NB_TOYS_2022_013_Revision Guidance Doc 11 - Comments NB Toys

Coordination of the Notified Bodies
NB-TOYS
under the Safety of Toys Directive
NB TOYS 2022-013
21 March 2022
Revision Guidance document No11 on the classification of toys intended for children under 3 years of
age
Comments NB Toys
# Page
1 5 Suggest to add CPSC age determination guide next to CEN ISO/TR 8124-8 as it is a
comprehensive document elaborated by experts children’s development.
2 6 Last Alinea: better to explain that apart from <3, >3 there are several other
requirements related to a different age that are essential to consider for age
determination. This document although focuses only on <3, >3
3 9 For each example it is not relevant to reference ISO 8124-8, because the aim of ISO
8124-8 is very different. ISO 8124-8 focuses only on the first starting age
4 9
5 12
6 14
Some foam puzzle examples are also to be used as a play mat,
those should be suitable for under 3
12. Maybe better provide an example of Tangram, where the complexity of
play is key and 3+ classification is clearly justified.
7 19
I should be suitable for under 3 yr , the play pattern is not to
complex: children can stack and match the picture by trial and error
5. It should be clarified that for dolls with partial had limbs templates A and B
as mentioned in clause 5.8 may not apply.

8 19
9 20
5. The explanation includes dolls
“even totally made of PVC or rubber”. This is confusing and should be deleted as
those hard dolls are not easy to cuddle.
the following example is a
separately sold doll accessories which is to be added into the doll series children are
already playing with, so 3+ is acceptable as additional accessories are encouraging
higher level of role playing; but with the explanation given in the draft guideline, does it
imply when a doll set come with cuddling doll and diaper only, the diaper is definitely
suitable for 3+ when the doll is suitable for under 3?
10 36 Squishies will not comply with under 3 tension testing. It does not make sense to
classify them.
11 38
12 46
Not a good example If a simple craft kit includes unpainted
squishies, it is still possbile to confuse that is suitable for children under 3 years
because of the soft texture. Parents may let children to use finger paint to play with
this kit.
13 46
13. It is not clear how the soap bubbles are created, looks like there is a
rod to be soaked in the bubble solution so bubbles can be blown. If so it is not easy to
handle even if the duck is easy operated. Classification should be 3+.
14. Same as above. The handling of the soap bubbles is leading.
Classification should be 3+.

14 51
15 50/51
11 children under 3 can not operate the small wind up mechanism
16 50
could be age graded for 3+
moving and barking pets are more complex play and
17 55
14 and 15 the function of both toys is quite close, besides
the look and feel is similar. They should be age graded similar.
18 57
and detail is limited. Both sets could be suitable for 3+
1 and 2 the differeence in size
For the following example of building
blocks it is unclear in how the connection is made, if the connection is to be made by
inserting something (e.g. rod) into the holes of the perforated plate then the connection
is not simple. Just seeing from the photo of the product, the objects it can created are
quite complex. Not a good picture.
19 62 The shown game sets may be age gragded for <3, but are also suitable for 3+
20 70 There are no toys to be entered given for children over 3. Maybe include one?

21 76
Balance bikes can be suitable for children starting from 2
year. The suitable age depends on the minimum and maximum seat heigh. The
presence of a hand brake / foot brake is not the key factor for age evaluation.
Children will simply not use a break if they can not handle one.
22 81
9 design and material is not attractive of children under 3. #+ should
be acceptable for such balls
23 81 There are no inflatable balls given as example. Maybe include one?
24 83
25 84
How to assess price
for an toy over or under 3. It is a criterium suitable for eg adult colecctors, but
caretakes do not spend more or less money for 2 or 3 year olds.
26 91
1 and 4 playing horse is a more complex play pattern. 3+
classification should be acceptable
Nightlights are not toys, they should the
assessed as child attactive products under GPSD.

27 104
105
Both sets have a realistic design and
could be age graded for 3+. Similar to the following example that is age graded 3+