, one of the following procedures must be used:
a. Module A – It can only be used if the manufacturer has applied designated standards that cover all the relevant safety requirements
b. Modules B and C – It should be used if designated standards do not exist, they were not applied in full, they were published with restrictions, or the manufacturer deems that third-party verification is necessary.
Note that, in order to complete the conformity assessment procedure that includes modules B and C, it is necessary to hire a UK-approved body, which is a third party assessment body approved by the UK.
Declaration of Conformity
After confirming that the toy product meets the requirements of the regulations, a Declaration of Conformity must be created. The required structure for the declaration is contained in Schedule 3 of the regulations.
Here are some examples of the content that should be featured in the declaration:
- Manufacturer’s name
- Manufacturer’s address
- References to designated standards applied
- Image of the toy
Technical Documentation
Technical documentation must be arranged and contain all the relevant information listed in Schedule 4 of the regulations. The information will indicate how the manufacturer complies with the requirements of the regulations.
Here are some examples of the content that would be featured in the documentation:
- A copy of the Declaration of Conformity
- Place of manufacture and storage addresses
- A description of the conformity assessment procedure applied
Instructions
Under the regulations, toys must be accompanied by instructions and safety information (as appropriate). In general, the aim of providing instructions is to enable the child or his guardian to understand how the product should be used safely.
For example, toys which may be dangerous for kids aged 3 years old and below (e.g. because they contain small parts) may feature on their instructions for use a brief indication of the risks (e.g. small parts are a choking hazard) associated with the product.
UKCA and CE Marking
The regulations require a compliance mark to be featured with the toy product, which can either be the UKCA or the CE Marking.
The UKCA marking is required to be affixed on the toy product. Alternatively, the UKCA marking can be placed on the following areas:
- Label affixed to the toy
- Toy’s packaging
- Accompanying documents
Note that CE marking is currently accepted indefinitely in the UK because of the Product Safety and Metrology etc. (Amendment) Regulations 2024. Thus, products that comply with the relevant EU regulations and include the CE marking can be sold in the UK.
Both the UKCA and CE markings may be followed by a pictogram or by any other mark indicating a special risk or use.
Traceability labelling requirements
The regulations require the product to feature the following information for traceability purposes:
a. Product identifying information (e.g. type, batch, serial or model number)
b. Manufacturer’s name
c. Single address for contacting the manufacturer
The above information should be placed on the toy, its packaging or accompanying documents.
Warning requirements
Toys must specify user limitations and other warnings that are contained in Schedule 5 of the regulations. Here are some examples of required warnings:
- ‘Only for domestic use’ (for activity toys)
- ‘Be used under the direct supervision of an adult’ (for functional toys)
- ‘Toy inside. Adult supervision recommended’ (for toys in food)
Product testing
The toy should be tested against the relevant designated standards so that it complies with the regulations and is safe for play. Testing is generally done by sending the toy product to a third-party lab testing company.
If you pass testing, you can expect to receive a test report that can be used to demonstrate the toy’s compliance with the regulations.
Approved bodies for toys
Here we list some approved bodies that can assess your product against the requirements of the The Toys (Safety) Regulations:
- SGS United Kingdom Limited
- ITS Testing Services (UK) Ltd
- Eurofins MTS Consumer Product Testing UK Limited
- TUV Rheinland UK Ltd
FAQ
What are the differences between The Toys (Safety) Regulations 2011 and the Toy Safety Directive (EU)?
The Toys (Safety) Regulations regulations are based on the EU Toy Safety Directive because the UK was once a part of the EU. The table below provides an overview of the key differences between the two legislations.
Note that there may be more differences between the two in the future, as the regulations continue to be updated.
| Requirements | The Toys (Safety) Regulations 2011 (UK) Latest version: 01/10/2024 |
Toy Safety Directive (EU) Latest version: 05/12/2022 |
|
| Conformity assessment procedures | To assess whether the toy conforms with the requirements, one of the following procedures in regulation 13 must be used:
When modules B and C are used, a UK approved body must be engaged. |
One of the following procedures in Article 19 must be used:
When modules B and C are used, a Notified body located in the EU must be engaged. Note that the requirements in the modules may differ from the UK version. |
|
| Standards | The standards are called “designated standards”. | The standards are called “harmonsied standards”
The list of standards (e.g. EN 71-1) at the moment are the same as the UK’s list. However, this may change in the future. |
|
| Documentation requirements |
Note that there are differences with the content requirements (e.g. English should be used, etc) |
Note that there are differences in the content requirements (e.g. depending on where the product is sold, documentation should be translated to the relevant official language of the EU country). |
|
| Compliance marking | UKCA marking
Note that CE marking is also accepted in the UK. |
CE marking | |
| Traceability labelling requirements |
|
|
|
| Warning requirements | Specify appropriate user limitations and warnings from Schedule 5.
Note that English must be used. |
Specify appropriate user limitations and warnings from Annex V.
Depending on where the toy is sold, the warnings should be translated into the relevant official language of the EU country. |
|
| Authorised representative | If appointed, must be established in the UK | If appointed, must be established in the EU.
Note that non-EU manufacturers must appoint an authorised representative located in the EU because of the Market Surveillance Regulation. |
|
Is EN 71 accepted in the UK?
Yes, the EN 71 safety standards are accepted in the UK. The toys should be tested against them as they are designated standards under the regulations.
Can CE-marked toys be sold in the UK?
Yes, due to the Product Safety and Metrology etc. (Amendment) Regulations 2024, CE-marked toys are accepted indefinitely. Thus, businesses whose products comply with the relevant EU requirements and contain the CE marking can be sold in the UK.
Can UKCA-marked toys be sold in the EU?
The UKCA marking is not recognised in the EU. Thus, toys intended to be sold in the EU must comply with the relevant EU regulations and directives and contain the CE marking.
