CE Marking – Fabric Toys

Note before reading... If you wish to use my post, please ensure you check with me first and link back to this blog. This blog post is intended as a collection of resources for your information and Emma's Fabric Studio takes no legal responsibility for the content, please use the links provided for this instead.

EDIT UPDATE 2 18.06.2012: Robert Kaufman have provided a statement from their Compliance Manager that I have incorporated into the post below.

EDIT UPDATE 1 03.05.2012: I am still awaiting further information regarding Robert Kaufman and Riley Blake Designs. I would encourage you to email the fabric companies yourself so that they are fully aware of how many people are awaiting this vital information for CE marking purposes.

CE Marking – Manufacturing Toys

If you manufacture toys and offer them for sale, you are required to ensure your product has the CE mark (CE stands for Conformité Européenne!).  CE marks are required for many products, but because Emma’s Fabric Studio is a fabric retailer, I’m only going to concentrate on the fabric side of things for soft toys.  One of the Directives relates to the ‘Safety of Toys’ so this comes into play mainly for my army of dolly makers out there!  If you look at the Directive relating to ‘Recreational Craft’ thinking this relates to you… think again… this relates to boats!

CE marking states that the product is assessed before being placed on the market and meets EU safety, health and environmental protection requirements.  It is your responsibility as a manufacturer to ensure everything is in place to obtain a CE marking.  Remember, this is for people who manufacture and sell toys, the majority of my customers don't, so this blog post possibly won't apply to you so don't panic!  In America the similar standard is called CPSIA (Consumer Products Safety Improvement Act) and you can obtain information from fabric manufacturers that show whether or not individual products are CPSIA compliant, to enable you to go forward with obtaining your CE marking.

A major part of gaining your CE marking is 'European standard' EN71 which relates, not solely, to fabric and the technical data for the components.  You'll hear this term often as you go through the process.  EN71 is the European standard that pertains to the safety of toys which is the Directive relating to you. CPSIA and EN71 may be different standards and test results need to be confirmed either by checking EN71 guidelines or with someone official. CPSIA compliant fabrics are likely to pass EN71 standards but this is not guaranteed. A company stating they are CPSIA compliant is not good enough in Europe, the fabrics need to comply with EN71.

With regard to CPSIA compliant fabrics, my suppliers are based in America and therefore I refer to CPSIA for this reason. My main fabric suppliers are listed below, please contact them directly if you need further technical data/detail or explanation:

• Michael Miller, whose CPSIA details are on their website here.
• Moda, see the very bottom of this page labelled 'CPSIA'.
• Riley Blake Designs, awaiting information.
• Robert Kaufman, The Kona cotton solid shade card states that Kona cotton solid fabrics are tested for harmful substances according to Oeko-Tex Standard 100.  This standard in turn is CPSIA compliant and the details can be found on their own official website here.  The Robert Kaufman Compliance Manager has provided the following statement (in grey only).  Note that if you require the certificate(s) mentioned below, you need to specify which collections you are interested in (suggest you email info@robertkaufman.com):

We are compliant with all standards and laws set forth in the Consumer Product Safety Compliance Act (CPSIA) and the Fabrics Flammability Act (FFA).

The CPSIA only provides requirements for Lead and Phthalates, it currently does not cover other heavy metals such as cadmium and mercury. It has deemed that textiles are exempt from Lead and Phthalate testing as neither are used in the production, dyeing or printing of textiles. We do test for lead and Phthalate on our Slicker quality because of the PU coating used. To the best of my knowledge cadmium and mercury in not used in the production, dyeing or printing of textiles either. The FFA also allow for exemptions in testing. The below fabrics are exempt from flammability testing because they exhibit low burn rates:

“(1) Plain surface fabrics, regardless of fiber content, weighing 2.6 ounces per square yard or more; and
 (2) All fabrics, both plain surface and raised-fiber surface, regardless of weight, made entirely from any of the following fibers or entirely from combination of the following fibers: acrylic, modacrylic, nylon, olefin, polyester, wool.”

Our fleece, Kona Cottons, sheeting prints and poplin solids and prints all qualify for one the above exemption. We do test annually the goods that are not exempt. I can provide a General Certificate of Conformity GCC stating our compliance. I must list a fabric description and collection on the certificate.

Finally, to obtain your CE marking you need to carry out testing or self certify.  Be sure to check the CE website (the link is at the end of this paragraph) to ensure your paperwork is in order, your testing is done as appropriate and your pathway to achieving CE marking is documented.  I have been asked a number of times if the fabrics I sell have the CE mark.  Please remember that it's the product that you manufacture (if you're in the business of soft toy manufacture) that actually requires the CE mark. I am not an expert on this subject but I feel an informed customer and also an informed fabric retailer are certainly good things to be! One place you can get advice from is your local Trading Standards team, who sit within your county council structure.  Look also at the official EU site for CE marking here and the Business Link guidance for CE marking here.