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The safety of puzzles and games

Puzzles and games can meet EU Safety Directives by being tested against harmonised standards and then clearly labelled.

Puzzles and games are enjoyed by all age groups and have been part of our lives for hundreds of years. They range from a child’s first puzzle, intended for young children of 12 months of age, to larger, more complicated items intended for the most serious adult enthusiast.

A huge selection of traditional products are available, as well as relatively recent inventions such as the Rubik’s cube and other strategy or intellectual games. All have the same basis: to make the player concentrate his or her mind in order to solve the puzzle or win the game.

Any of these puzzles or games which are either intended for, or able to be used by, persons under 14 years of age – which also includes many products designed for adults – are covered within the European Union (EU) by the Toy Safety Directive. Specifically in the UK, the requirements of the directive are encompassed by the toy safety regulations. Such products therefore need to carry the CE mark showing compliance with these requirements. For most of these products this can be achieved by testing against the appropriate parts of the test standard, EN 71.

Traditional games like chess are often played by children under the age of 14 and are therefore covered in the EU by the Toy Safety Directive

As well as ensuring that all toys are safe, EN 71 part 1 covers other logistical issues, such as the ability of individual items to be traced by the use of batch or lot numbers. It also requires the labelling of manufacturers’ or retailers’ contact details or a trade mark or brand name, which allows a product to be recalled or additional warnings or instructions to be provided if any potential safety risks are discovered.

Labelling clarity

The range of materials that these products could be made from is very wide and includes cardboard, metal, wood and plastics. The component parts can be small and therefore unsuitable for young children as such parts can pose choking hazards. Considering the labelling requirements for these products is therefore an important part of the development and design process. The packaged product must give the user clear information on the suitability of the product for children under 36 months.

Figure 1: This pictogram should only be used to indicate unsuitability for children under 3 years of age

Such labelling is a requirement of EN 71 part 1 and many retailers and manufacturers use the symbol contained in this standard, (figure 1), to clearly mark the suitability of a product. It should be noted that this symbol must only be used as a way of showing a product is unsuitable for children under 36 months and this must be used in conjunction with a written description of all hazards present.

The symbol cannot be used to show that the product is unsuitable for any other age groups. This is to avoid confusing consumers with any age range labelling intended to indicate the developmental level of a child required to understand or use the puzzle or game.

Old and new

There is a risk that toys and puzzles which are based on traditional designs are, by their nature, considered safe and, as such, may not be treated to the same degree of testing or assessment that would be carried out on a new design.

Manufacturers and retailers need to be aware that all products must have up to date test reports showing compliance with the appropriate parts of the toy safety or other relevant directives. In many cases harmonised toy safety standards (the EN 71 set of standards) are applicable.

Products should also be tested or assessed on a regular basis to make sure that they continue to conform to these regulations (see the toys and due diligence testing article for further details).

When a new or innovative product is designed, the potential hazards and risks may not be fully covered by the harmonised standards, in which case type approval by a recognised Notified Body will be required before the product can be placed on the market.

General safety

All products, whether intended for children or adults, which are sold within the EU need to comply with the requirements of the General Product Safety Directive (GPSD). This compliance is in addition to any other legal requirements or regulations, including any other specific directives that cover the product, such as the waste electrical and electronic equipment (WEEE) and the restriction of the use of certain hazardous substances in electrical and electronic equipment (ROHS).

How can we help?

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SATRA can provide a comprehensive range of services from testing of finished products or raw materials to the latest requirements of EN 71 parts 1, 2 and 3, and we are a notified body for undertaking third party type-approval of toys. Our laboratory houses state-of-the-art instrumentation and we are an ISO 17025 accredited laboratory. Please contact toys@satra.com for further information on toy testing.