General Toy Safety Requirements in the Customs Union
Adopted by the CU member states in 2011, toy safety regulation CU TR 008/2011 came into force in 1 July, 2012. It sets specific safety requirements for toys, including:
- Materials used in the manufacturing process.
- Eurasian Conformity (EAC) marking.
- Technical documentation (product technical file).
What Constitutes a Toy in the Customs Union?
Toys produced, or imported and sold in the CU are defined by article 2 of TR CU 008/2011 as “an article or material intended for games of a child (children) under 14 years old”. This definition and the exclusions (items designed for use by this age group, but not regarded as toys) are broadly similar to those under the EU Toy Safety Directive 2009/48/EC.
Mandatory Certificate of Conformity for Toys in the Customs Union
Toys destined for CU member states (Russia, Kazakhstan or Belarus) require a TR CU Certificate of Conformity (CoC). To achieve certification, toys must be tested and certified by an independent third party, an accredited body within CU. Without TR CU certification, there will be no customs clearance.
Who Can Apply for the Certificate of Conformity?
Any company importing toys to the CU market must have a representative in the CU:
- The CoC is the new format valid for all Union countries.
- The CoC can be issued for one shipment, or for serial production (1 to 5 years).
- The expert of the accredited Certification Body (CB) signs the CoC, but the representative in CU is the official applicant for it. The manufacturer is mentioned on the certificate.
- The expert and the manufacturer are responsible for the quality of the toys. For serial production, onsite production inspection is required to monitor the certified product’s quality. Every year of validity of the CoC, 50% of the samples tested in the first year are retested.
Certification Process to Receive the Certificate of Conformity
STEP 1: Check the HS Code and toy description to confirm CoC is required.
STEP 2: Conformity assessment including documentation check, sample testing by CU lab, manufacturers auditing, labeling verification.
STEP 3: Check of CoC draft version. This step is important as the certificate cannot be modified, once registered in the CU system.
STEP 4: Issuance of final CoC. There are three schemes for toy certification:
- Scheme 1c: Applies to serially manufactured toys on the basis of product testing and a production (factory) audit.
- Scheme 2c: Applies to serially manufactured toys on the basis of product testing and certification of the toy production quality management system, conducted by a CU accredited certification body.
- Scheme 3c: Applies to a separate batch of toys. Manufacturers should apply for certification for toys manufactured within the CU. For imported toys, the importer should make the application, or the manufacturer’
When certifying toys under any of the above schemes, the manufacturer (or its authorized representative)
Accredited Body Rules for Toy Safety Testing
Only an accredited body, listed on the Union’s Unified Register of Certification Bodies and Testing Laboratories (centers) can conduct testing and conformity assessments. Testing laboratories outside the CU cannot help to achieve product certification. For example, a product launched in the EU may have undergone safety testing in a laboratory in China, but these results will not be valid for CU certification purposes.
All toys destined for the CU must meet requirements including:
- General safety.
- Physical and mechanical.
- Electric and electromagnetic compatibility (EMC).
- Hygiene (sanitary, toxicological and microbiological characteristics)
- Packaging and marking.
Toy Safety Requirements:
CU toy safety regulation is essentially based on the European toy safety requirements (EU toy directive 2009/46/ EC and the former 88/378/EEC). Some differences can be noted, including but not limited to:
- Physical characteristics:
- Chemical characteristics:
a) Additional phthalates are regulated.
b) Formaldehyde limits are specified whereas this topic is still under discussion within the EU.
c) Toxicological and microbiological characteristics have also different parameters.
Eurasian Conformity (EAC) Mark Required on the CU Market
In addition to meeting the above mentioned safety requirements, all toy products sold within the CU must qualify for, and display, the EAC Mark, the unified mark of conformity for products available within the CU’s member states. Applied directly to the product, its packaging, label, tag (including sewn-in tags), packaging insets and accompanying documentation the EAC Mark must be applied before a toy product is placed on the market. Toys not marked are not allowed on the CU market.
About SGS Services for Toys and Juvenile Products
SGS’ expertise in compliance management helps clients make the right choices to access the CU market, while carrying out the necessary testing and certification quickly and professionally. The company’s Russian subsidiary, SGS Vostok Limited, has full capability to support requests for toy testing (http://www.sgs.com/
Please do not hesitate to contact an SGS expert for further information.
SGS is the world’s leading inspection, verification, testing and certification company. SGS is recognized as the global benchmark for quality and integrity. With more than 80,000 employees, SGS operates a network of over 1,650 offices and laboratories around the world.