08. Box Marking - EU | v.20211122

8.1 CE Marking

Format requirements:

8.1.1 Conflict Between 14+ and CE Marking

8.1.1.1 The case with three marks: 14+ / Non-toy / CE Marking

If a customer's product contains all three marks at the same time, it is CE Marking abuse. 14+ non-toy products are not within the scope of CE Marking use. The priority recommendation is to remove the CE Marking, or remove both CE and non-toy, and arrange for testing.

Test application: products with age standard 13+ refer to the EN71 series for the test.

Results: The labels and markings will not be evaluated. The report will state the result of the test as PASS, but the package mark is not evaluated in the test. Instead, customers will receive a PASS report (with remarks). The notes are as follows.

Labeled Age Grade:	14+
Appropriate Age Grade:	NOT REQUESTED
Client Specified Age Grade：	OVER 13 YEARS OF AGE
Tested Age Grade:	OVER 13 YEARS OF AGE

NOTE:

1. The sample is tested for "OVER 13 YEARS OF AGE" as the client's request.

2. The product is tested as non-toy products, thus clause 7 of EN 71:2014+1:2018 & CE Marking, Manufacturer/Importer name and address, product identification under 2009/48/EC were not evaluated.

If the customer insists on keeping the CE Marking (or if the large shipment has been completed with 14+/non-toy/CE Marking), you need to negotiate with the lab, which may issue a PASS report (with remarks). However, there is still a chance that the customs of the destination country will not release the goods due to "CE label abuse". The customer needs to consider this risk when deciding whether to keep the CE Marking or not.

8.1.1.2 With two marks: 14+/CE Marking

Same as 8.1.1.1: The main point of conflict is that the CE Marking has been removed from the 14+/non-toy category.

8.1.1.3 Contains only 14+/Non-toy, no CE Marking

You can apply for testing according to 13+ and refer to the EN71 series for testing. The lab pass sample will issue a PASS report with remarks.

NOTE:

1. The sample is tested for "OVER 13 YEARS OF AGE" as the client's request.

2. The product is tested as non-toy products, thus clause 7 of EN 71:2014+1:2018 & CE Marking, Manufacturer/Importer name and address, product identification under 2009/48/EC were not evaluated.

The risk is low, and so far, no cases of goods being detained by customs have been found.

8.1.1.4 Contains only 14+, no CE Marking

Same as 8.1.1.3

8.1.2 If a product is marked for users under 14 years of age

If a product is marked for users under 14 years of age, then it will be recognized as a toy; therefore, the CE Marking must be added. You can apply for testing according to the actual age. If there is no CE Marking, there is a high probability that the goods will be detained by customs.

8.2 Warning Language, Warning Age Range

Requirements of EN71-1:

"Warning. Not suitable for children under 36 months. Small parts"

"Warning. Not suitable for children under 36 months. Long cord. Strangulation hazard"

The manufacturer shall provide appropriate information about the hazard(s) through the examples mentioned above or through other sentences that achieve the same result.

8.3 Manufacturer, Importer's Name and Address

The manufacturer's name, registered trade name, or registered trademark, and the address at which the manufacturer can be contacted shall be indicated on the toy or, where that is not possible, on its packaging or in a document accompanying the toy. This requirement applies also to the name and address etc. of any importer.

8.4 Product Lot Number, Model

Manufacturers shall ensure that their toys bear a type, batch, serial or model number, or other element allowing their identification, or where the size or nature of the toy does not allow it, that the required information is provided on the packaging or in a document accompanying the toy.