UK Statutory Instrument 2011 United Kingdom

Toys (Safety) Regulations 2011

What this means for your business

46 obligations
12 penalties
2 guides
Enforced by
OPSS
Applies to
United Kingdom
On this page
46 compliance obligations, 2 practical guides
Read full text on legislation.gov.uk

What you must do

46 compliance obligations under this legislation.

Appointments 1

Appoint a UK authorised representative for toy compliance

If you make toys and want to appoint a UK‑based person to act on your behalf (for example, because you are based overseas), you must do so with a written mandate. The mandate must let the representative keep the required technical files, answer enforcement requests and act on any risk‑elimination steps you are asked to take. Even though the representative does the work, your business remains ultimately responsible for those duties.

Manufacturer/Importer s.25 OPSS When you decide to appoint an authorised representative (e.g., you are a …

Risk assessment 4

Carry out safety hazard and exposure assessment for each toy

If you make toys, you must check for all possible hazards – chemical, physical, mechanical, electrical, fire, hygiene and radioactivity – and evaluate how people could be exposed to them. This assessment has to be done before the toy is placed on the market, ensuring the product is safe for children to use.

Manufacturer/Importer s.12 OPSS when producing a toy for sale

Carry out toy conformity assessments you are approved for

If your company is an approved body that certifies toys, you must perform the conformity assessment tasks you are approved to do and use the detailed steps set out in Schedule 6. This keeps the toy market safe and lets consumers trust the products you certify.

Any Person Operational matters in relation to approved bodies OPSS Once you are approved or notified to assess toy modules under regulation …

Carry out toy Type examinations as approved body

If your company is an approved body that conducts Type examinations for toys, you must carry out those examinations exactly as set out in Module B. You also need to check the manufacturer's safety assessment and perform the exam in a proportionate way, taking account of your size, sector and the toy’s complexity.

Trader/Business s.43 OPSS When you conduct a Type examination on a toy

Follow the correct conformity assessment procedure for your toys

You must show that each toy meets the essential safety requirements. If you use all the relevant designated standards, you can use the internal production control procedure (Module A). If the standards don’t exist, are only partly applied, are restricted, or you decide third‑party verification is needed, you must arrange a type examination and conformity‑to‑type test (Module C).

Manufacturer/Importer s.13 OPSS

Inspections 2

Apply to an approved body for a toy type examination

If you make a toy that needs a safety check, you must apply to a designated body that can test it. The body will only do the test if your application is in English, the fee is paid and all documents are supplied, and you expect the test to be done within 6 months of receiving your paperwork.

Manufacturer/Importer s.42 OPSS When you produce a toy that requires type examination for market sale

Obtain a Type examination certificate for your toys

If you make or sell children’s toys, you must get a Type examination certificate from an approved body. This certificate shows the toy meets all safety rules and must be kept with the toy and displayed on its packaging. It protects you from selling unsafe toys and helps meet legal requirements.

Manufacturer/Importer s.44 OPSS

Management duties 23

Affix UK(NI) indication on toys sold in Northern Ireland

If you place a toy on the Northern Ireland market and the CE mark is based on a UK‑notified body assessment, you must also put a UK(NI) label on the toy. The label has to be clearly visible, legible and permanent, attached wherever the CE mark is. If you are an importer, you must make sure the manufacturer has done this.

Manufacturer/Importer UK(NI) indication OPSS When the CE marking is issued by a UK notified body and …

Comply with manufacturer safety duties when importing or re‑branding toys

Unlimited fine

If you import a toy and sell it under your own brand, or you change a toy that’s already on the market, you must meet the same safety obligations that apply to the toy’s original manufacturer. In practice this means you have to follow the essential safety requirements, keep the technical documentation and ensure the toy is correctly marked, just as a manufacturer would.

Trader/Business s.32 OPSS You place a toy on the market under your own name/trademark, or …

Comply with manufacturer safety duties when you market or modify toys

If you sell a toy under your own brand or change a toy in a way that could affect its safety, you must take on the responsibilities normally owed by the toy’s manufacturer. That means you must follow all the safety testing, documentation and labelling rules that apply to manufacturers, and you do not need to follow the separate distributor rules.

Trader/Business s.37 OPSS When you place a toy on the market under your own name …

Correct non‑compliant toys and report risks to the authority

If you discover that a toy you have placed on the market may not meet the safety rules, you must act immediately – either fix the problem or withdraw/recall the toy. If the toy could be dangerous, you also have to tell the enforcement authority what the risk is, what went wrong and what you have done, and cooperate with any further requests they make.

Manufacturer/Importer s.24 OPSS When you have reason to believe a toy you have placed on …

Ensure imported toys meet safety requirements before sale

Unlimited fine

If you import toys, you must only put them on the market if they meet all essential safety requirements and have the correct UK marking, technical file, manufacturer information and safety instructions. You also need to confirm the manufacturer has carried out the required conformity assessment and you must add your own importer details and follow the proper storage and transport rules.

Trader/Business s.26 OPSS When you place an imported toy on the market

Ensure safe storage and transport of imported toys

Unlimited fine

If you import toys, you must make sure that the way you store or move them does not damage them or affect their safety. This means keeping them protected from things like moisture, extreme temperatures or rough handling while the toys are in your control, up to the point they are placed on the market.

Trader/Business s.28 OPSS while the toy is under the importer’s responsibility (during storage or transport)

Ensure toys have UK marking, declaration of conformity and technical documentation

Unlimited fine

When you place a toy on the UK market you must affix the correct UK marking, produce a compliant declaration of conformity and keep complete technical documentation. If an enforcement authority serves you a compliance notice, you must either fix the problem or provide evidence it does not exist within the period set in the notice, otherwise the toy can be withdrawn or recalled.

Manufacturer/Importer s.52 OPSS When supplying a toy in the UK or when a compliance notice …

Ensure toys meet all safety requirements before market

You must design and manufacture toys so they are mechanically strong, stable and free from hazards such as choking, strangulation, fire, harmful chemicals, excessive noise, overheating or dangerous projectiles. All of the listed safety standards (mechanical, flammability, chemical, acoustic, etc.) must be met and you must be able to show proof of compliance before the toy is sold.

Manufacturer/Importer Schedule 2 OPSS

Ensure toys meet essential safety requirements

Unlimited fine

If you manufacture toys, you must make sure they are designed and built so they meet all the essential safety requirements for the whole period you expect them to be used normally. This means checking safety at each stage of design and production and keeping evidence that the toy stays safe throughout its normal life.

Manufacturer/Importer s.11 OPSS

Ensure toys meet safety requirements before making them available

Unlimited fine

If you distribute toys, you must only put them on the market when you are sure they comply with all safety rules. You cannot sell a toy you think might be unsafe, and you must check that the manufacturer has applied the UK marking, provided the required label and instructions, that any importer has supplied the correct information, and that the toys are stored and transported safely.

Trader/Business s.33 OPSS

Ensure toys meet safety requirements before selling

Unlimited fine

If you manufacture toys you must not put them on the market unless they meet the essential safety requirements and you have completed every step set out in the regulations – design to safety standards, a safety assessment, the correct conformity‑assessment procedure, a UK declaration of conformity and UKCA marking, full technical documentation, clear product identification, user instructions and safety warnings, and the series‑production compliance procedures. In practice this means carrying out a complete compliance programme before any toy is sold.

Manufacturer/Importer s.10 OPSS

Implement compliance procedures for series‑produced toys

If you manufacture toys by series production, you must have written procedures that ensure every toy meets the essential safety requirements throughout its normal, foreseeable use. You also need to review and update those procedures whenever the toy’s design or its referenced safety standards change.

Manufacturer/Importer s.21 OPSS When you manufacture toys by means of series production

Join and stay informed about sectoral groups of notified bodies

If your company is a UK notified body that carries out conformity assessments for toys, you must either take part in each relevant sectoral group set up by the European Commission, or at least make sure the staff who do the assessments are kept up‑to‑date on what those groups are doing. You can do this yourself or by appointing a representative.

Employer s.48 OPSS

Keep stored and transported toys safe and compliant

Unlimited fine

If you distribute toys, you must make sure that any toy you store or move does not lose its safety compliance because of the way it is kept. This means controlling things like temperature, humidity, packaging and handling while the toy is in your possession, so it remains safe for normal use.

Trader/Business s.34 OPSS while a toy is under your responsibility for storage or transport

Manage non‑compliant or risky toys

If you import a toy and realise it may not meet the safety rules or could be dangerous, you must act straight away. You need to tell the manufacturer and the enforcement authority about the risk, fix the problem or withdraw/recall the toy, give the authority full details of the issue and any actions taken, and cooperate with any further requests they make.

Trader/Business s.30 OPSS When you have reason to believe a toy you intend to place …

Manage subcontracting and retain responsibility for conformity assessment tasks

If your UK notified body wants to subcontract any part of a conformity assessment for a toy, you must first be sure the subcontractor meets the notified‑body requirements and obtain the manufacturer’s consent. You then have to tell the Secretary of State that the subcontractor is acceptable, stay liable for the work, and be ready to supply evidence if asked.

Employer s.49 OPSS When you intend to subcontract a specific task or activity of a …

Mark toys (or packaging) with manufacturer and product details

If you make toys, you must put a clear identifier on each toy showing its type, batch/serial/model number, your business name or trademark, and a single contact address. Where the toy is too small or its shape prevents marking, the same information must appear on the packaging or in a document that comes with the toy.

Manufacturer/Importer s.19 OPSS

Monitor marketed toys for safety

Unlimited fine

As a toy manufacturer you must keep an eye on the safety of any toy you sell. This means testing samples, investigating any complaints, recording problems, recalls or breaches, and letting your distributors know about any actions you take. It’s an ongoing duty to protect consumers and stay compliant.

Manufacturer/Importer s.23 OPSS

Monitor safety of imported toys

If you import toys into the UK you must actively monitor their safety. This means you need to carry out sample testing, investigate any complaints you receive, keep a register of complaints, non‑compliant toys and recalls, and inform any distributors about the actions you have taken.

Trader/Business s.29 OPSS

Notify, correct and cooperate on non‑compliant or risky toys

If you sell toys and become aware that a product may not meet the essential safety requirements or could be hazardous, you must inform the importer (or manufacturer if there is no importer) and the enforcement authority, take the necessary corrective action or recall the toy, and give the authority details of the risk, the non‑compliance and any remedial steps. You must also cooperate with any further requests the authority makes. All of this must be done immediately.

Trader/Business s.35 OPSS When you, as a distributor, have reason to believe a toy you …

Only affix the UK toy safety marking correctly

You may only put the UK safety mark on a toy if you are the toy’s manufacturer or an authorised representative who has been approved by the manufacturer, and only after the toy has passed the required conformity assessment. You must not use any other mark that pretends to show the toy meets safety requirements, nor add any sign that could confuse people about the meaning of the UK mark. Any other labels you add must not obscure or degrade the UK mark.

Manufacturer/Importer s.39 OPSS When affixing a UK marking to a toy for sale in the …

Provide clear English warnings on toys and packaging

If you place a toy on the UK market, you must make sure any hazards are clearly explained to users or supervisors. All warnings must start with the word “Warning” (or “Warnings”), be written in English and displayed prominently on the toy itself, on any label or packaging, and in the instruction booklet. The wording must be easy to read and understand.

Manufacturer/Importer s.5 OPSS Whenever a toy is placed on the market (i.e., any toy you …

Provide correct instructions, warnings and safety info with toys

If you manufacture toys, you must supply each toy with suitable user instructions and safety warnings, including any age or hazard warnings required by the regulations. These warnings must be shown clearly in English on the toy itself, a label, the packaging or the instruction leaflet, and must be visible to the consumer before purchase (including online listings).

Manufacturer/Importer s.20 OPSS

Notifications 1

Notify parties when you withdraw or recall a toy

If you decide to stop a toy being sold or to recall it, you must immediately tell the other party why you are doing so, what remedy they can use and any deadline for that remedy. The notice must contain the exact legal or safety grounds for the action and be sent without delay.

Trader/Business s.55 OPSS When you prohibit/restrict, withdraw, or recall a toy from the market

Other requirements 2

Affix UK marking to every toy and its packaging

If you make toys, you must put the UK conformity mark on each product where consumers can see it – on the toy itself, a label, the packaging, or an accompanying document if allowed. The mark has to be clear, permanent and legible, and for small toys you can use a separate label or leaflet. The marking shows your toy meets the safety rules.

Manufacturer/Importer s.18 OPSS

Mark importer name and contact address on imported toys

If you import toys into the UK, you must put your business name (or trade name/trademark) and a contact address directly on the toy. If the toy is too small, you would have to open the packaging, or it was imported from the EEA/Switzerland within the last seven years, you can instead place that information on the packaging or in a document that comes with the toy.

Trader/Business s.27 OPSS when you place imported toys on the UK market

Offences and prohibitions 1

Contravene Regulation 15A (UK/NI indication)

Unlimited fine

If you place a toy on the market without complying with Regulation 15A – the rule that sets out how a toy must be marked to show it is intended for the UK or Northern Ireland – you commit a criminal offence. On a summary conviction in the Magistrates' Court you can be ordered to pay an unlimited fine.

Any Person Offence in respect of UK(NI) indication OPSS

Record keeping 4

Create declaration of conformity and apply UK marking

Once you have tested a toy and shown it meets the required safety standards, you must produce a written declaration confirming this and attach the UKCA (UK) marking to the toy or its packaging. This lets customers and regulators know the product is safe and complies with the law before it is sold.

Manufacturer/Importer s.15 OPSS After the toy passes the required conformity assessment procedures and is ready …

Keep toy conformity records for 10 years

Unlimited fine

If you import toys into the UK, you must keep a copy of the EC declaration of conformity and be able to show the technical file to the authorities if they ask. These records must be retained for ten years after the toy is first placed on the market.

Trader/Business s.31 OPSS When you import a toy and place it on the UK market

Prepare and keep up‑to‑date Declaration of Conformity for each toy

If you manufacture toys, you must create a Declaration of Conformity that says the toy meets all essential safety requirements and includes the information set out in Schedule 3 and any module‑specific details. You must keep this declaration current and recognise that, by issuing it, you are taking responsibility for the toy’s compliance.

Manufacturer/Importer s.16 OPSS for every toy you place on the market

Prepare and retain technical documentation for toys

If you manufacture a toy, you must produce a technical file in English that shows how the toy meets all safety requirements and includes the items listed in Schedule 4. You must keep this file (and the declaration of conformity) for 10 years after the toy is first placed on the market, and any correspondence about type‑examination must also be in English. If an enforcement authority asks, you must arrange approved‑body testing at your own cost.

Manufacturer/Importer s.17 OPSS

Registration and licensing 1

Apply to become a UK notified body and maintain compliance

If your company wants to carry out conformity assessment for toys, you must apply to the Secretary of State to be designated as a UK notified body. You must prove you meet the required criteria, accept the written designation (which sets out what tests you can do and for how long), and respond to any information requests from the Secretary of State.

Trader/Business s.40 OPSS when your business wishes to act as a UK notified body for …

Reporting and filing 7

Notify the Secretary of State of certification decisions and provide information on request

If your business is an approved notified body, you must tell the Secretary of State whenever you refuse to issue, suspend, restrict or withdraw a toy type‑examination certificate, or when anything changes that affects your approved status. You also have to supply any information about your conformity‑assessment activities when the Secretary asks for it, within the time‑frame they set.

Any Person s.51 OPSS When you refuse, restrict, suspend or withdraw a toy type‑examination certificate, when …

Provide identification of other toy economic operators when requested

If your business supplies toys – whether you are the manufacturer, importer, distributor or retailer – you must tell the enforcement authority the names of any other companies you bought the toy from and any you have sold the toy to, if they ask you. You have to give this information within the time‑frame they set, and the authority can only make the request up to 10 years after the toy was placed on the market (for manufacturers) or supplied to you (for other operators).

Manufacturer/Importer s.38 OPSS When an enforcement authority makes a request for identification of other economic …

Provide information and act on enforcement authority orders for toy certification

If you run an approved body that issues Type examination certificates for toys, you must give the enforcement authority any information they ask for (including test reports and technical files) within the time you set. You also have to withdraw a certificate or review it if the authority tells you to do so.

Trader/Business s.47 OPSS When an enforcement authority requests information, orders withdrawal, or requires review of …

Provide information to authorities about toys on the market

Unlimited fine

If you place toys on the UK market, you must give the competent authority any information they ask for about the toy’s safety – such as test reports, technical files or conformity statements. Failing to do so can lead to criminal penalties, so keep your records ready and respond promptly.

Manufacturer/Importer s.36 OPSS When a competent authority requests information about a toy you have placed …

Share conformity assessment results with other approved bodies

If your business is an approved body that carries out toy safety tests, you must pass on any negative assessment findings to other approved bodies doing the same work. If another approved body asks for your positive findings, you must provide those too. This ensures all testing bodies have the same safety information.

Trader/Business s.46 OPSS When your approved body conducts a conformity assessment of a toy and …

Submit type‑examination application for each toy

If you place a toy on the UK market, you must apply to an approved body for a type examination. Your application has to follow Module B, include a description of the toy, the address where it is or will be made, and you must pay the fee the body charges.

Manufacturer/Importer s.14 OPSS When you need a type examination for a toy you intend to …

Submit type‑examination certificate for review

If you manufacture a toy, you must send its safety (type‑examination) certificate to an approved body for review whenever you change the way the toy is made, the materials or components used, every five years after it was issued or last reviewed, or whenever you think a review is needed. This ensures the certificate stays up‑to‑date with the product.

Manufacturer/Importer s.22 OPSS a) any change to the manufacturing process, raw material or component; b) …

Penalties for non-compliance

12 penalties under this legislation. 12 carry an unlimited fine.

Unlimited fine

Comply with manufacturer safety duties when importing or re‑branding toys

Unlimited fine

s.32 Penalises: Comply with manufacturer safety duties when importing or …
Unlimited fine

Ensure imported toys meet safety requirements before sale

Unlimited fine

s.26 Penalises: Ensure imported toys meet safety requirements before sale
Unlimited fine

Ensure safe storage and transport of imported toys

Unlimited fine

s.28 Penalises: Ensure safe storage and transport of imported toys
Unlimited fine

Ensure toys have UK marking, declaration of conformity and technical documentation

Unlimited fine

s.52 Penalises: Ensure toys have UK marking, declaration of conformity …
Unlimited fine

Ensure toys meet essential safety requirements

Unlimited fine

Summary only s.11 Penalises: Ensure toys meet essential safety requirements
Unlimited fine

Ensure toys meet safety requirements before making them available

Unlimited fine

s.33 Penalises: Ensure toys meet safety requirements before making them …
Unlimited fine

Ensure toys meet safety requirements before selling

Unlimited fine

s.10 Penalises: Ensure toys meet safety requirements before selling
Unlimited fine

Keep stored and transported toys safe and compliant

Unlimited fine

s.34 Penalises: Keep stored and transported toys safe and compliant
Unlimited fine

Monitor marketed toys for safety

Unlimited fine

s.23 Penalises: Monitor marketed toys for safety
Unlimited fine

Contravene Regulation 15A (UK/NI indication)

Unlimited fine

Summary only Offence in respect of UK(NI) indication Penalises: Contravene Regulation 15A (UK/NI indication)
Unlimited fine

Keep toy conformity records for 10 years

Unlimited fine

s.31 Penalises: Keep toy conformity records for 10 years
Unlimited fine

Provide information to authorities about toys on the market

Unlimited fine

Summary only s.36 Penalises: Provide information to authorities about toys on the …

Practical guidance

Our guides explain how to comply with the requirements above.

Sections and provisions

79 classified provisions from this legislation.

Duties 51

  • Schedule 2 PARTICULAR SAFETY REQUIREMENTS (Annex II to the Directive) Toys and their parts
  • s.5 Essential safety requirements
  • s.10 Prohibitions on placing toys on the market A manufacturer
  • s.11 Design and manufacture of toys in accordance with essential safety requirements The manufacturer
  • s.12 Safety assessment
  • s.13 Applicable conformity assessment procedures
  • s.14 Application for Type examination
  • s.15 Declaration of conformity and UK marking
  • s.16 information required
  • s.17 Technical documentation and correspondence relating to Type examination correspondence relating
  • s.18 Toys to bear UK marking
  • s.19 Information identifying toy and manufacturer The manufacturer
  • s.20 Instructions for use, safety information and warnings information provided as
  • s.21 Compliance procedures for series production
  • s.22 Submission of Type examination certificate for review
  • s.23 Monitoring of toys complaint made in relation
  • s.24 Non-compliant toys and toys presenting a risk The manufacturer
  • s.25 Manufacturer's authorised representative
  • s.26 Prohibitions on placing toys on the market An importer
  • s.27 Information identifying importer An importer
  • ... and 31 more duties

Offences and penalties 1

  • Offence in respect of UK(NI) indication Offence in respect of UK(NI) indication

Powers 8

  • s.41 UK national accreditation body
  • s.50 Charging of fees by approved body
  • Approval of conformity assessment bodies Approval of conformity assessment bodies
  • Designated standard Designated standard
  • Powers to amend Appendix A to Schedule 2 Powers to amend Appendix A to Schedule 2
  • Power to amend Appendix C to Schedule 2 Power to amend Appendix C to Schedule 2
  • Power to amend Schedules 1, 2 and 5 Power to amend Schedules 1, 2 and 5
  • Restriction, suspension or withdrawal of approval Restriction, suspension or withdrawal of approval

Definitions 5

  • s.57 Amendment to the General Product Safety Regulations 2005
  • Approved bodies Approved bodies
  • Further use of UK marking Further use of UK marking
  • Qualifying Northern Ireland Goods Qualifying Northern Ireland Goods
  • Subsidiaries and contractors Subsidiaries and contractors

Exemptions 5

  • Schedule 1 PRODUCTS THAT ARE NOT TOYS (Annex I to the Directive)
  • s.4 Toys to which these Regulations apply
  • s.8 Exception for trade fairs or exhibitions
  • Obligations which are met by complying with obliga Obligations which are met by complying with obligations in the Directive
  • Transitional provision in relation to EU Exit Transitional provision in relation to EU Exit