CEN/TR 15371:2009

SLOVENSKI STANDARD
01-maj-2009
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SIST-TP CEN/TR 15371:2006
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Safety of toys - Replies to requests for interpretation of EN 71-1, EN 71-2, and EN 71-8
Sicherheit von Spielzeug - Antworten auf Anfragen zur Interpretation von EN 71-1, EN 71
-2 und EN 71-8
Sécurité des jouets - Réponses aux demandes d'interprétation de l'EN 71-1, EN 71-2 et
EN 71-8
Ta slovenski standard je istoveten z: CEN/TR 15371:2009
ICS:
97.200.50 ,JUDþH Toys
2003-01.Slovenski inštitut za standardizacijo. Razmnoževanje celote ali delov tega standarda ni dovoljeno.

TECHNICAL REPORT
CEN/TR 15371
RAPPORT TECHNIQUE
TECHNISCHER BERICHT
January 2009
ICS 97.200.50 Supersedes CEN/TR 15371:2006
English Version
Safety of toys - Replies to requests for interpretation of EN 71-1,
EN 71-2, and EN 71-8
Sécurité des jouets - Réponses aux demandes Sicherheit von Spielzeug - Antworten auf Anfragen zur
d'interprétation de l'EN 71-1, EN 71-2 et EN 71-8 Interpretation von EN 71-1, EN 71-2 und EN 71-8
This Technical Report was approved by CEN on 13 November 2008. It has been drawn up by the Technical Committee CEN/TC 52.
CEN members are the national standards bodies of Austria, Belgium, Bulgaria, Cyprus, Czech Republic, Denmark, Estonia, Finland,
France, Germany, Greece, Hungary, Iceland, Ireland, Italy, Latvia, Lithuania, Luxembourg, Malta, Netherlands, Norway, Poland, Portugal,
Romania, Slovakia, Slovenia, Spain, Sweden, Switzerland and United Kingdom.
EUROPEAN COMMITTEE FOR STANDARDIZATION
COMITÉ EUROPÉEN DE NORMALISATION
EUROPÄISCHES KOMITEE FÜR NORMUNG
Management Centre: rue de Stassart, 36  B-1050 Brussels
© 2009 CEN All rights of exploitation in any form and by any means reserved Ref. No. CEN/TR 15371:2009: E
worldwide for CEN national Members.

Contents Page
Foreword .3
Introduction .3
1 Scope .4
2 EN 71-1:2005 - Safety of toys – Part 1: Mechanical and physical properties (including
amendments A1, A3, A4, A5 and A6:2008) .4
2.1 3.30 and 3.31 Projectile toys (no action decision) .4
2.2 4.5 Glass (no action decision) .5
2.3 4.14.2 Masks and helmets (no action decision) .5
2.4 4.15.1.4 Stability (interpretation) .7
2.5 4.15.1.4; 8.23.1 Stability (interpretation) .7
2.6 4.15.1.6 c) Transmission and wheel arrangement (no action decision). 10
2.7 4.15.1.6 d) Transmission and wheel arrangement (no action decision) . 11
2.8 4.17 Projectiles (no action decision). 11
2.9 4.17 Projectiles (no action decision). 13
2.10 5 Toys intended for children under 36 months (re: inflatable toys) (interpretation) . 14
2.11 5.1 General requirements (re: small parts) (interpretation) . 14
2.12 5.1 General requirements (re: small parts) (interpretation) . 14
2.13 5.1 General requirements (re: fuzz) (no action decision) . 15
2.14 5.1 e) General requirements (re: glued wooden toys) (no action decision) . 15
2.15 5.2 Filling materials (interpretation) . 15
2.16 5.2 Filling materials (interpretation) . 16
2.17 5.4 Cords on toys (no action decision) . 16
2.18 5.7 Glass and porcelain (interpretation) . 16
2.19 5.8 Shape and size of certain toys (re: accessibility) (interpretation) . 17
2.20 5.8 Shape and size of certain toys (interpretation) . 17
2.21 5.13 Suction cups (no action decision) . 17
2.22 6 Packaging (no action decision) . 18
2.23 8.4.2.2 Seams and materials (interpretation) . 18
2.24 8.13 Flexibility of metallic wires (no action decision) . 19
2.25 8.28.1.4 Operating conditions (re: acoustics) (interpretation) . 19
2.26 8.28.2.4.3 Measurement results (re: acoustics) (interpretation) . 19
2.27 8.28.1.3 Mounting (re: acoustics) (no action decision) . 20
3 EN 71-2:2006 - Safety of toys – Part 2: Flammability (including amendment A1:2007) . 20
3.1 4.2.2 Beards, moustaches, wigs etc., . (interpretation) . 20
3.2 4.2.5 Flowing elements of toys . and 4.3 Toy disguise costumes . (interpretation) . 20
3.3 4.4 Toys intended to be entered by a child (interpretation) . 21
4 EN 71-8:2003 - Safety of toys – Part 8: Swings, slides and similar activity toys for indoor
and outdoor family domestic use (including amendment A1:2006) . 22
4.1 4.2.1 Barriers and handrails preventing the child from falling down (no action decision) . 22
4.2 4.2.2 a) Means of access to toys, and 4.5.4 Means of access to slides (interpretation) . 23
4.3 4.3.1 Head and neck entrapment . 23
4.4 4.3.1 a) Head and neck entrapment (no action decision) . 23
4.5 4.3.2 Entrapment of clothing and hair (no action decision) . 24
4.6 6.1 Stability (no action decision) . 24

Foreword
This document (CEN/TR 15371:2008) has been prepared by Technical Committee CEN/TC 52 ―Safety of
toys‖, the secretariat of which is held by DS.
This document supersedes CEN/TR 15371:2006.
Introduction
Interpretations and no-action decisions
This Technical Report contains replies to requests for interpretations concerning the understanding of clauses
in EN 71-1:2005, EN 71-2:2006 and EN 71-8:2003. The replies concern those requests that have resulted in
an interpretation or a decision that no action is required as the standard is sufficiently clear.

An interpretation does not have the same status as the text of the standard, nor can it overrule the text of the
standard. However, following an interpretation should give assurance that the relevant clause of the standard
has been correctly applied. An interpretation should only be regarded as a clarification of the meaning of the
standard.
Disclaimer
The interpretations have been derived by expert groups of CEN/TC 52. The information contained
herein is for guidance only and does not reflect the formal approval by CEN or CEN member bodies. It
should be noted that the interpretations are neither part of any standard nor have been referenced in
the Official Journal of the European Union.

Requests for interpretation
Requests for interpretations may be submitted by a CEN member body through its national committee or by a
CEN/TC 52 liaison (but not directly by an individual or a company) - in accordance with the interpretation
protocols agreed by CEN/TC 52. The requests are then channelled to the relevant TC 52 working party, which
will then deal with the request.
A request for an interpretation may lead to
a) An interpretation of the standard

This should reflect a reasonable interpretation of how the standard should be used, taking into account
the wording of the standard
the rationale of the standard
the history of the standard
b) A no-action decision
This is applicable when it is agreed that the standard appropriately specifies how a toy shall be assessed.

c) A proposal for an amendment of the standard

This is applicable when it is agreed that the standard is deficient in some way.

NOTE Interpretation and no-action decisions are published in CEN/TR 15371, which will be updated on a regular
basis.
Proposals for amendments will be progressed as new work item proposals in accordance with CEN rules.
Answers to requests for interpretations
Since requests for interpretations are submitted through a CEN member body, it is assumed that the member
body will keep itself informed about decisions concerning the request and its progress and will itself inform the
originator of the request as appropriate.
1 Scope
The purpose of this CEN Technical Report is to provide replies to requests for interpretations of
EN 71-1:2005, Safety of toys – Part 1: Mechanical and physical properties (including amendments A1, A3, A4,
A5 and A6:2008)
EN 71-2:2006, Safety of toys – Part 2: Flammability (including amendment A1:2007)
EN 71-8:2003, Safety of toys – Part 8: Swings, slides and similar activity toys for indoor and outdoor family
domestic use (including amendment A1:2006)
2 EN 71-1:2005 - Safety of toys – Part 1: Mechanical and physical properties
(including amendments A1, A3, A4, A5 and A6:2008)
2.1 3.30 and 3.31 Projectile toys (no action decision)
Question
EN 71-1 has the below definitions of projectiles with or without stored energy:
3.30
projectile toy with stored energy
toy with a projectile propelled by means of a discharge mechanism capable of storing and releasing energy

3.31
projectile toy without stored energy
toy with a projectile discharged by the energy imparted by a child

An example - a toy where the energy is imparted by e.g. a spring or an elastic band and the launching is
entirely controlled by the child, as the toy has no mechanism for holding back the projectile and storing the
energy for a prolonged time. Such a toy could be interpreted not to be included in 3.31. However, the toy is
obviously also not within 3.30 because we interpret 3.30 so that the toy must be capable to accumulate and
store the energy for a prolonged period of time without involvement of a child.
We would like to have a confirmation that a projectile toy, which cannot accumulate and store energy is within
3.31 even if a spring is used in launching the projectile.
We suggest rewording 3.31 to make this clear.
Reply
Standard is clear. In this case, the energy is not stored and released by a discharge mechanism but the
energy is imparted by the user. In consequence, this toy is regarded as a ―projectile toy without stored energy‖
REQ 064-06 (DS, Denmark)
2.2   4.5 Glass (no action decision)
Question
4.5 states that accessible glass may only be used for toys for children over 36 months where it is necessary
for the function of the toys (e.g. optical toys, glass light bulbs, glass in experimental sets).
Traditionally there are some creativity sets where glass is used, but where it is not clear whether the glass is
functional or not.
1 Should we consider the glass used in candle making set as functional?
2  What about a glass painting set intended to decorate glass objects?
Reply
The nature and use of this product (involving candles) means that EN 71-1 cannot address the safety. If this
product were sold as a toy, it would need to be EC Type examined.
The same may apply to glass painting sets but much would depend on the nature of each product.
REQ 057-05 (AFNOR, France)
2.3   4.14.2 Masks and helmets (no action decision)
Question
1) Subclause 4.14.2 of EN 71-1 states about masks the following:
“4.14.2 Masks and helmets
Mask and helmets shall conform to the following requirements:
a) Masks and helmets that fully enclose the head and which are made of impermeable material shall provide a
total ventilation area of 1300 mm minimum through at least two holes at least 150 mm apart or through any
equivalent single ventilation area.”
We understand reading this point that the requirement apply to all types of masks.
Nevertheless, There are several types of masks in the market according to their design and their material:
Masks that fully enclose the head (generally the area of the face with polymeric flexible material and the rest
with textile material with or without hair). Masks that enclose the head but not fully (generally the area of the
face with polymeric flexible material and the rest with textile material with or without hair).
Masks that only enclose the face.
The last ones have several designs, ones fit in the form of the face and others are more or less flat and are
made of flexible material, polymeric half-rigid material and even cardboard.
Taking into account that establishing the safety requirements to address risks is the target of the standard (in
this specific case, the risk of asphyxia that could happen to the children when using the masks), we have a
doubt regarding the below type of masks, which enclose only the face, because it is likely that not all the
mentioned masks could present the risk of asphyxia.
Therefore, there could be masks like the below ones that could not need to fulfil the requirements on 4.14.2 a)

2) Regarding the ventilation area required, we have a doubt about what has to be included in the mentioned
area, i.e. does the ventilation area only include the holes at the level of the nose and the mouth, or include the
holes at the level of the eyes too?
Reply
1) Requirements in 4.14.2 a) only apply to masks that fully enclose the head and which are made of
impermeable material therefore masks that cover the face and for which pictures are given are not covered by
this requirement.
2) All holes are to be taken into consideration whatever their position knowing that if only eye, nose and mouth
holes were considered the 150 mm requirement would conflict with the normal positioning of those holes for a
correct use and should never been fulfilled.
REQ 048-04 (AENOR, Spain)
2.4  4.15.1.4 Stability (interpretation)
Question
Is the lateral stability test applicable to a two wheels toy motorbike intended for children over 3 years of age,
for which removable stabilizers are provided, considering that the toy can be operated by the child when
stabilizers are removed?
Interpretation
This toy shall be considered as toy where the feet of the child can provide sideways stability and therefore
excluded from the 4.15.1.4 requirements.
REQ 046-04 (AENOR, Spain)
2.5 4.15.1.4; 8.23.1 Stability (interpretation)
Question (UNI, Italy))
EN 71-1 requires, for the stability test, to ―load the toy in the most onerous position with a mass […] on its
standing or sitting surface‖.
Our interpretation of this requirement is ―Load the toy in the most onerous position on the standing or sitting
surface, in such a way the mass is perpendicular to the standing or sitting surface and that the vertical
projection of the base of the test mass is fully enclosed in the sitting surface. If the standing or sitting surface
is narrower than the test mass, the centre of the test mass shall be positioned along the axis of the seat.‖
Applying this interpretation, a correct position to place the test mass for the front stability is shown in the
following pictures (please, do not consider the position of the toy on the inclined plane, it is just an example).

If we do not apply this interpretation every laboratory can try to find any improbable sitting surface like in the
following examples:
We consider that all the above examples represent a not correct way to perform the test: in the first row
example, the mass is not perpendicular to the sitting surface, in the second and in the third rows, the mass
base is outside the sitting surface.
In the third row, someone can argue that the ring allows the placing of the mass without any external support,
but if we consider applying this interpretation, we will again have problems. Actually, EN 71-1 Figure 21 does
not define the sides of the test mass. Since the test mass does not need to be a perfect cylinder, also the test
mass for the dynamic test defined in Figure 23 may be used. Since the position of the test mass on ride on
toys with armrest may be significantly influenced (if we agree with this interpretation) by the sides of the test
mass, we will have for sure different test results, depending on the kind of the test mass used.

We can also have even more improbable test conditions like the following:

According to our opinion, the correct interpretation is ―load the toy in the most onerous position on the
standing or sitting surface, in such a way the mass is perpendicular to the standing or sitting surface and that
the vertical projection of the base of the test mass is fully enclosed in the sitting surface. If the standing or
sitting surface is narrower than the test mass, the centre of the test mass shall be positioned along the axis of
the seat". Thus between the two positions shown in the following examples, in case we are considering the
frontal stability, it is the second (the one with the test mass with its base in contact with the front edge of the
seat) to be considered as the most onerous condition (in the other one, the test mass is just centred on the
seat, and thus this is not the most onerous position). Nevertheless, allowing laboratories to place the mass
with its base outside the sitting surface would lead to have no more repeatable tests.

We also consider that a stability test for ride on toys with child rings or armrests should be developed, like the
test method to test ride on toys with backrest, which is currently being developed by TG 6 (We suggest that for
armrest, the test mass should be further decreased to 9 kg).
Question (BSI, United Kingdom)
The clause states ―Load the toy in the most onerous position‖ Can this be clarified as to whether the
weight/mass is loaded in the most onerous position or the toy is placed in the most onerous position with the
test mass located in the ―normal‖ position of use?

Comments/proposal for an answer: Believed that the test mass should be placed on the seat (or standing
position) to the extremity of the seat, but within the confines of the seat, i.e. not overhanging the seat.
Also, the test mass should remain perpendicular to the plane of the seat, when placed on the 10° slope.
Interpretation
Before placing the toy on the slope, the mass shall be placed on the sitting or standing surface so that the
main axis of the mass remains as close as vertical as possible without any additional support between the
mass and the sitting or standing surface. If the sitting or standing surface is larger than the base of the test
mass, the test shall be performed placing the mass on the sitting or standing surface in the most onerous
position(s) with regards to stability and shall remain within the sitting or standing surface. It is allowed to use
e.g. tape, straps, etc. to maintain the mass in position when the toy is placed on the slope.
REQ 070-06 (UNI, Italy); REQ 074-07 (BSI, United Kingdom)
2.6   4.15.1.6 c) Transmission and wheel arrangement (no action decision)
Question
During testing of a battery-operated ride on car (shown below), it was noted that there was a gap of
approximately 6 mm between a wheel and the adjacent motor housing (see illustration).
It is clear from 4.15.1.6 c) of EN 71-1 that the product fails:
Text of standard
c) Spaces between the wheels and the body or parts of the body (e.g. mudguards) shall, if they allow a 5 mm
diameter rod to be inserted, also allow a 12 mm diameter rod to be inserted.
Is this an accurate understanding of the standard?

View of back of car                       5 mm plug gauge inserted in gap
The UK committee agreed that the product apparently failed the technical requirements of
4.15.1.6 c) of EN 71-1and that that subclause was applicable to the toy in question and has asked me to
forward this enquiry to CEN TC52/TG1 for a further interpretation and action as necessary.
Reply
The standard adequately treats this case. The 5/12 mm requirement only applies to areas capable of crushing
fingers or other parts of the body if entrapped considering the normal and foreseeable use of the toy.
Reference is made to EN 71-1 Annex A, second sentence of A.20: ―the requirements are also intended to
address the hazards associated with chain transmissions and wheel arrangements capable of crushing fingers
and other parts of the body if entrapped‖
REQ 054-05 (BSI, United Kingdom)
2.7   4.15.1.6 d) Transmission and wheel arrangement (no action decision)
Question
Subclause 4.15.1.6 d) states:
―Tricycles, provided with an attached handle used for pushing the child, shall be constructed in such a way as
to prevent entrapment of the child’s feet in the pedals, etc whilst being pushed, (e.g. free-wheeling mechanism
or foot rests).‖
If a free-wheeling mechanism is present, subclause 4.15.1.5 requires a mechanically propelled toy to have a
braking device.
It is very difficult for a manufacturer to add a brake to a tricycle. Therefore, one possible solution (in my
opinion) is to manufacture the tricycle with the option of having the front wheel (with pedals) set as either a
fixed wheel or free-wheeling, with accompanying instructions clearly informing the parent to set it as free-
wheeling if the parent handle is attached, or fixed wheel if the handle is not attached (I have seen several like
this on the market).
However, subclause 4.15.1.5 excludes ―toys where hands or feet provide the motive power to the driving
wheel(s) via direct transmission (e.g. pedal cars, tricycles).‖
It is our belief that this exclusion was written prior to the addition of subclause 4.15.1.5 d) in the 1998 edition,
when all tricycles were of the traditional fixed wheel design. This exclusion is therefore, in my opinion, not
valid if the tricycle has a free-wheel mode.
A.20 also excludes tricycles with pedals on the front wheel, but again, I believe this rationale was written with
only fixed wheel tricycles in mind.
The point here is that a retailer wishes to supply a free-wheeling tricycle with a parent handle and no brake. If
the parent handle is removed, the child will be riding a free-wheeling toy with no means of braking, usually
performed by the child putting his feet on the pedals (I do not hold with a suggested view that the child can
brake the tricycle by putting his feet on the ground, since this is likely to lead to foot entrapment by the frame
or rear wheels. Remember that subclause 4.15.1.6 d) requires a tricycle with a parent handle to have foot
rests, for example, for the very reason of keeping the child’s feet away from moving parts).
Would the group agree that the exclusion in subclause 4.15.1.5 is not valid in this instance?
Reply
The standard, as it is currently, adequately addresses this case. This kind of toy would require a brake.
However, TG 1 recommends TC 52/WG 3/TG 6 – Bicycles, scooters and ride-on toys to consider this request
and associated concerns.
REQ 055-05 (BSI, United Kingdom)
2.8   4.17 Projectiles (no action decision)
Question
Our question is that whether the toy product said to be DRONE (containing plastic darts with resilient material
point and a plastic target, and the darts are designed to be thrown by hand of a child upon the target) is
considered as a ―projectile toy‖ according to the given definition of EN 71. On the other hand, simply to say
that the question is whether a toy intended to be thrown by hand of a child but not to be launched by a
mechanism is considered as a ―projectile‖ according to EN 71.
The following is the relevant subclauses of EN 71:
3.29 projectile: Object intended to be launched into free flight, or a trajectory, in the air.
3.30 projectile toy with stored energy: Toy with a projectile propelled by means of a discharge mechanism
cable of storing and releasing energy.
3.31 projectile toy without stored energy: Toy with a projectile discharged by the energy imparted by a child.
4.17 Projectile (see A.22)
4.17.1 General
4.17.2 Projectile toy without stored energy
4.17.3 Projectile toy with stored energy
A.22 Projectiles (see 4.17)
"These requirements are intended to address certain, but not all, potentially unexpected hazards associated
with firing toys and by the firing of improvised projectiles from such toys.
A toy in which the kinetic energy is determined by the toy and not by t
...