CE Marking for Wooden Toys

CE marking is the importer’s legal responsibility, not the factory’s — but the factory is the only place the evidence can come from. This page sets out what that evidence is.

Who is responsible for CE marking

The obligation sits with the person who places the toy on the EU market. In practice that means an importer or an EU-established brand, and the CE mark is their declaration that the toy meets the Directive.

The manufacturer designs and produces to the Directive and provides the test evidence, the risk assessment and the technical documentation.
The importer verifies that the file is complete and that the marking and labelling are correct before the goods go on sale, and keeps a copy of the DoC.
The distributor checks that the CE mark and the accompanying documents are present, and must not supply a toy they know to be non-compliant.
An authorised representative can be appointed for administrative duties, but the responsibility itself cannot be transferred away.

What the CE file for a wooden toy contains

Legal basis	Toy Safety Directive 2009/48/EC. A wooden toy is a toy under the Directive, so it must comply before it can be placed on the EU market.
Declaration of Conformity (DoC)	A signed document naming the product, the manufacturer, the directives applied and the standards used. Issued by the manufacturer or the importer, depending on who places the toy on the market.
Technical documentation	Drawings, materials, risk assessment, test reports, the DoC and the labelling. Kept for ten years after the last unit is placed on the market.
Test reports	Reports from a third-party laboratory against the harmonised EN71 standards, issued per item and per material combination.
Labelling	CE mark, name and address of the manufacturer and importer, batch identification, age warning and, where relevant, the small-parts warning.
Traceability	A batch or serial reference that links the unit on the shelf back to the production record and the test report.

How conformity is actually demonstrated

For a wooden toy the usual route is not a type-examination. It is self-declaration against harmonised standards: test to EN71, apply the Directive, and sign the DoC. Using the harmonised standards is what creates the presumption of conformity.

EN71-1, EN71-2 and EN71-3 cover mechanical and physical properties, flammability, and migration of certain elements. These are the three parts that matter to most wooden toys.
Other parts apply depending on the product: organic chemical compounds, and the parts covering particular toy types.
Risk assessment is a separate written exercise. A test report is not a risk assessment, and the file is incomplete without one.
Chemical requirements in the Directive are assessed as well, including the restrictions on substances that apply regardless of the migration limits.

What our factory supplies

We are a Chinese manufacturer, so we cannot sign an EU DoC on our own account — but we supply everything the importer needs to sign one.

Third-party EN71 test reports for the item and the material combination you order.
A manufacturer’s Declaration of Conformity naming the standards applied, which our EU customers use as the basis for their own.
Technical documentation: drawings, the bill of materials, the paint and material specifications, and the production and QC records.
FSC chain of custody where FSC stock is specified (certificate ESTS-COC-240650), and BSCI social audit documentation.

The wider market picture, including the UK, US, Canada and Australia, is set out in Wooden Toy Import Requirements and in wooden toy safety standards.

The mistakes that come up most often

Most CE problems we see are administrative, and they surface when a customs officer, a marketplace or a trading standards officer asks a question.

A DoC that names no standards, or names EN71 without a part number.
A test report for a different item or a different material combination than the one being shipped.
The CE mark applied at the wrong proportion, or on an insert rather than on the toy or its packaging.
No risk assessment in the technical file, because it was assumed the test report covered it.
The EU importer’s name missing from the toy or its packaging.

We keep test reports and declarations on file per item, so a document request during an inspection can normally be answered the same day.

Frequently asked questions

Can you issue a CE certificate?

There is no such thing as a CE certificate from a factory. CE marking is a declaration by the party placing the toy on the EU market. We supply the test reports, the materials documentation and a manufacturer’s declaration that the importer uses to sign their own Declaration of Conformity.

Do wooden toys need CE marking?

If it is a toy within the meaning of the Toy Safety Directive, yes. Decorative wooden items and furniture-style pieces that are not designed for play fall outside the toy definition, and that distinction should be settled before the artwork is printed.

Which EN71 parts apply to a wooden toy?

EN71-1 for mechanical and physical properties, EN71-2 for flammability and EN71-3 for migration of certain elements are the three that apply to most wooden toys. Other parts apply depending on the material and the product type.

How long must the technical file be kept?

Ten years after the last unit of that product is placed on the EU market. The file has to be available to market surveillance authorities on request.

Is a test report the same as a risk assessment?

No. A test report is laboratory evidence against a standard; a risk assessment is a written analysis of the hazards the product presents. The technical file needs both.

What labelling must be on the toy or the packaging?

The CE mark, the name and address of the manufacturer and of the EU importer, a batch reference, the age grading and any warning that applies, such as the small-parts warning.

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Tell us the items, quantities and the market you sell in. We will come back with a quotation, the documentation we can supply, and the next step.

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