Friedrich Hauptmann - Consultant

Consultant for toy safety, quality and environmental solution

Important information and recent developments


11th May 2019

Important changes in toy standard and RoHS!

1. EN 71-1:2018 - Standard changed between August and December

2. RoHS Directive for electrical appliances: New material prohibitions.

EN 71-1 of August 2018 is already replaced by is by successor: EN 71-1 December 2018.

If you have purchased the former 2018 standard, you can receive the new version free of charge from Beuth or your other sources.

There are some important changes which can apply to: flight toys, rotors, propellers; slingshots and catapults; projectile toys, also with suction cups, also improvised projectiles; rolling toys; cords, chains, electric cables; cords; warning texts; toys for cots, children's beds and prams; tensile test; test loads for toy scooters; sunglasses.

„RoHS-3“ RL (EU) 2015/863 electrical appliances is now tightening the ban on heavy metals and flame retardants by banning phthalates. This ban must be implemented in all new products before 22nd July 2019. The low limits for lead, cadmium, mercury, chromium VI; flame retardants PBB, PBDE; are now also valid for plasticizers DEHP, BBP, DBP, DIBP. Attention! Phthalates are often used in cable tie insulations of electrical appliances.




28th August 2018

Toy slime on the RAPEX List

Problems: Boron, preservatives, dyes

EU authorities are concerned about boron in toy slime products. The quantities of boron used in these products are teratogenic and pose a health hazard. Products lose their marketability. Some are already listed on the RAPEX list of dangerous products.
There is reason to believe that they impair fertility (reprotoxic, class 2).
In the assessment of “slime” there was uncertainty as to which class it belongs. There is no information on this subject in the Toy Directive 2009/48/EC. However in the Table 1 of the EN 71-3 slime is assigned to class II. This should remove all doubt on the subject.
Another problem arises from the preserving agents contained in slime products. These should comply with the requirements in EN 71-9: EN 71-9, Table 1, Table of limit values 2 H: Preservatives.
Dyes - Primary aromatic amines.
The Table of limit values 2C in the EN 71-9 lists another problem: Primary aromatic amines.
I hope that the information above helps to solve these problems.




21st April 2017

URGENT New radio equipment must comply with RED

All new radio equipment on the market must comply with the RED / Radio Equipment Directive 2014/53/EU by June 13th 2017 at the latest. Any new radio equipment complying with the former R&TTE Directive 1999/5/EC is then no longer permitted.

One of the new essential requirements is the fulfilment of the requirements of the EMC Directive 2014/30/EU and the electric safety requirements of the 2014/35/EU Directive.

Radio equipment includes radio sets, transmitters and receivers.

This regulation applies to the first placing on the market of radio equipment within the EU. The good news for importers is that, in contrast to EU manufacturers, “placing on the market” begins on reception of the equipment from the bonded warehouse.

Please remember to alter your products and the Declarations of Conformity in accordance with these new requirements.




30th March 2016

The new Radio-Equipment-Directive 2014/53/EU will replace the former R&TTE Directive from 13th June 2016 onwards.

The hitherto existing R&TTE Directive included radio equipment, EMC and LVD.

NEW: The Radio Equipment Directive 2014/53/EU will replace the former R&TTE Directive 1999/5/EC from 13th June 2016 onwards. In Germany the new Directive will not be converted in time so that up to 12th June 2017 radio equipment can be produced according to the former R&TTE Directive.
NEW: The EMC Directive 2014/30/EU will replace the former EMC Directive 2004/108/EC from 20th April onwards.
NEW: The Low Voltage Directive 2014/35/EU will replace the former

LVD 2006/95/EC from 13th June 2016 onwards.

All radio equipment must be labelled correctly. Each device must bear the name and address of the company and a correct Declaration of Conformity must be provided.


Since 17th December 2015 the REACH Regulation (EC) No 1907/2006 determines 168 SVHC substances.

At present the REACH Annex XVII contains 52 entries or 64 entries if phthalates and PAH are counted separately.



10th November 2015

BPA – Ban on bisphenol A in toys made of polycarbonate plastic - Directive 2014/81/EU

Bisphenol A is often used in toys made of polycarbonate plastic. BPA can be toxic to reproduction and up to now its content was limited. The Directive 2014/81/EU now specifies a low migration value of 0.1 mg/l.

From 21st  December at the latest,  all toys, including all stocks,  must comply with this lower migration value.



30th May 2015

Battery-Directive 2013/56/EU

Important, please note: from October 1st 2015 onwards button cells containing more than 0.0005% mercury will be forbidden, including those built into toy products.
It is advisable to sell your stock of button cells containing mercury as quickly as possible.
Make sure that all new orders contain only mercury-"free" button cells.


27th February 2015

Declaration of the country of origin


There is a never-ending debate on the subject of this declaration.
In spite of years of discussion, there is still no legal compulsion to provide this declaration
now or in the near future. 

30th June 2014


EU Directive 2011/83/EU on consumer rights

This Directive was transposed into German National Legislation and
is valid now from 13th June 2014.

The many new European Consumer Rights mentioned in the Directive are important for stationary and online trade.
Please check whether you have implemented all these new regulations.


On 16th June 2014 the ECHA organisation added 5 new substances to the SVHC list so that

155 SVHC substances are now listed.

All companies concerned should take this into consideration.

16th December 2013 - now 151 SVHC substances on the Candidate List

As from 16th December 2013 the ECHA List contains 151 SVHC entries.
If you want to be sure that your products do not contain any of these substances, please check with the chart below:

The new EN 71-1 is available -  Mechanical and physical properties

The new version of EN 71-1:2013-12 is published and is available by Beuth.

It is advisable to read the introduction.

You can find it under:

  • From 18th June 2012 onwards 11 new substances have been added to the candidate list of substances of very high concern at the ECHA.
  • This new development should be taken into consideration when selecting raw materials or suppliers.

    You can find the “Candidate List of Substances of Very High Concern for Authorisation” on the Internet under:

Selling your toys online:

When you sell toys on the internet please do not forget the following …

… the price-marking regulations. Some toys require price unit specifications such as: “per meter”, “per litre” or “per kg”.

the textile labelling regulation.

… that deliveries overseas and in some EC countries are subject to different requirements, to legal notices,
 right of revocation and general terms and conditions.

… the different national implementations of the EC Directive 98/6/EC to price-marking.

… the translation of essential safety and warning texts into the respective national languages (e.g. CH = DE+FR+IT).

… to obtain confirmation that all warning texts have been acknowledged before sales transactions.

thJuly 2011 - End of transition period:

The new Toy Safety Directive 2009/48/EC 

is now in force


The new Toy Safety Directive 2009/48/EC came into force 20th July 2011 and replaces the former Toy Safety Directive.

  • The former Toy Safety Directive 88/378/EC is now invalid.
    As a result all toys put on the market after 20th July must fulfil the requirements of the new Directive.

    This also applies to your current range of toys!

  • IMPORTANT: Online or catalogue sales:

Potential buyers must be informed of any hazard warnings pertaining to the product before purchase. Helpful tips for this are available

The new Standard EN71-1  
The new Standard EN 71-1:2011-07 of 18th June 2011 offers you support for the testing of your product range for compliance with the new Directive.


The new Toy Safety Directive 2009/48/EC

  • of 18th June 2009 replaces the 20 year old Toy Directive 88/378/EC.
  • The transition period of two years for adapting products to the new Directive
    ended 20
    th July 2011.
  • The transitional period for chemical requirements is 4 years and ends 20th July 2013.
  • Before this deadline, toys covered by EN 71-3 may be placed on the market according to the old Toy Safety Directive.
  • Up to now, the EN 71-3 has provided limits for the migration of 8 elements. Now 19 elements and compounds are mentioned.
  • New limit values have been defined.
  • The competence and responsibility of "economic operators, manufacturers, representatives, importers and distributors" have been newly defined, together with their responsibility as part of the delivery and distribution chain.
  • You can find the new Toy Safety Directive in the internet under

Essential requirements of the new Toy Safety Directive

Art. 2: Scope – age group now under 14 years

  • The age limit for toys has been lowered by one year.
    Old Directive –  "up to" 14 years (including teenagers of 14 years but not 15 years).
    New Directive: "under" 14 years (including teenagers of 13 years but not 14 years).

Art. 2: Scope – dual-function products which may be used as toys

  • All products which could be used as toys shall comply with the requirements of the Directive ("whether or not exclusively for use in play... ").
  • Dual function products (e.g. toy-like key tags) must comply with toy safety requirements.

Art. 10 (2) Essential safety requirements

  • Toys shall not jeopardise the safety or health of users or third parties when they are used as intended or in a foreseeable way, bearing in mind the behaviour of children.

Conclusion: A misuse of toys must be taken into consideration.

Art. 3 Making available on the market

  • The definition "placing on the market" as making available on the market is sometimes wrongly interpreted as offering for sale. Art. 3 of the new Toy Safety Directive actually describes with "placing on the market" the supply of a toy for distribution. The "supply" of an object refers to the physical delivery  / collection/transport / circulation etc.

    "Placing on the market" is legally interpreted as in the following examples:

    "Passing an object on to a third party", "a third party acquires possession of an object", independent of whether the object is a free gift, purchased, hired, leased etc.

Art. 4; 9; 21 Obligations of manufacturers – Identification by batch numbers

  • (2) Manufacturers shall perform a conformity assessment procedure and draw up a Declaration of Conformity.
  • (3) Manufacturers shall keep the Declaration of Conformity and technical documentation for 10 years after placing a product on the market and must be able to submit them to the market surveillance authorities within 30 days at the latest.
  • (5) Manufacturers shall mark their toys with a batch number for identification purposes.
  • The retraceability of products is stipulated in Art. 9. This obligation to mark products is a useful aid for identifying batches which are questioned by market surveillance authorities.
    (4) Manufacturers shall compile a list of those products about which complaints have been made. (Art. 21 + Annex IV). It must always be possible to provide the market surveillance authorities with technical documentation on request, including
  • a description of the design and manufacture of a toy,
  • a list of components and materials used in the toy and
  • safety data sheets on chemicals used and a hazard analysis.

Art. 11 Warning notes:

  • Warning notes shall be easily legible, understandable, appropriate and easily visible at the place of purchase (and online), and include minimum age, maximum age or maximum weight if applicable.
  • This also applies to sales in the Internet or by catalogue. Please acquaint yourself with the regulations, there are some helpful tips.
  • Small toys in displays: Warnings must now be affixed directly to the toy.

  • Safety texts must name the hazard: warnings about choking or injuries must be replaced by:
    "Attention! Small parts". The particular hazard may still however be additionally indicated, e.g. choking. The additional specification of the type of hazard is extremely important because parents may not otherwise understand that small parts can cause choking.
    Another example:
    "Warning! Sharp edges. Injury hazard due to functional sharp edges" etc.

  • The text "Not suitable for children under 36 months" can be replaced by the pictogram no.17 under section 7.2 “Warning notes” of the new Standard EN 71-1:2011-07.
    The word "Attention" shall not be replaced by the pictogram.

If you want to use the symbol below for your products or packages, you can download it here. Just select the required file format and save the displayed graphic in your system.
The graphic shall only be used in the standardised version and must measure at least 10 mm.

If you require safety texts, please contact me.

Art. 18 Safety assessments

  • Manufacturers must carry out a hazard analysis and assessment.

Art. 19 Applicable conformity assessment procedures

  • All manufacturers and importers (Art. 5) shall carry out conformity assessment procedures for their toys.
    Detailed instructions are given in Annex II.


ANNEX II – Chemical properties

The New Directive

  • bans the use of hazardous chemical substances, e. g. substances classified as CMR = carcinogenic, mutagenic or toxic to reproduction, and specified allergenic substances and fragrances,

  • stipulates the marking of allergenic substances and fragrances, if they are used according to regulations and

  • updates the list of chemical substances and adjusts their limit values.

  • Information on chemicals must be provided in the technical dossier.


CE Labelling


  • With the CE label, the EC manufacturer or first European importer informs the market surveillance authorities that the product at hand complies with all applicable EC Directives.

  • The CE symbol shall only be used in the standardised version and must measure at least 5 mm.

  • If you want to use the CE symbol for your products or packages, you can download it here. Just select the required file format and save the displayed graphic in your system.


    ce.gif (3 KB)
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    ce.psd (9 KB)


GPS Directive 2001/95/EC General Product Safety

This Directive supersedes the old or new Directive on toy safety.

  • The GPS Directive basically states: Products must be safe.

  • In Germany the GPS Directive was transposed into national law as part of the German Equipment Safety Act (GPSG).

  • A product must be safe. This basic principle applies to all products, whether they are considered as being toys or consumer articles.

  • According to the GPSG, it is left to the manufacturer's own discretion to make a product safe.

  • Fortunately, the Toy Safety Directive provides toy producers with important information.

  • Specifications and details are given in the Standards, e.g. EN 71.

  • You can find the GPS Directive in the internet under



Warnings for magnets:

  • Dangerous magnets, i.e. strong magnets in a swallowable size shall no longer be used in normal toys, so that warning texts are no longer required.

  • Strong magnets are only allowed in electricity and magnetism project kits, with warning texts, for children over 8 years.

  • "Functional" magnets (e.g. in loudspeakers and electric motors) or weak magnets (flow index less than 50 kG2 mm2) are permitted.


  • (Dimethylfumarate) an anti-mould agent is banned for health reasons in the EU Commission Decision 2009/251/EC. Please note: mouldproof sachets may contain this substance.


External transformers with no-load power consumtion (eco design)

  •  Directive 2005/32/EC (ecodesign), “requirements for the environmentally beneficial design of energy driven products”.

  •  Regulation (EC) 1275/2008 (Standby regulation) “ecodesign requirements for standby and off mode electric power consumption of electrical and electronic household and office equipment”.

  •  Regulation (EC) 278/2009 (for external transformers)   “ecodesign requirements for no-load condition electric power consumption and average active efficiency of external power supplies in operation”.

  • The above mentioned Directive and Regulations stipulate that after 26th April 2011 only "efficient" external transformers shall be placed on the market. Exceptions are battery charging devices to which a removable battery is directly connected and "external low-voltage transformers < 6 V and > 550 mA" (input voltage up to 230 V, output voltage lower than 6 Volt, output current greater than 550 mA). 


Radio controlled toys / R&TTE Directive 1999/5/EC

Radio controlled toys in the non-harmonised frequency range above a specific radiated power require this   Alert  symbol, together with the country abbreviation + RTTE information on transmission class, Declaration of Conformity, notification. In all cases the transmitter, receiver, instruction manual and packaging must be especially labelled.

The "alert symbol" indicates that there are restrictions for the use of this appliance within Europe.

This symbol can be downloaded here.


  • Please contact me. I have gained a great deal of experience in dealing with this topic.

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alert.jpg (35 KB)
alert.pdf (48 KB)
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Battery Directive 2006/66/EC

DIRECTIVE 2006/66/EC on batteries and accumulators and waste batteries and accumulators

  • In Germany the Battery Directive was transposed into national law with the Battery Act. This Act came into force 1st December 2009. Since this date a registration office is available for registering battery producers and importers in Germany.

  • The Battery Directive specifies low heavy metal values, bans other heavy metals (e.g. lead, mercury, NiCad, ) and regulates specifications (capacity) and labelling (see below).

Symbol (for the Battery Directive without bar)