CEN/TR 15371:2014

SLOVENSKI STANDARD
01-julij-2014
1DGRPHãþD
SIST-TP CEN/TR 15371:2013
9DUQRVWLJUDþ2GJRYRULQD]DKWHYHSRLQWHUSUHWDFLMLVWDQGDUGRY(1(1
LQ(1
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 and 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 15371:2014
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
May 2014
ICS 97.200.50 Supersedes CEN/TR 15371:2013
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 20 April 2014. 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

CEN-CENELEC Management Centre: Avenue Marnix 17, B-1000 Brussels
© 2014 CEN All rights of exploitation in any form and by any means reserved Ref. No. CEN/TR 15371:2014 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 .6
1 Scope .7
2 EN 71-1:2011 – Safety of toys – Part 1: Mechanical and physical properties .7
2.1 3.11 Cord (no action decision) .7
2.2 3.28 Fuzz (no action decision) .7
2.3 3.31 Large and bulky toy (interpretation) .8
2.4 3.41 and 3.42 Projectile toys (no action decision) . 10
2.5 3.41, 3.42 and 7.7 Projectile toys (no action decision) . 11
2.6 4.3 Flexible plastic sheeting (no action decision) . 12
2.7 4.4 Toy bags (no action decision) . 13
2.8 4.5 Glass (no action decision) . 13
2.9 4.9 Protruding parts (interpretation) . 14
2.10 4.10.1 c) folding and sliding mechanisms (no action decision) . 15
2.11 4.10.3 Hinges and rationale A.13 (interpretation) . 15
2.12 4.11 Mouth-actuated toys and other toys intended to be put in the mouth (interpretation) . 16
2.13 4.14.2 Masks and helmets (no action decision) . 17
2.14 4.15.1.2 Warnings and instructions for use (no action decision) . 18
2.15 4.15.1.4 Stability (interpretation) . 19
2.16 4.15.1.4; 8.23.1 Stability (interpretation) . 19
2.17 4.15.1.6 c) Transmission and wheel arrangement (no action decision). 21
2.18 4.15.1.6 d) Transmission and wheel arrangement (no action decision) . 22
2.19 4.15.5.7 Toy scooters – protruding parts (interpretation) . 23
2.20 4.17 Projectiles (no action decision). 23
2.21 4.18 Aquatic toys and inflatable toys (no action decision) . 26
2.22 4.18 Aquatic toys and inflatable toys (interpretation) . 26
2.23 4.19 Percussion caps (no action decision) . 26
2.24 4.20 Acoustics (Re: Squeeze toys) (no action decision) . 27
2.25 5 Toys intended for children under 36 months (re: inflatable toys) (interpretation) . 27
2.26 5.1 General requirements (re: small parts) (interpretation) . 27
2.27 5.1 General requirements (re: small parts) (interpretation) . 28
2.28 5.1 General requirements (re: fuzz) (no action decision) . 28
2.29 5.1 General requirements (re: plastic whiskers) (interpretation) . 28
2.30 5.1 General requirements (no action decision) . 29
2.31 5.1 General requirements (no action decision) . 30
2.32 5.1 General requirements (no action decision) . 31
2.33 5.1 e) General requirements (re: glued wooden toys) (no action decision) . 31
2.34 5.1 e) General requirements (re: paper, varnish) (interpretation) . 31
2.35 5.1 e) General requirements (re: stickers, varnish, coating) (interpretation) . 32
2.36 5.2 Soft-filled toys and soft-filled parts of a toy (no action decision) . 32
2.37 5.4 Cords, chains and electrical cables in toys (no action decision) . 33
2.38 5.4 Cords, chains and electrical cables in toys (interpretation) . 33
2.39 5.4 g) Cords, chains and electrical cables in toys (interpretation) . 34
2.40 5.7 Glass and porcelain (interpretation) . 36
2.41 5.8 Shape and size of certain toys (re: accessibility) (interpretation) . 36
2.42 5.8 Shape and size of certain toys (interpretation) . 37
2.43 5.8 Shape and size of certain toys (re: squeeze toys) (no action decision) . 37
2.44 5.10 Small balls (no action decision) . 37
2.45 5.12 Hemispheric-shaped toys (no action decision) . 41
2.46 6 Packaging (no action decision) . 42
2.47 7.1 Warnings, markings and instructions for use – General (no action decision) . 42
2.48 7.1 Warnings, markings and instructions for use – General (no action decision) . 42
2.49 7.2 Toys not intended for children under 36 months & 7.3 latex balloons (re: warning) (no

action decision) . 43
2.50 8.4.2.2 Seams and materials (interpretation) . 44
2.51 8.13 Flexibility of metallic wires (no action decision) . 44
2.52 8.23.1 Stability – Toys intended to bear the mass of a child (no action decision) . 44
2.53 8.25.1.1 Plastic sheeting - apparatus (interpretation) . 45
2.54 8.28.1.3 Mounting (re: acoustics) (no action decision) . 47
2.55 8.28.1.4 Operating conditions (re: acoustics) (interpretation) . 47
2.56 8.28.2.4.3 Measurement results (re: acoustics) (interpretation) . 47
3 EN 71-2:2011 - Safety of toys – Part 2: Flammability . 48
3.1 Applicability of clauses 4.1 to 4.2.5 (supporting document to the revised version of EN 71-

2: 2011) . 48
3.2 4.2.2 Beards, moustaches, wigs etc., . (interpretation) . 53
3.3 4.2.5 Flowing elements of toys . and 4.3 Toy disguise costumes . (interpretation) . 53
3.4 4.3 Toys disguise costumes and toys intended to be worn by a child in play

(interpretation) . 54
3.5 4.4 Toys intended to be entered by a child (interpretation) . 54
3.6 5.4.1 Preparation of test sample (no action decision) . 56
3.7 5.4.1 Preparation of test sample (interpretation) . 57
3.8 5.4.1 Preparation of test sample (interpretation) . 58
4 EN 71-8:2011 - Safety of toys – Part 8: Activity toys for domestic use . 59
4.1 3.7 Forced movement (no action decision) . 59
4.2 4.2.1 Barriers and handrails preventing the child from falling down (no action decision) . 59
4.3 4.3.1 Head and neck entrapment . 60
4.4 4.3.1 a) Head and neck entrapment (no action decision) . 60
4.5 4.3.2 Entrapment of clothing and hair (no action decision) . 61
4.6 4.6.7 Suspension connectors and swing devices (no action decision) . 61
4.7 4.6.8.3 Geometry and design of swing elements (no action decision) . 62

Foreword
This document (CEN/TR 15371:2014) 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 shall not be held responsible for identifying any or all such patent rights.
This document supersedes CEN/TR 15371:2013.
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 or a CEN TC 52 liaison, it is
assumed that they will keep themselves informed about decisions concerning the request and its progress
and will themselves 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 71-8:2011, 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 3.11 Cord (no action decision)
Question
The question relates to 3.11 “cord” of EN 71-1.
The standard defines cord as:
“length of flexible textile or non-textile material including elastic material, monofilament polymeric material,
tape, ribbon, rope, strap, woven and twisted material and string as well as certain weak and long springs”
Soft filled parts of a soft filled toy are not included by the definition of cord. Therefore, the requirements of 5.4
shall not be applied to those parts.
In the example provided, the tail of Figure 1 and the toy of Figure 3 are soft filled, while the tail of Figure 2 is
not soft filled, therefore 5.4 is applicable only to the tail of Figure 2. Is it correct?

Figure 1 Figure 2 Figure 3
Reply
Standard is clear. Soft-filled parts of toys are not cords as defined in the standard. The tail of the toy in Figure
2 is considered a cord because there is not stuffing material inside.
REQ 104-12 (UNI, Italy)
2.2 3.28 Fuzz (no action decision)
Question
The question relates to 3.28 “fuzz” of EN 71-1.
Some soft filled toys may have fur with long hairs, even longer than 50 mm. We do know that such hairs are
not to be considered as monofilament fibres.
If the toy loses these hairs when pet (as per foreseeable use), as in the attached picture, even in great
amount, is it correct to consider these hairs included in the definition of fuzz, therefore excluding them from
the requirements of 5.1?
Reply
Standard is clear. It is correct to consider the described fibres as fuzz (which is excluded from 5.1
requirements).
REQ 105-12 (UNI, Italy)
2.3 3.31 Large and bulky toy (interpretation)
Question
How do you measure the volume of large and bulky toys as defined in 3.31 of EN 71-1?
Here are two possible ways. Option A or Option B (see drawings below)?
OPTION A: GLOBAL VOLUME CALCULATION

OPTION B : follow the shape to calculate volume

Interpretation
The volume is considered to be smallest imaginary box that would contain the toy after having removed minor
appendages which actually is option A above.
Minor appendages would be the wooden elements on the sides of toy 1.
REQ 134-13 (BSI, United Kingdom)
2.4 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 shall 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)
2.5 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 0,08 J.
Is it correct?
Reply
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 EN 71-1 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)
2.6 4.3 Flexible plastic sheeting (no action decision)
Question 1
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)
2.7 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)
2.8 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)
2.9 4.9 Protruding parts (interpretation)
Question
An example is given below where wheel axles have been exposed when the wheel has come off. For
guidance also some other reference information is given.

For toys intended for children over 3 years:
Q1: Shall a wheel on a wheel axle (which, if exposed, can present a puncture hazard) be considered to be a
protective component and thus subjected to 8.4.2.3 (tension test, protective components)?
Q2: If the answer to question 1 is “Yes”, shall the potential puncture hazard of the axle be assessed after
removing the axle from the toy and after placing the axle in a reasonably foreseeable position, or shall it be
assessed when still in the toy and in a reasonably foreseeable position?
Q3: If the answer to question 1 is “No”: Shall any force at all be applied in an effort to remove/detach a wheel
from a wheel axle in order to thereafter check the potential puncture hazard presented by the remaining
exposed axle?
Interpretation
Q1: No, it shall not be considered as a protective component since the presence of the wheel is not to protect
the end of the axle. Protective components are those which are intended to protect from a potential hazardous
protrusion.
Q3: No, according to the standard and for over 3 toys, there is no requirement asking for the application of
such a force.
REQ 129-12 (SIS, Sweden)
2.10 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)
2.11 4.10.3 Hinges and rationale A.13 (interpretation)
Question
Balance bikes made of wood have in several designs introduced a hazard of having fingers crushed in the
squash/squeeze points along the hinge line assembling the “front fork” and “bike frame” at the front end.
These squash/squeeze points as shown below between the two hinged parts are not common on other
traditional ride-on toys and toy bicycles with traditional head tubes and fittings making this hinge
encapsulated.
The Toy Safety Directive states in Annex II Particular Safety Requirements, Point 3 the following:
“Toys shall be designed and manufactured in such a way as not to present any risk or only the minimum risk
inherent to their use which could be caused by the movement of their parts.”
Shall the below hinged part conform to the requirement in EN 71-1 4.10.3, despite the remarks made in the
informative rationale A.13 of 4.10.3?

Interpretation
The purpose of the requirement in 4.10.3 is to address possible crushing hazard related to varying clearances
along a hinge line as stated in the first sentence of the rationale A.13. Therefore, hinged part of the toy as
described above shall comply with this requirement.
REQ 132-12 (DS, Denmark)
2.12 4.11 Mouth-actuated toys and other toys intended to be put in the mouth (interpretation)
Question
Which toys shall be considered as intended to be put in the mouth according to EN 71-1, 4.11?
It is clear that mouth-actuated toys, whistles and peashooters are intended to be put in the mouth but what
about other toys like toy cups, toy spoons, toy forks, toy toothbrushes and toy lipsticks as in the following
images?
And what about toys intended to be placed in the doll’s mouth but that, for imitation, also the child may put in
his mouth (like toy feeding bottle, toy soother, etc.)?
Interpretation
Toys which are miniatures of real products (e.g. cutlery, feeding bottles, soothers, toothbrush) and intended
for use with dolls etc. are not considered to be intended to be put in the mouth and are not covered by 4.11
requirements.
Toys which are copies of real products and which might be used by children for their real purpose during play
are covered by 4.11 requirements if that leads to them being put in the mouth.
Toys which are copies of real products and which are just intended to be put to the lips (e.g. lipsticks, cups)
should not be regarded as toys intended to be put in the mouth and are not covered by 4.11 requirements.
REQ 106-12 (UNI, Italy)
2.13 4.14.2 Masks and helmets (no action decision)
Question
1) 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 1 300 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)
2.14 4.15.1.2 Warnings and instructions for use (no action decision)
Question
4.15.1.2 indicates:
“Electrically-driven ride-on toys and/or their packaging, and their instructions for use, shall carry a warning
regarding protective equipment (see 7.10.3). This warning is not required on electrically-driven ride-on toys
that are equipped with a seat, and are either covered by the requirement in 4.15.1.4 or have a maximum
design speed of less than 8,2 km/h when tested according to 8.29 (determination of maximum design speed
of electrically-driven ride-on toys).”
7.10.3 applies when the electrically-driven ride-on toys are equipped with a seat but are not covered either by
the requirement in 4.15.1.4 or have a maximum design speed of less than 8,2 km/h when tested according to
8.29 (determination of maximum design speed of electrically-driven ride-on toys).
Where a toy is not required by the requirement of this clause to bear the warning referenced in 7.10.3, do you
remove the reference to protective equipment or the warning as a whole?
Reply
Standard is clear. When the labelling requirement related to protective equipment from 7.10.3 does not apply,
the required labelling is:
“Warning. Not to be used in traffic”.
REQ 124-12 (BSI, United Kingdom)
2.15 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)
2.16 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)
2.17  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)
2.18  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
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