Toys with soft filling and sequins

Toys with soft filling must be safe for children of all ages, when covered with sequins.

Stuffed toys partially or fully covered with sequins (spangles) are a new toy trend. They have attracted the attention of EU market surveillance authorities. Here, you can find details of the specific aspects that apply to toys with soft filling.

The following regulations apply:

• the RD of 19.01.2011 on the safety of toys (RD) (the Belgian transposition of the Toy Safety Directive 2009/48/EC);
• the harmonised standard EN 71-1: 2014 + A1: 2018 Safety of toys - Part 1: mechanical and physical properties (EN 71-1).

The opinions of the majority of the members in the Administrative Cooperation Group (AdCO) from the Expert Group on Toy Safety are also taken into account.

The definition "intended for use by" in Article 2.28 of the RD provides the criteria to assess whether a specific toy is intended for use by a specific age group. The definition indicates that the deciding factor is what the parent or guardian can reasonably assume about the age group on the basis of the toy's function, dimensions and features. This particularly applies to toys that are intended for use by children under the age of 36 months.

Standard EN 71-1 offers the following example in Article 1 “Scope of application”: toys with soft filling with simple features, that are intended to be held and cuddled, are considered to be toys that are intended to be used by children under the age of 36 months.

Clause 3.61 of EN 71-1 provides a definition of toys with soft filling:

• with or without clothing; 
• with soft bodily surfaces; and 
• filled with soft materials, allowing easy compression of its main part with the hand.

The first age at which it is suitable for a child to play with the toy can be found in CEN ISO/TR 8124-8 "Safety of toys – Part 8: Age determination guidelines".

For "simple dolls and animals - dolls and animals with a soft filling, made of textile or plush with or without clothing and small parts attached to them that cannot be removed", the starting age is 2 months.

We can therefore conclude that in general, toys with soft filling must be suitable for children of all ages.

A toy with soft filling that is partially or fully covered with sequins and which still fulfils the definition of toys with soft filling is considered a toy intended for children younger than 36 months. A similar topic is covered in clause A.27 of EN 71-1, which states that toys with soft filling and toys that are covered with items that could be torn or bitten off (e.g. toys made of foam) must satisfy the torsion test (clause 8.3) and the pulling test (8.4), as required for toys intended for children younger than 36 months (in 5.1, general requirements).

You may not circumvent the requirements for small parts (RD) by adding the warning "Not suitable for children under the age of 3" or displaying the corresponding pictogram on toys that are clearly (also) intended for use by children under the age of 3. This is set out in Article 11 (1), third paragraph of the RD and is further elaborated in the corresponding section of the Explanatory orientation document for toy regulations.

To conclude

Toys with soft filling and sequins must be safe for children of all ages.