Guide · 1385 words
What EN71, ASTM F963 and CPSIA actually require from a wooden toy supplier
Buyers usually open with one question: "is it CE marked?" It is a fair question and the wrong first one. CE is a mark the manufacturer applies after building a technical file, and the file is only as strong as the test reports behind it. What you want to see is the report, the model it covers and the laboratory that issued it.
This page sets out what each of the three regimes covers, what a report should contain, and where buyers most often get caught.
Three different things
| Aspect | EN71 | ASTM F963 | CPSIA |
|---|---|---|---|
| Applies in | EU and EEA | United States | United States |
| Legal status | Harmonised standard under the Toy Safety Directive | Consensus standard, mandatory in practice through CPSIA | Federal law |
| Covers | Mechanical, flammability, migration of elements | Mechanical, flammability, heavy elements, warnings | Lead, phthalates, testing, certification, tracking |
| Evidence | Test report plus technical file | Test report from a CPSC-accepted lab | Children's Product Certificate and tracking label |
| Enforced by | Market surveillance authorities and customs | CPSC, customs | CPSC, customs |
They overlap, but none replaces another. A toy sold in both markets needs both sets of evidence.
EN71: the parts that matter for wooden toys
EN71-1, mechanical and physical properties. Small parts, sharp edges and points, accessible gaps and holes, drop and impact tests, torque and tension on attached components, packaging film, and the warning requirements. For a wooden toy the small-parts test is the one that decides the age band, and the gap tests catch a block that can trap a finger.
EN71-2, flammability. Solid wood is hard to ignite and rarely the problem. The clause starts to matter when a toy carries fabric, felt, cord or a surface finish that can burn, and when the toy is meant to be worn.
EN71-3, migration of certain elements. This is the one that governs paint and ink. The method simulates what a child's stomach would extract from a material that has been mouthed, and the limits are set by material category. It applies to the coating and to the substrate, so a natural block is not automatically outside the test.
A report should name the model and, for painted toys, the colourways tested. A natural beech cube does not cover the same cube painted red with a different ink supplier.
ASTM F963: the US standard
ASTM F963 covers toys for children under 14 and includes material quality, small objects, sharp edges and points, heavy elements in substrate and coatings, flammability, and warning labelling. The current edition is F963-23, which replaced F963-17. Older reports are still in circulation. That is not automatically a problem, but ask the lab whether the report still holds for your toys.
In the United States, testing for children's products must be done at a CPSC-accepted third-party laboratory, and the result feeds the Children's Product Certificate. A report from a lab not accepted for that test is not evidence for customs.
CPSIA: the law underneath
CPSIA sets the substance limits. Lead is capped at 100 ppm in accessible substrate and 90 ppm in paint and surface coatings. Eight phthalates are capped at 0.1 percent in toys that children can mouth. A children's product is anything designed for children 12 and under, which covers every toy on our floor.
It also sets the paperwork: third-party testing, a CPC per product and shipment, and a permanent tracking label on the product and its packaging showing manufacturer, location, production date and batch. Retailers ask for the tracking label detail before they will list a SKU.
What a test report should contain
Open the report and check these before you file it:
- Laboratory and accreditation. A named lab with an ISO/IEC 17025 accreditation number, and scope that includes the standard.
- Report number and date. Traceable, and recent enough that the standard edition in the report is the current one.
- Applicant and manufacturer. The factory that made the sample, not a trading company three steps away.
- Sample description. Photos, dimensions, materials, colours, and the age grading tested.
- Results per clause. Each clause numbered, with pass or fail rather than a single "compliant" stamp.
- Conclusion and signature. Dated, signed, and on the lab's letterhead.
If any of the six is missing, the report will not survive a retailer's compliance desk, and it will not survive a market surveillance check either. We keep each model's report with its batch record; the quality page explains how.
CE marking and the technical file
CE is a self-declaration, not a certificate issued by a body. For toys the route runs through the Toy Safety Directive: the manufacturer builds a technical file, issues an EU Declaration of Conformity, and affixes the mark. Where a harmonised standard is followed in full, notified body involvement is not normally required.
The technical file is the part buyers forget to ask for. It should hold design drawings, material specifications, test reports, the declaration, warnings and instructions, and production control records, and it is kept for ten years after the last unit is placed on the market.
The importer has its own duties. If you are the EU importer, your name and address go on the product or its packaging, and you are expected to be able to produce the file. That is why we ask for the importer's details before we print the label block.
Great Britain uses UKCA marking, and CE is still accepted for many product groups. Confirm with your customer before you commit to one mark.
Age warnings and small parts
The 36-month line is common to both EN71 and ASTM F963. A toy marked 3+ may contain small parts; a toy marked under 3 may not. The warning is not a suggestion about difficulty. It is a statement about choking risk, and it must state the reason, not only the age.
Warning text has to be in the language of the market where the toy is sold. A carton printed in English for a German retailer is a recall waiting to happen. We set it at the artwork stage: cheap to change on a dieline, expensive on a printed carton.
The age on the box, the age tested on the report and the age in your catalogue should match. When they do not, the mismatch is the first thing a compliance officer finds.
Key takeaways
- CE is a declaration, not a certificate. Ask for the report and the technical file behind it.
- EN71-1 decides the age band through small parts; EN71-3 governs paint and ink migration.
- ASTM F963 must be tested at a CPSC-accepted lab to support a Children's Product Certificate.
- CPSIA sets 100 ppm lead in substrate, 90 ppm in coatings, and 0.1 percent for eight phthalates.
- A report covers a model and its colourways. A new colour is a new test question.
- Warning text must match the destination market's language and the tested age grade.
FAQs
Do you provide test reports for every model?
Yes. Each model we ship has a report tied to it, and we send the report with the quotation when the buyer needs it for their compliance file. Ask for it with your quote request. Reports are issued to the manufacturing entity, not to the buyer.
Is CE marking enough to sell in the EU?
No. You also need the technical file, an EU Declaration of Conformity, importer details on the product or packaging, and warnings in the language of each market. Toy safety is enforced at the border, and the file is what gets checked.
Can we use our own lab or our existing reports?
If the sample in the report matches the product, the materials, the colours and the factory, yes. If any of those differ, the report does not cover the product. Most retailers accept any accredited laboratory within the scope of the standard, but the manufacturer named must be the one that made the goods.
Are wooden toys exempt from phthalate testing?
Bare wood has no plasticiser to test. Anything added to the wood changes that: a moulded part, a printed film, a coated cord. Where those are present, the relevant tests apply.
Need a quotation? Send the product, quantity and destination market — we reply within 12 working hours.