As the soft-filled toys covered with sequins became more and more attractive for children of all ages, the toy industry started to face regulatory challenges when it comes to the warning on the allowed age for playing with this type of toys.
As such, given that their presumed harm could affect children below the age of 3, a question of intent of use has arisen when selling these specific toys. Sequins are normally defined as “small shiny discs sewn on to clothing for decoration” and, thus, it would fall in the category of small parts requirements of the Toy Safety Directive. Moreover, given their application on soft-filled toys, certain concerns may arise when the material or the connection is not strong enough to withstand when used by the children.
The Administrative Cooperation (ADCO) Expert Group on Toy Safety within the European Commission brought this issue to public attention on 19 February 2019 by issuing a note to help companies understand the approach market surveillance authorities will take on this matter.
The note explains and substantiates the fact that “a soft-filled toy that is partially or completely covered with sequins is considered as a toy intended for children under 3 years.” All the more so, according to the Toy Safety Directive 2009/48/EC, soft-filled toys with simple features, intended for holding and cuddling, are considered as a toy intended for children under three years of age.
The manufacturers will have to comply with the additional small parts requirements and as such, they can no longer be avoided by adding the age warning, “Not suitable for children under 3 years” or the age warning symbol for a toy.
It has been concluded that soft-filled toys with sequins are intended for children of all ages and, thus, all security measures and adequate age warnings must be thoroughly implemented.
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