CEN/TR 15371:2013

SLOVENSKI STANDARD
01-april-2013
1DGRPHãþD
SIST-TP CEN/TR 15371:2009
9DUQRVWLJUDþ2GJRYRULQD]DKWHYHSRLQWHUSUHWDFLMLVWDQGDUGRY(1(1
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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, l'EN 71-2 et
l'EN 71-8
Ta slovenski standard je istoveten z: CEN/TR 15371:2013
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
February 2013
ICS 97.200.50 Supersedes CEN/TR 15371:2009
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, l'EN 71-2 et l'EN 71-8 Interpretation von EN 71-1, EN 71-2 und EN 71-8

This Technical Report was approved by CEN on 13 August 2012. It has been drawn up by the Technical Committee CEN/TC 52.

CEN members are the national standards bodies of Austria, Belgium, Bulgaria, Croatia, Cyprus, Czech Republic, Denmark, Estonia,
Finland, Former Yugoslav Republic of Macedonia, France, Germany, Greece, Hungary, Iceland, Ireland, Italy, Latvia, Lithuania,
Luxembourg, Malta, Netherlands, Norway, Poland, Portugal, Romania, Slovakia, Slovenia, Spain, Sweden, Switzerland, Turkey and United
Kingdom.
EUROPEAN COMMITTEE FOR STANDARDIZATION
COMITÉ EUROPÉEN DE NORMALISATION

EUROPÄISCHES KOMITEE FÜR NORMUNG

Management Centre: Avenue Marnix 17, B-1000 Brussels
© 2013 CEN All rights of exploitation in any form and by any means reserved Ref. No. CEN/TR 15371:2013: E
worldwide for CEN national Members.

Contents Page
Foreword .4
0 Introduction .5
0.1 Interpretations and no-action decisions .5
0.2 Requests for interpretation .5
0.3 Answers to requests for interpretations .5
1 Scope .6
2 EN 71-1:2011 - Safety of toys – Part 1: Mechanical and physical properties .6
2.1 3.41 and 3.42 Projectile toys (no action decision) .6
2.2 3.41, 3.42 and 7.7 Projectile toys (no action decision) .6
2.3 4.3 Flexible plastic sheeting (no action decision) .8
2.4 4.4 Toy bags (no action decision) .9
2.5 4.5 Glass (no action decision) .9
2.6 4.10.1 c) folding and sliding mechanisms (no action decision) .9
2.7 4.14.2 Masks and helmets (no action decision) . 10
2.8 4.15.1.4 Stability (interpretation) . 11
2.9 4.15.1.4; 8.23.1 Stability (interpretation) . 11
2.10 4.15.1.6 c) Transmission and wheel arrangement (no action decision). 14
2.11 4.15.1.6 d) Transmission and wheel arrangement (no action decision) . 15
2.12 4.17 Projectiles (no action decision). 16
2.13 4.19 Percussion caps (no action decision) . 18
2.14 4.20 Acoustics (Re: Squeeze toys) (no action decision) . 18
2.15 5 Toys intended for children under 36 months (re: inflatable toys) (interpretation) . 19
2.16 5.1 General requirements (re: small parts) (interpretation) . 19
2.17 5.1 General requirements (re: small parts) (interpretation) . 19
2.18 5.1 General requirements (re: fuzz) (no action decision) . 19
2.19 5.1 General requirements (re: plastic whiskers) (interpretation) . 20
2.20 5.1 General requirements (no action decision) . 20
2.21 5.1 e) General requirements (re: glued wooden toys) (no action decision) . 21
2.22 5.1 e) General requirements (re: paper, varnish) (interpretation) . 21
REQ 092-09 (PKN - Poland) . 22
2.23  5.7 Glass and porcelain (interpretation) . 22
2.24 5.8 Shape and size of certain toys (re: accessibility) (interpretation) . 22
2.25 5.8 Shape and size of certain toys (interpretation) . 23
2.26 5.8 Shape and size of certain toys (re: squeeze toys) (no action decision) . 23
2.27 5.10 Small balls (no action decision) . 23
2.28 6 Packaging (no action decision) . 27
2.29 . 7.2 Toys not intended for children under 36 months & 7.3 latex balloons (re: warning)
(no action decision) . 27
2.30 8.4.2.2 Seams and materials (interpretation) . 28
2.31 8.13 Flexibility of metallic wires (no action decision) . 28
2.32 8.23.1 Stability – Toys intended to bear the mass of a child (no action decision) . 29
2.33 8.25.1.1 Plastic sheeting - apparatus (interpretation) . 29
2.34 8.28.1.3 Mounting (re: acoustics) (no action decision) . 31
2.35 8.28.1.4 Operating conditions (re: acoustics) (interpretation) . 31
2.36 8.28.2.4.3 Measurement results (re: acoustics) (interpretation) . 31
3 EN 71-2:2011 - Safety of toys – Part 2: Flammability . 32
3.1 Applicability of clauses 4.1 to 4.2.5 (supporting document to the revised version of EN 71-
2: 2011) . 32
3.2 4.2.2 Beards, moustaches, wigs etc., . (interpretation) . 37
3.3 4.2.5 Flowing elements of toys . and 4.3 Toy disguise costumes . (interpretation) . 37
3.4 4.3 Toys disguise costumes and toys intended to be worn by a child in play
(interpretation) . 37
3.5 4.4 Toys intended to be entered by a child (interpretation) . 38
3.6 5.4.1 Preparation of test sample (no action decision) . 39
3.7 5.4.1 Preparation of test sample (interpretation) . 40
3.8 5.4.1 Preparation of test sample (interpretation) . 41
4 EN 71-8:2011 - Safety of toys – Part 8: Activity toys for domestic use . 41
4.1 4.2.1 Barriers and handrails preventing the child from falling down (no action decision) . 41
4.2 4.3.1 Head and neck entrapment . 42
4.3 4.3.1 a) Head and neck entrapment (no action decision) . 42
4.4 4.3.2 Entrapment of clothing and hair (no action decision) . 42

Foreword
This document (CEN/TR 15371:2013) has been prepared by Technical Committee CEN/TC 52 “Safety of
toys”, the secretariat of which is held by DS.
Attention is drawn to the possibility that some of the elements of this document may be the subject of patent
rights. CEN [and/or CENELEC] shall not be held responsible for identifying any or all such patent rights.
This document supersedes CEN/TR 15371:2009.
0 Introduction
0.1 Interpretations and no-action decisions
This Technical Report contains replies to requests for interpretations concerning the understanding of clauses
in EN 71-1:2011, EN 71-2:2011 and EN 71-8:2011. 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.

0.2 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.
0.3 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 Technical Report is to provide replies to requests for interpretations of EN 71-1:2011,
Safety of toys – Part 1: Mechanical and physical properties, EN 71-2:2011, Safety of toys – Part 2:
Flammability and EN 71-8:2003, Safety of toys – Part 8: Activity toys for domestic use.
2 EN 71-1:2011 – Safety of toys – Part 1: Mechanical and physical properties
2.1 3.41 and 3.42 Projectile toys (no action decision)
Question
EN 71-1 has the below definitions of projectiles with or without stored energy:
3.41
projectile toy with stored energy
toy with a projectile propelled by means of a discharge mechanism capable of storing and releasing energy

3.42
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 3.42. However, the toy is
obviously also not within 3.41 because we interpret 3.41 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
3.42 even if a spring is used in launching the projectile.
We suggest rewording 3.42 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  3.41, 3.42 and 7.7 Projectile toys (no action decision)
Question
Even if we are aware of the ongoing discussion about the revision on projectiles requirements, we ask to give
an official interpretation of the following issue to interpret correctly the current version of the standard.
1) EN 71-1 defines as projectile an “object intended to be launched into free flight or a trajectory in the air”

a) does this include toys like boomerang or frisbee?
b) does this include small toys designed in such a way that hitting their base, they make a little jump,
rotating on themselves? (to figure them think about a spoon on a table: hitting its extremity you can
have it make this kind of jump)
c) does it include objects launched by catapult toys?
2) If a toy has a spring or an elastic band, but no mechanism to hold the projectile in the “charged” condition
(this means that as soon as you release the projectile, it is launched, like in a bow), is it considered “projectile
toy with stored energy” (the spring and elastic are considered as discharge mechanisms) or as a “projectile
toy without stored energy” (the energy of the projectile depend upon how much the child put the projectile into
the toy, like a bow, even if, differently form bows, in this case usually there is an “end of stroke” and the
maximum projectile energy is defined)?

3) 7.7 defines two warnings: not to use different projectiles from the supplied ones and not to aim at eyes or
face.
We consider the first one applicable to all the projectile toys from which a generic projectile may be launched
(for example projectile toy with stored energy or bows), but not applicable for toys without stored energy like
catapults (4.17.2 does not give any reference to 7.7).
Instead we consider the second warning (“Aim at face”) applicable only to projectiles toys with stored energy
or bows with a kinetic energy greater than 0.08J.
Is it correct?
Reply
NO ACTION DECISION
1a) Standard is clear those toys enter into the projectiles definition.
1b) Standard is clear those toys enter into the projectiles definition.
1c) Standard is clear those toys enter into the projectiles definition (provided those “catapults” do not enter
into the exclusion list as outlined into EN71-1 scope).
2) Standard is clear this is a “projectile toy without stored energy” (see 3.42 definition) provided the described
item is not regarded as a catapult and therefore enters into the exclusion list as outlined into EN 71-1 scope.
3) Standard is clear for projectile toys with stored energy in 4.17.3 c). If a discharge mechanism is able to
discharge an object other than that provided with the toy, then labelling according to 7.7.1 is required. If a toy
is capable of discharging a projectile with a kinetic energy greater than 0,08 J, labelling according to 7.7.2 is
required. If a toy meets both conditions then the two labelling are required
Bows and arrows shall only bear “Warning. Do not aim at eyes or face” under the conditions outlined in 4.17.4
c)
REQ 076-07 Part 1 (UNI, Italy)
2.3 4.3 Flexible plastic sheeting (no action decision)
Question 1
Clause 4.3 applies only to plastic sheeting having dimensions greater than 100 mm X 100 mm.
If a plastic bag has a dimension of 100 mm X 80 mm, as it is, does the requirement apply?

Question 2
If we consider the plastic bag, its dimension is less than 100 mm X 100 mm, but if we consider the plastic
sheeting, cutting the plastic bag along two edges, we can get a 100 mm X 160 mm (80 mm X 2).
But, especially if the toy is intended only for children over 36 months of age, it is not required to apply any
cutting.
And, if the toy is intended for children under 36 months of age, and we apply the tension test to the bag,
before to break it into a plastic sheet, it is foreseeable that the applied 90 N force will elongate the plastic
sheeting and thus will also make it having a thinner thickness.
Moreover, the test method of 8.25.1.2 reads ”For plastic bags, cut along the seams without stretching the bag
so that two single sheets are produced.”.
But this test method is referred both by 4.3 and by Clause 6 (which does not apply to toy bags which have a
play value in the toy).
In our opinion the need to cut the bag along the seams is referred to packaging bags, and not to plastic
sheeting addressed by 4.3. The reason for this interpretation is that in case of bags with an opening perimeter
greater than 380 mm (as required by Clause 6), the child can put his head inside the bag and so it can have
on his nose and mouth just one sheet of the twos forming the bag.
But if 4.3 is not applicable to plastic bags, but to plastic sheeting only, we can have plastic bags with an
opening perimeter less than 380 mm and with a thickness of less than 0,038 mm both for packaging and for
bags having a play value (4.4 does not require a minimum thickness and Clause 6 defines a minimum
thickness only for plastic bags with an opening perimeter greater than 380 mm).
The reason for this may be that bags (in which the child cannot put his head), having a double layer, are less
foreseeable to become attached to a child's face in such a way to cause asphyxiation, differently from single
layer plastic sheeting (this is just a supposition). Thus, one of the following should apply:
1) If the sheet is in a form of a plastic bag, its whole area shall be measured (not the area of the plastic bag,
and thus the area which is the sum of the two layers area). The measurements are performed before any
mechanical test.
2) For plastic bags only the area of the plastic bag (double layer) shall be taken into account. The
measurements are performed before any mechanical test.
3) The area and the thickness of the plastic bags shall be measured after the mechanical tests (which ones,
especially in the case of toys intended for children above 36 months of age?).
Which one is the correct one?
Reply
To question 1: The requirement does not apply
To question 2: Option 2 is the correct one
REQ 090-09 (UNI, Italy)
2.4 4.4 Toy bags (no action decision)
Question
In EN 71-1 there is a specific requirement for toy bags (4.4), which applies to toy bags with an opening
perimeter greater than 380 mm and having a drawstring as means of closure.
But what shall be done if the bag has a perimeter smaller than 380 mm and it is made of a plastic sheet?
Reply
4.4 is not applicable and 4.3 should be considered.
REQ 089-09 (UNI, Italy)
2.5 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 toy (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)
2.6  4.10.1 c) folding and sliding mechanisms (no action decision)
Question
The below toy is an ironing board made of plastic material with a height of 25 cm. It is intended to be used on
a table (child is then standing up) or can also be placed on the ground (the child is sitting in front of the table).
The legs of the ironing board are folding ones and present a scissor like action.
Are the requirements from 4.10.1 c) required for this type of toy?
Reply
Standard is clear, 4.10.1c applies since the legs of the ironing board are folding ones and present a scissor
like action.
REQ 085-08 (AFNOR, France)
2.7  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 or more 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)
2.8  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)
2.9 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)
2.10  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 also allow a 12 mm
diameter rod to be inserted if they allow a 5 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 71-1 and 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)
2.11   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, 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 drive or free-wheeling, with accompanying instructions clearly informing the parent to set it as free-
wheeling if the parent handle is attached, or fixed drive if the handle is not attached (I have seen several like
this on the market).
However, 4.15.1.5 excludes “toys where hands or feet provide the motive power to the driving wheel(s) via
direct transmission”.
It is our belief that this exclusion was written prior to the addition of 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 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 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.
REQ 055-05 (BSI, United Kingdom)
2.12  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:
3.40 projectile: Object intended to be launched into free flight or a trajectory in the air.
3.41 projectile toy with stored energy: Toy with a projectile propelled by means of a discharge mechanism
capable of storing and releasing energy.
3.42 projectile toy without stored energy: Toy with a projectile discharged by the energy imparted by a child.
4.17 Projectiles (see A.22)
4.17.1 General
4.17.2 Projectile toys without stored energy
4.17.3 Projectile toys with stored energy
A.22 Projectiles (see 4.17)
"These requirements are intended to address certain but not all potentially unexpected hazards associated
with projectile 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 the child is typically a gun or other
spring-loaded device. A pea-shooter is an example of a toy with a projectile (a pea) of which the kinetic energy
is determined by the child by blowing."
We notice that there are two key words in the above subclauses: “launch” and “firing”. According to the
normal understanding of people, the meaning of the two words is to shoot something into the sky using a
discharge mechanism but not throw something by hand.
In addition, we also notice that in EN 71 Part 1 A.22, which is the explanation of the requirements of 4.17,
there is an important statement that again leads people to regard projectile as an object, which is shot by a
discharge mechanism. The statement is: “These requirements are intended to address certain, but not all,
potentially unexpected hazards associated with projectile firing toys and by the firing of improvised projectiles
from such toys.” The statement tells us what is the most important thing concerned in the EN 71 projectile
4.17. That is the hazards caused by projectiles that are fired by a mechanism.
Furthermore, in A.22, there are two examples used to explain two definitions --“a toy in which the kinetic
energy is determined by the toy and not by the child” and “a toy in which the kinetic energy is determined by
the child”. Both of the examples are projectile toys where the projectile is shot by a discharge mechanism. The
example lead us to understand that “a toy in which the kinetic energy is determined by the child” refer to the
projectile toy of which the projectile is fired through a mechanism but not thrown by hand. Since in 4.17 these
two definitions are not mentioned, naturally we regard “a toy in which the kinetic energy is determined by the
toy and not by the child” as “projectile toy with stored energy”. In addition, “a toy in which the kinetic energy is
determined by the child” as “projectile toy without stored energy”
In order to verify the above understanding, we also refer to another international toy standard of ASTM F963-
96a.
The following is the relevant subclauses of ASTM F963-96a:
3.1.25: Projectile -- an object propelled by means of a discharge mechanism capable of storing and
releasing energy under the control of the operator.
4.20: Projectile Toys – These requirements relate to certain, but not all, potential, unexpected hazards that
might be caused by projectile firing toys and by the firing of improvised projectiles from such toys. Certain
well-recognised hazards that are inherent in traditional toys such as slingshots and darts are not
covered by these requirements.
4.20.1: These requirements apply to toys that are intended to launch projectiles into free flight by means of a
discharge mechanism in which the kinetic energy of the projectile is determined by the toy and not by the user.
4.20.1.5: The aforementioned requirements shall not apply to any discharge mechanism incapable of storing
energy independent of the user.
It is very clear that in ASTM toys intended to be thrown by hand are not projectile toys. Moreover, in ASTM,
“projectile toy” is also divided into two kinds: “projectile toy with stored energy” and “projectile toy without
stored energy”. The projectile requirements of ASTM are not applicable to “projectile toy without stored
energy” but the requirements of EN 71 do.
After the study of the relevant clauses of EN 71 and making reference to the above mentioned clauses of
ASTM F963-96a, we may get the following understanding about EN 71 projectile clauses: “Projectile toy with
stored energy” may be regarded as the toys that are intended to launch projectiles into free flight by means of
a discharge mechanism in which the kinetic energy of the projectile is determined by the toy and not by the
child, such as a gun or other spring-loaded device. And “projectile toy without stored energy” may be regarded
as toys having discharge mechanism incapable of storing energy independent of the child and the kinetic
energy is determined by the child, such as A pea-shooter mentioned in A.22, bows and arrows, slingshots etc.
To sum up all above, we may draw a conclusion that in both EN 71 and ASTM F963, the real meaning of
“projectile” is a toy having discharge mechanism. In addition, the real purpose to set up projectile testing
clauses is to reduce the potentially unexpected hazards that might be caused by projectile firing toys and by
the firing of improvised projectiles from such toys.
Please note that this conclusion is not only based on the above study, but also on our testing practice. We
found that in practice there were many kinds of toys intended to be thrown by hand of a child that would not be
treated as projectile by all other laboratories, for example small planes and baseballs etc. The requirements of
EN 71 projectile clauses are not applicable and suitable for these toys. These requirements are also not
suitable for dart game intended to be thrown by hand of a child. Otherwise, most of these toys in market will
not comply with EN 71. For example dart fitted with magnetic metal disc, if it is treated as projectile, the disc
according to EN 71 projectile clause. We have seldom seen such dart
shall have a minimum area of 3 cm
with a big point. We think it is more dangerous because of the weight of the big point. If it is thrown to a child’s
face or head, it is likely to cause a hole hurt.
Reply
The definition included in 3.40 of EN 71-1 indicates:
"Projectile: Object intended to be launched into free flight or a trajectory in the air"
Launching something in the air can be produced through a discharge mechanism (kinetic energy determined
by the toy only) or with hands (kinetic energy determined by child strength).
As the hazard associated with projectiles does not depend on the fact that they are launched or not through a
discharge mechanism, it is considered that all types of projectiles, with or without stored energy and with or
without discharge mechanism are covered by 4.17 of EN 71-1, the applicability of the different subclauses
being determined by the nature of the projectiles and the way they are launched.
REQ 026-03 (EU Commission)
2.13 4.19 Percussion caps (no action decision)
Question
Clause 4.19 requires that an indication of the make and model of percussion caps to be used shall be printed
on the toy.
The toy shall carry also the warning of clause 7.14, i.e. “Warning. Do not use close to the ear! Misuse may
cause damage to hearing. Do not fire indoors! Use only percussion caps recommended by the manufacturer”.
Clause 4.19 states that the warning may alternatively be placed on the packaging.
Some laboratories interpret that also the make and model of percussion caps may alternatively be placed on
the packaging. Is it correct?
Reply
Standard is clear, the make and model shall appear on the toy.
REQ 100-09 (UNI, Italy)
2.14 4.20 Acoustics (Re: Squeeze toys) (no action decision)
Question
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