It is tempting to feature household appliances with eye-catching designs, including designs that attract children. Confusion often arises over the concept of ‘play value’ or ‘use in play’.
Virtually everything has play value for a child, but this does not make every product fall into the definition of a toy. The Toys Safety Directive applies only to products designed or intended for use in play by children under 14 years. Adding child-appealing designs to appliances comes very close to intended for children, the key question is: is it foreseeable that the child will play with the appliance as it would play with a toy. Even if a child appealing product is not a toy, it still needs to be safe for children in accordance with the provisions of the General Product Safety Regulation (EU) 2023/988.
Examples of Child Appealing Appliances
Child appealing appliances are fully functional household appliances designed with features that appeal to children. The child appealing risk shall be assessed under the General Product Safety Regulation (EU) 2023/988 and the EN IEC 60335 series of standards for electrical appliances. Specific warnings are required to prevent children from mistaking them for toys.
Functional toys perform and are used in the same way as an appliance intended for use by adults, and which often are a scale model of such appliance or installation. As the name implies, these are toys. Non-functional replicas of real appliances intended for play are also classified as toys because they provide a play value rather than real functionality.
Identifying Child Appealing Features
Article 6 of the General Product Safety Regulation (EU) 2023/988 emphasises key factors to consider when assessing the safety of child appealing appliances that are not toys. Extra precautions are inevitable if the design, packaging, or characteristics make the appliance attractive to children.
To guide economic operators identifying child appealing features, the Coordinated Activities on the Safety of Products (CASP) has published the “Child-appealing (including Food Imitation) Products” Handbook in 2021.
Elements to consider in the identification of child appealing appliances:
Elements | Explanation |
Colour | Products designed for children under 14 years old are typically featuring bright colours, which are more appealing and attractive to children. |
Size | Children’s articles are usually smaller and easier to handle, whereas larger and heavier products are generally less appealing for children to pick up. |
Pictures | Including an image or a logo can attract attention to the product but would not necessarily make the item a toy or encourage children to play with it. However, pictures designed for younger children, such as featuring cartoon characters, may increase the risk level, whereas others may be more suitable for an older age group. |
Marketing | The marketing of a product plays a key role in identifying its target audience and is reflected in websites, packaging, and advertisements. Packaging showing children using or playing with the product increases its attractiveness to children. |
Interaction | Interactive features (lights, sounds, movements) can encourage children to touch, move or adjust a product. For example, an appliance with a start button that plays music when pressed. |
Play value | Play is defined as engaging in an entertaining activity, typically for recreation rather than a practical purpose. Play value is usually long term (longer periods), unlike activities that quickly lose interest. While toys are specifically designed for play, other products may have features that encourage interaction and may give rise to repetition actions or play-like behaviour. |
Stricter Requirements for Child Appealing Appliances
Standard EN IEC 60335-1 states general safety requirement for household electrical appliances.
While child appealing appliances are not inherently prohibited, they must comply with stricter safety requirements under EN IEC 60335-1.
Clause 22.44 was updated in 2023 and provides the following criteria for child appealing appliances.
The appliance is child appealing if one of the following two criteria is present:
- It is decorated with faces, cartoon like characters, or similar images;
- It is shaped representing animals, characters, persons or scale models.
An appliance is also child appealing if two or three of the following criteria are present:
- It has non-functional lights (excluding illumination lights or status indicators);
- It makes non-functional sounds (e.g. music);
- It has non-functional movement (e.g. decorative spinning parts).
If the appliance is child appealing and:
- It weighs less than 4 kg; and
- It is mounted or normally intended for use at a height below 85 cm,
Then, the following conditions shall be met (summarised):
- Limited surface temperatures to prevent burns;
- No hazardous moving parts;
- No accessible live electrical parts;
- Accessible liquids shall not exceed 38 °C;
- No small, loose parts that could cause choking.
This article is originally published by ProductIP:
Caspar ter Horst – Managing Director, ProductIP
Caspar has 25+ years of experience in product compliance. In 2008, he co-founded ProductIP together with Maarten van der Dussen. Caspar and his team are dedicated to support companies within the supply chain to efficiently demonstrate to customers, authorities, and users that their products meet applicable legislation and buying requirements. As a result, helping companies reduce costs, streamline operations, manage suppliers, and at the same time put compliant, safer, more sustainable products to the market.
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