Ensuring compliance of costumes for European market (Toy Safety Directive 2009/48/EC)

Did you know that children’s costumes and dress-up products in Europe are regulated by the Toy Safety Directive (TSD) 2009/48/EC?

According to the Directive, products intended, whether or not exclusively, for use in play by children under 14 years of age are considered toys, and costumes for children are therefore included in this.

As a result, children’s costumes sold in the European Union market are required to fulfil the safety requirement of TSD 2009/48/EC and bear CE Marking to protect the safety of children.

Under this Directive, manufacturers, importers and sellers need to ensure the costumes they are selling on the EU market are in compliant with various regulatory requirements, including:

• Safety assessment in terms of chemical, physical, mechanical, electrical, flammability, hygiene and radioactivity hazards, as laid out in the harmonised standards EN 71-2:2020 and EN IEC 62115 (for electrically operated toys)
• Conformity assessment procedure to demonstrate that the costumes are compliant with the regulatory safety requirements. During the conformity assessment, a Notified Body attests to whether the technical design of the toys meets TSD requirement and issues EC-type examination certificate for fulfilling products
• Technical File with all necessary documentation and details to support the conformity assessment
• EC Declaration of Conformity stating the fulfilment of the safety requirement with certification from a European Union Notified Body
• Apply CE Marking to the costumes, either directly on the products, on the affixed labels or on the packaging, together with names and addresses of manufacturers and importers, as well as identification of the products for traceability (e.g. a batch or serial number)
• Insert user manual containing instructions and safety information with warnings in the language(s) that the costumes are intended to be sold in.

Our laboratory in France is a Notified Body (2817) for toys. Contact us for assistance!

Knowing more on EN 71-2:2020

Within EN 71, costumes are covered in particular under chapter 4.2 "Toys to be worn on the head" (fake beards, wigs and so on) and chapter 4.3 "Toy disguise costumes and toys intended to be worn by a child in play".

In the latest version of EN 71-2:2020 published in just December 2020, though yet to be accepted by the EU Commission and Member States, a few key points concerning costumers have been extracted below:

• Definition of toy disguise costume refers to “costume intended to be worn by children to facilitate imaginative play where the child pretends to be a character”
• Definition of toys intended to be entered by a child refers to “toy constructed from fabric and/or polymer sheets and films that are intended to fully or almost fully enclose a child on all sides”
• Test method: this type of toy (costumes) shall be tested both before and after washing, even if the good’s instruction states not to wash
• Suggestion on costume designs and construction to reduce the rate of spread of flame
• Flowcharts to help select test samples

Explaining Declaration of Conformity (DoC)

Declaration of Conformity (DoC) is the document that manufacturers, importers or sellers prepare to show that their products comply with EU requirements, and the parties drawing the DoC assume the responsibilities of the product compliance. The DoC should be supported by a valid test report against EN 71 standards and translated into the language(s) of the targeted Member States market(s).

More about Technical File

Technical File is the set of compulsory document for any CE Marking application. It consists of all the necessary proof that the products fulfil the Directive’s requirement. Kept for 10 years after the toy is placed to the market(s), the Technical File is composed of:

• Detailed description of the design and manufacture, including a list of components and materials used in the toys, as well as the Safety Data Sheets obtained from the chemical suppliers
• Safety assessment/Risk assessment report
• Description of the conformity assessment procedure followed
• A copy of the EC Declaration of Conformity (DoC)
• The addresses of the manufacturing and storage locations
• Copies of documents that the manufacturer has summited to a Notified Body, if applicable
• Copies of test reports
• A copy of the EC-type examination certification
• Labelling and packaging file

Without proper certification and assessment, your products will be liable to product recalls, causing financial loss and brand reputation damage. Ensuring compliance of your toys is essential to both your company’s and children’s health!

Our laboratories offer comprehensive testing and compliance services to help you out. Reach out to us anytime if you need assistance in costumes or toys safety support.