New EU Toy Directive Focuses on Strict Product Documentation

Awaiting implementation in July 2011, the new EU 2009/48/EC Toy Safety Directive (TSD) realises the European Parliament demand for greater technical documentation and further responsibilities for toy manufacturers and importers.
By: SGS Consumer Testing
April 4, 2011 - PRLog -- Manufacturers to Shoulder Toy Responsibilities

The EU 2009/48/EC Toy Directive includes greater technical documentation responsibilities, including the requirement that manufacturers draft an EC declaration of conformity (DoC) for each product they release in the European market. In addition, manufacturers must keep each DoC and all other technical documentation on file for ten years after their product has been released on the market. As expected, product instructions and safety information is mandatory for inclusion.

The responsibilities assigned to manufacturers don’t stop there. Products must now be marked with the name and address of the manufacturer and importer, the product type, batch and serial number and CE mark.

The EU, however, has attempted to ease the burden on manufacturers by issuing the EU Explanatory Guidance Document ( , which aims to enable compliance with the requirements of the directive. The EU is also compiling a guidance document related to technical documentation responsibilities now issued under the directive.

Mandatory Technical Documentation

To ensure compliance with safety requirements, manufacturers must now provide detailed description of product design and manufacture, including references to the manufacturing process, age suitability, grading level and intended product use. General description and a colour picture of the product must also be included, along with the address of both product manufacture and storage. As well as this, all packaging and instruction details and test reports are mandatory and where relevant, an EC type examination certificate must also be provided.

Where changes in toy design occur, it is the responsibility of manufacturers to ensure continued product compliance with the requirements of the directive. Continued compliance is mandatory for all toy products under the directive.

The new technical documentation requirements under the directive also specify the inclusion of a Bill of Materials (BOM) along with manufacturing documentation per toy product. The BOM is required to detail all relevant substances and components for each component and material included in toy manufacture. Where specified under REACH ( , Safety Data Sheets (SDS) must also be provided.

All Toys to Undergo Safety Assessments

New to the directive is the inclusion of a Safety Assessment Procedure, whereby manufacturers must identify chemical, physical, mechanical, electrical, fire, hygiene and possible radioactive hazards associated with their toy product.

Importers Obliged to Verify Their Products Too

Importers do not escape the new toy directive ( They will have to ensure that conformity assessment procedures have been carried out by the manufacturers of all imported toy products. Importers will also be required to verify that manufacturers have the appropriate technical documentation, instructions, safety information and CE marking for all imported toys. Each imported toy product must carry both the importer’s and manufacturer’s company details, including the company registered name, trademark and address. It is also the responsibility of importers to ensure that each imported toy carries a type, batch or serial number.

SGS Validation Services for Technical Documentation
SGS is able to assist toy manufacturers and importers with services designed to ensure compliance with the new directive. These services include the BOM list review, the preparation and review of CLP notification dossiers, the preparation of Safety Data Sheets (SDS), SHVC screening (as per REACH regulation requirements), risk assessment and factory audits as per the requirements of the new legislation. SGS is also able to provide a full capacity product testing service, report validation as well as the provision of EC type examination certificates.

SGS will organize on a regular basis some free webinars on the EU Toy Directive. Don’t hesitate to email us at to receive invitations.

For further details please contact:

SGS Consumer Testing Services
Stephanie Pionchon
Marketing Manager, SGS France
215 Rue Paul Langevin, Pôle d'activité Aix les Milles, 13854 Aix en Provence, France

t:  +33 4 42 61 64 46

SGS is the world’s leading inspection, verification, testing and certification company. SGS is recognised as the global benchmark for quality and integrity. With 64'000 employees, SGS operates a network of over 1'250 offices and laboratories around the world.

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