Removed?! High risk?! A must-read for Amazon children's toy product compliance!

The full text is about 1,700 words, and the reading time is about 6 minutes

Despite being affected by the pandemic this year, Amazon's overseas sales momentum is still strong in many categories, and the toy category is no exception. In the first quarter, sales of chess and puzzle products in the UK increased by 240% [1], promoting this home entertainment for both adults and children. However, in these seemingly “harmless” products, there are often safety hazards.

For example, as early as the end of last year, a wooden puzzle toy designed for 1-year-olds was investigated by Amazon as failing its safety test results [2] on the grounds that it contained “small objects” that could cause suffocation. Countries have always paid great attention to child safety and health, and toy safety inspection standards are even stricter [3]. Therefore, sellers must not take it lightly when producing and designing toy products, and should pay extra attention to compliance requirements.

Toy safety recall case

Product name: baby monitor
Harm: The product's wire is connected under the child's mattress. If the baby pulls the wire into the crib, it may cause the wire to wrap around the baby's neck and cause suffocation!
Outcome: recall

As different countries or regions define “children's toys” differently, the standards for their products are also different. For example, in the US, consumer goods suitable for children under 12 (including those aged 12) are called “children's products” (children's products); in the EU and Japan, only products suitable for those under 14 (including those aged 14) are subject to corresponding directives and standards.

Please accept the compliance requirements and applicable standards for children's toys (children's products) in Europe, America, and Japan, so that you can understand the market situation and not take detours!

In the US, all toys intended for children 12 and under must meet federal child product safety standards. These safety standards include:

1. The consumer safety standard ASTM F963 for toys is a requirement for surface coating and base materials of toys; it also has requirements for various physical properties
2. Lead Content Requirements for Toy Products 15 USC 1278a
3. Legislation applicable to different children's products, such as 16 CFR Part 1203 on bicycle helmets, or 16 CFR Part 1232 on children's folding chairs

Everyone can go through the American Consumer Product Safety Association
Find information on the official website of CONSUMER PRODUCT SAFETY COMMISSION (CPSC)
Standards and laws for toy products sold by oneself.
Click the link to open

The Consumer Product Safety Commission (CPSC) is an American agency that regulates children's products. The CPSC requires that all children's products sold in the US must be tested in a CPSC-approved third-party laboratory according to corresponding standards and include a “Children's Product Certificate” to prove the product's compliance.

Children's Product Certificate (CPC), we can think of it as a self-affirmation. This statement is based on test results from a third party laboratory and uses a written document to prove that the product complies with children's product safety standards.

Of these, special note is based on US Federal Act 16 CFR Part 1110:

1. Children's Product Certificate CPC should not be issued by a third-party laboratory providing testing services
2. CPCs can only be issued by factories or importers in the US; CPCs issued by non-domestic factories or sellers are not accepted

If your children's products are made in a factory other than the US, then you must find an American importer to help you publish this CPC. To help you publish a qualified CPC, here is a summary of the 7 elements that must be included in a CPC:

1. Identification of the product covered by this certificate, detailed product descriptions, etc.
2. Citation to each CPSC children's product safety rules to which this product is being certified applicable safety standards and laws
3. Identification of the importer or domestic manufacturer certifying compliance of the product release this CPC importer or factory information
4. Contact information for the individual records of test results Contact information
5. Date and place where was this product manufactured production time and address
6. Provide the date (s) and place when the product was tested for compliance with the consumer product safety rule (s)
7. Identify any third party, CPSC-Accepted Laboratory on Accepted Testing the Certificate Depents laboratory specific information

Which laboratories are CPSC-accredited third-party laboratories?

In fact, most regular laboratories on the market are within the scope of CPSC accreditation, and you can also search for relevant laboratories through https://www.cpsc.gov/cgi-bin/labsearch/.

US summary

1. Meets federal children's product safety standards
2. Testing is carried out in CPSC-accredited third-party laboratories according to corresponding standards to prove product compliance
3. Children's product certificate CPC can only be issued by a factory or importer in the US. CPC issued by a non-local factory or seller is not accepted

Europe

In Europe, all toys or products for children aged 14 and under are regulated by Directive 2009/48/EC on toy safety (“Toy Safety Directive”), which contains rules for supplying and selling toy products in the EU. The Directive sets out a number of important requirements for toy safety, labelling, warning, and management obligations. In particular, specific numerical requirements are made for toxic and harmful substances and heavy metal content in toys.

Sellers can refer to the EU link to match each
Restricted usage of elements
Standards and laws for toy products sold by oneself.
Click the link to open

As an overseas seller or manufacturer outside of the European Economic Area, very similar to the US, you must prepare two documents to prove the safety and compliance of the product:

1. Declaration of Conformity (DoC)
2. Technical documents, such as test reports or product certification certificates, certify that the product complies with the corresponding EU harmonized standards

It is important to note that the first document DoC was issued by the factory itself (the biggest difference between this and the US is that Europe does not require a local European factory or importer to issue it). The second technical document can be issued by a third-party laboratory or verified by the factory itself.

To help you publish a proper DoC, let's summarize a few important elements:

1. Product details (product description, product model, images, etc.)
2. The EU directives and applicable harmonized standards applicable to the products included in the declaration can be indicated in the following form

3. DoC release date
4. Publisher's signature and position (this is usually the head of the factory or quality manager)

Special note: It is important to note that for some toys that may be dangerous to children under 36 months, EU regulations must indicate on the product packaging: Not suitable for children under 36 months or not suitable for children under three years, and the following graphic warning can also be used on the package.

Europe summary

1. Complies with European toy safety directives
2. Provide a Declaration of Conformity (DoC)
3. Provide technical documentation such as test reports or product certification certifications to prove that the product complies with the corresponding EU harmonized standards

Japan

Japan has no specific regulations on imported toy products; it only stipulates that toys must comply with the provisions of the Food Sanitation Law. According to the Act, all imported baby toys must submit documents such as the “Imported Food Notice” to the quarantine department at the port of entry so that the authorities can review and check the content of heavy metals, arsenic and other harmful substances in toy products.

The Japan Toy Association (JTA) has prescribed a safety control system for toy products for manufacturers to voluntarily comply with. All products certified to meet JTA standards can be affixed with the ST (safety toy) mark. Attaching the ST mark to the product is voluntary and is not required by law.

Toy Safety Standard (ST) The toy safety standard mainly assesses the following three aspects of toys:

1. The physical characteristics of the toy, such as how the product is designed and shaped to prevent injury to children
2. The flammability of toys is mainly tested for flammability of textile toys such as tents and plush toys
3. The composition of toys prevents the product from containing toxic and harmful substances and heavy metals that are harmful to humans (this is similar to European and American standards)

All stations must keep in mind that toys don't hit rock bottom when they go out to sea. Cross-border e-commerce sellers need to pay attention to the different compliance requirements and applicable standards for children's toy products in various countries. While ensuring that the products go overseas smoothly, they also allow overseas consumers to buy and use them with confidence.

*Data source:
[1] Games and puzzles sales grow 240 per cent in the UK, as families turn to classic games during COVID-19 lockdown, Toynews, 2020, https://www.toynews-online.biz/2020/04/02/games-and-puzzles-sales-grow-240-per-cent-in-the-uk-as-families-turn-to-classic-games-during-covid-19-lockdown/
[2] Something happened again!There is a problem with these four products and has been investigated by Amazon!, Sohu, 2019, https://www.sohu.com/a/362228387_190834
[3] U Proposes To Strengthen Allergenic Fragrances In Toy Safety, SGS, 2020, https://www.sgs.com/en/news/2020/04/safeguards-04320-eu-proposes-to-strengthen-allergenic-fragrances-in-toy-safety