Toy Safety Directive: an explanatory guidance document revised

The European Commission updated the explanatory guidance document for the Toy Safety Directive (TSD) on 16th of December 2021. One of the most significant changes concerns instructions and safety information on the website, language requirements and second-hand toys.

Apart from the revision of the Toys Directive, the latest ECHA’s Enforcement Forum study stated an important message to producers concerning breach of EU chemicals laws.

Please see below one of the most important changes in the explanatory guidance document for the Toy Safety Directive (TSD):

Second-hand toys

The newly revised legislation applies to placing products on the market – it is understood as the first making available for distribution on the Common market (also applies to the second-hand toys from the third countries). If toys have already been placed on the EU market and later, due to the commercial activities appear as second-hand toys – they are no longer considered as being placed on the market. Measures against second-hand toys can be taken under the GPSD on a national basis.

Instructions and safety information on the web

Additionally, the guidance clarified that the instructions and safety information on the web cannot replace those that have to accompany the toy on the packaging, in a leaflet, or notice. The information provided on the website is not sufficient and should be regarded only as an additional channel to provide information.

EC declaration of conformity language requirements

An EC declaration of conformity and any information inserted may be multilingual. This information can contain all official languages of the European Community or only those where the toys are made available.

Guidance document No. 20 on decorative products and products for collectors

Decorative objects for Christmas and other celebrations like folk dolls, decorative dolls, and similar products now also refer to the Guidance document No. 20 on decorative products and products for collectors. It is important to note that a child-appealing product which is not considered a toy still needs to be safe for children and comply with the provisions of the General Product Safety Directive (GPSD).

Child-appealing luminaires

Products like lamps and lightings are not considered toys. They do not have the play value to be classified as toys. However, lamps used in a dollhouse are considered toys.

The Low Voltage Directive applies to child-appealing luminaries.

Allergic fragrances

The following substances will be prohibited from the 5 of July 2022.

· Atranol (2,6-Dihydroxy-4-methyl-benzaldehyde) (CAS number: 526-37-4)

· Chloroatranol (3-Chloro-2,6-Dihydroxy-4-methyl-benzaldehyde) (57074-21-2)

· Methyl heptine carbonate (111-12-6)

N-nitrosamines and for N-nitrosatable substances in toys

These substances are prohibited in the toys for children under 36 months or the ones that may be placed in the mouth – as newly added to the directive – water balloons.

For more information, please see TSD explanatory guidance document.

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1)     European Commission. (2021). TSD explanatory guidance document. Retrieved on 20/01/22 from:

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