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HMG Knowledge Base
Toy Safety Regulations
Whilst these regulations strictly only apply to toys and articles intended to be sucked or chewed by children, they are often referred to in the context of other health protection issues. Importantly, the Regulations apply to the toy or article itself as placed on the market.
Coatings as supplied by HMG Paints Limited, are intermediates used in the manufacture of the toy or article, and as such are subject to further processing during which the physical state changes from the form supplied to a film on the relevant substrate. As we are not responsible for the handling of the paint or ink outside our own operations, HMG are not in a position to make statements on the conformance of the coating or ink on the toy or article in question, and the compliance of the product as supplied cannot guarantee the status of the applied film.
HMG can supply a wide range of coating systems in different shades and sheens, which from previous history we would expect to comply with the Toy Safety Regulations EN71-3 (i.e. in compliance with the metal limits that are contained in the standard). The most widely used systems are Industrial Cellulose. Pre Cat Lacquer, Acid Cat Lacquer, C71 Speedline and LMP Water Based Acrylic. All systems would have to be independently analysed and certificated that they comply with EN71-3.
The independent analysis would have to be performed on every batch of material requiring conformance to EN71-3. The cost for the independent certification is £70.00 per batch regardless of batch size. The process generally takes around 7 working days at the end of which a certificate can be issued. It is worth stating that products classed as 'lead-free' or 'no added lead' may not conform to the Toy Regulations. Both phrases indicate that no lead or heavy metal containing products have been added to the coating system during manufacture.
However, lead or heavy metal impurities could be present in the raw materials used, hence the reason for independent certification. For the toy or article to be in compliance with the regulations then the item itself has to be analysed. The Toys (Safety) Regulations 1995, SI 1995:204, download from www.hmso.gov.uk BS EN 71-3:1995, safety of Toys - Specification for the migration of certain elements, purchase from BSI.
