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Pacifier cord or toy?

On September 26, 2019, the European Commission (EC) published guide number 19 for weaning cords. The EC and the Expert Group on Toy Safety have produced several guides to help manufacturers, importers, distributors and regulators interpret and apply the Toy Safety Directive 2009/48/EC. These documents describe when articles are considered toys and thus covered by the Toy Safety Directive. They are not legally binding, but represent the opinion of the majority of the expert group.

Manual number 19 provides a tool, through information and examples, to assess when a pacifier cord should or should not be considered a toy.

Functional versus play value

Pacifier cords are defined in standard EN 12586 as: "article by which a pacifier can be attached to a child's garment". This is to prevent the pacifier from getting lost. A functional pacifier cord includes:

  • a simple cord;
  • simple colored beads or shapes;
  • Simple 2D figures such as a moon, star or heart;
  • components with attractive graphics, but with low or no play value.

The manual also covers pacifier holders that are not intended to be attached to a child's garment. Examples include cloths made of plush or other textile materials in simple colors with simple 2D elements such as labels and embroidery.

These pacifier cords and holders are considered children's articles and fall under the scope of the European General Product Safety Directive 2001/95/EC and must also comply with standard EN 12586.

However, there are also pacifier cords where the pacifier is attached to a stuffed toy, cloth or an object with one or more play elements. In this case, the product invites play. A pacifier cord with play value includes:

  • interactive elements, such as movable beads and rings;
  • varied shaped elements, such as cars and flowers;
  • a rattle;
  • 3D figures, such as animals with different components;
  • plush or wooden toys;
  • an additional function, such as a teething ring.

These products are pacifier cords and toys at the same time and fall under the scope of the European General Product Safety Directive 2001/95/EC and the Toy Safety Directive 2009/48/EC.

Need support?

Are you unsure whether a product should be classified as a children's article or a toy? Or do you want to know which legal requirements apply to your product? Précon Quality Services can help you! We have a team with extensive experience in training, advising and supporting in the field of product compliance for children's articles and toys. Feel free to contact us at +31 (0)30 - 65 66 010 or info@precongroup.com.

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