GPSR technical documentation for toys — template and requirements

The product may not be placed on the market unless an economic operator established in the EU is responsible for it. Name and contact details must appear on the product, its packaging, the parcel or an accompanying document.

GPSR Art. 16(1) / Reg. (EU) 2019/1020 Art. 4 · Information · Applies if “Is the manufacturer established outside the EU?” Yes

The technical documentation must contain a detailed description of the design and manufacture, including a list of components and materials used in the toy.

2009/48/EC Art. 21, Annex IV(a) · Information

The technical documentation must state the addresses of the places where the toy is manufactured and stored.

2009/48/EC Annex IV(e) · Information

The manufacturer's name, registered trade name or trade mark and contact address must be indicated on the toy or, where that is not possible, on its packaging or in an accompanying document.

2009/48/EC Art. 4(6) · Information

Before placing the toy on the market, the manufacturer must analyse the chemical, physical, mechanical, electrical, flammability, hygiene and radioactivity hazards the toy may present, and assess the potential exposure to them.

2009/48/EC Art. 18 and Annex IV(b) · Document

Safety data sheets for the chemicals used in manufacture must be included in the technical documentation.

2009/48/EC Annex IV(a) · Test report / certificate

Shows that the toy meets the requirements on small parts, sharp edges and points, cords, magnets and strength, among others.

2009/48/EC Art. 13 and Annex II Part I; Annex IV(g) · Test report / certificate

Shows that the toy does not present a dangerous flammability risk.

2009/48/EC Annex II Part II · Test report / certificate

Shows that migration of lead, cadmium and chromium VI, among others, from accessible materials is below the limits in Annex II Part III.

2009/48/EC Annex II Part III point 13 · Test report / certificate

Shows electrical safety, including temperatures, battery compartments and protection against button batteries becoming accessible.

2009/48/EC Annex II Part IV · Test report / certificate · Applies if “Does the toy have electrical functions or batteries?” Yes

Plasticised material must not contain more than 0.1 % by weight of DEHP, DBP, BBP or DIBP (entry 51), and toy parts that can be placed in the mouth must not contain DINP, DIDP or DNOP (entry 52). Rubber and plastic parts in contact with skin or mouth must not contain more than 0.5 mg/kg of listed PAHs (entry 50, point 6).

REACH Annex XVII entry 50(6), entries 51 and 52 · Test report / certificate · Applies if “Does the toy contain plasticised material (e.g. PVC) or rubber?” Yes

The listing must clearly show: the manufacturer's name, postal and email address; the responsible person in the EU if the manufacturer is outside the EU; a picture and identification of the product (type and other identifier); and warnings and safety information in a language consumers easily understand.

GPSR Art. 19 · Document · Applies if “Is the product sold through a webshop or marketplace (e.g. Amazon)?” Yes

The manufacturer must ensure that accidents caused by the product are notified without undue delay to the competent authority via the Safety Business Gateway.

GPSR Art. 20 · Document

Signed declaration that the requirements of Art. 10 and Annex II are fulfilled, following the structure in Annex III. A copy must be included in the technical documentation.

2009/48/EC Art. 15, Annex III; Annex IV(d) · Document

The toy must be accompanied by instructions and safety information in a language consumers easily understand, as determined by the Member State.

2009/48/EC Art. 4(7) · Document

The CE marking must be affixed visibly, legibly and indelibly to the toy, a label or the packaging before the toy is placed on the market.

2009/48/EC Art. 16 and 17 · Marking

The toy must bear a type, batch, serial or model number or other element allowing its identification — or, where that is not possible, on the packaging or in an accompanying document.

2009/48/EC Art. 4(5) · Marking

Warnings must be clearly visible, easily legible and understandable and preceded by the word “Warning” or “Warnings”. Warnings that affect the purchase decision must be visible on the packaging.

2009/48/EC Art. 11(1)–(2), Annex V · Marking

Toys that might be dangerous for children under 36 months must bear the warning “Not suitable for children under 36 months” (or the equivalent pictogram) together with a brief indication of the specific hazard, e.g. small parts.

2009/48/EC Annex V Part B point 1 · Marking · Applies if “Is the toy intended for children under 36 months?” No and “Does the toy contain small parts or parts that can come loose?” Yes