Toy Cosmetics Test — EN 71-13 / 1223/2009 / 2009/48/EC

What Is Toy Cosmetics?

Toy cosmetics sets are a special product that can be subject to dual legislation. The cosmetic products in the set (lipstick, nail polish, eyeshadow) fall under cosmetics legislation and require their own safety assessment, while the toy components of the set are assessed under the Toy Safety Directive. EN 71-13 additionally defines requirements for olfactory games, cosmetics sets and gustative games.

Purpose of Toy Cosmetics

The purpose is to show together that the products applied to the child's skin meet the safety requirements of cosmetics legislation, and that the set's toy components comply with toy requirements. The most common non-conformity in these products is that the cosmetics side has not been assessed at all.

Which Products Is Toy Cosmetics Applied To?

Children's make-up sets
Toy nail polish and lip gloss sets
Scent and perfume-making games
Soap and bath bomb making sets
Face paint and carnival make-up

In Which Sectors Is Toy Cosmetics Used?

ToyRetailConsumer ProductsCosmeticsChemistry

Standards Related to Toy Cosmetics

TS EN 71-13 (olfactory games, cosmetics sets and gustative games)
TS EN 71-1 (mechanical and physical properties)
TS EN 71-3 (migration of certain elements)
TS EN ISO 22716 (cosmetics good manufacturing practice)
TS EN ISO 11930 (preservative efficacy — challenge test)
EN 71-1Mechanical and physical properties in toys test
EN 71-2oyuncaklarda yanabilirlik test
EN 71-3migration of certain elements in toys test

Toy Cosmetics Conditions

Scope distinction: The component applied to skin is subject to cosmetics legislation, the play component to toy legislation
Age group: EN 71-13 defines minimum age requirements for these products
Cosmetic assessment: A Product Information File, safety assessment and CPNP notification are required

Equipment for Toy Cosmetics

GC-MS and LC-MS/MS
ICP-MS
pH meter and viscometer
Microbiology laboratory
Toy mechanical test rigs

Sample Requirements for Toy Cosmetics

The complete set, with packaging and instructions for use
Each cosmetic component is a separate specimen
Formulation and INCI list must be provided
The declared age group must be provided

Duration of Toy Cosmetics

Testing the toy components spans several days. On the cosmetics side, microbiological and stability studies determine and markedly extend the duration.

Toy Cosmetics Procedure

1The set's components are separated by scope.
2EN 71-1 and EN 71-3 tests are applied to the toy components.
3The set requirements and age requirements under EN 71-13 are assessed.
4The formulation and INCI of the cosmetic components are examined.
5Microbiological quality, preservative efficacy and stability studies are carried out.
6Screening for banned and restricted substances is carried out.

Toy Cosmetics Acceptance Criteria

The toy components must separately meet the requirements of 2009/48/EC and EN 71, and the cosmetic components those of (EC) 1223/2009. On the cosmetics side, there must be no banned substance, restricted substances must stay within the Annex III limits, and a qualified safety assessment must have been carried out for the product.

Evaluation of Results

Both pieces of legislation must be applied together; compliance under one does not cover the other. In addition, appointing a responsible person and CPNP notification for cosmetic products are mandatory steps independent of testing.

Toy Cosmetics Report

Set contents and component scope distinction
EN 71 tests applied to the toy components
Analysis and microbiology results for the cosmetic components
Banned/restricted substance screening
Age group and warning assessment

Accreditation

EUROLAB holds internationally recognised accreditation obtained from accreditation bodies party to the IAF and ILAC multilateral recognition arrangements, under ISO/IEC 17025 for laboratory testing, ISO/IEC 17020 for inspection and surveillance, and ISO/IEC 17021-1 and ISO/IEC 17065 for system and product certification. This chain ensures the reports and certificates issued are accepted worldwide.

Whether this test can be offered within accredited scope depends on your product and the standard applied; since accreditation is method-based, the scope is confirmed in writing at the quotation stage.

Scope and authorisations

Related Regulations

2009/48/EC Toy Safety Directive
(EC) 1223/2009 Cosmetic Products Regulation
(EC) 1907/2006 REACH

Oyuncak Testleri — What Does This Testing Field Cover?

The section below describes the field that the Toy Cosmetics test belongs to; the conditions and acceptance criteria of this particular test are given in the sections above. The scope specific to your product is confirmed in writing at the quotation stage.

Toy testing shows that a product is safe in children's use. What sets this family apart is that risk is defined according to the USER: the same product may be hazardous for a child under 36 months and safe for an older child. Age marking is therefore not a marketing preference but a technical decision that determines which requirements apply, and it is justified in the technical file.

At the centre of the field is the risk of CHOKING. Children under 36 months put objects in their mouths; a part that detaches or is small to begin with can block the airway. Assessment with the small parts cylinder is the fundamental criterion for this group, and the tests examine whether the part detaches after use and misuse.

The logic of the tests is not that the toy must not break but that BREAKING must not produce a hazardous outcome. A child drops, pulls, bites and stands on a toy. Drop, tension, compression, torque, impact and tipping tests are therefore applied, and the resulting new state is then assessed: is the detached part a small part, did the broken surface leave a sharp edge, has the internal mechanism become accessible?

On the chemical axis, MIGRATION is what counts. What is measured in a toy is not how much of an element the material contains but how much of it dissolves and transfers under conditions simulating the mouth. Materials are divided into three categories (dry brittle powder, liquid or sticky, scrapable) and different limits apply to each; the amount of material a child could ingest varies by category.

Flammability is the third axis and is critical particularly for costumes, tents and plush toys: how quickly flame spreads across the surface is measured.

Electrical and battery-powered toys bring additional bodies of work: EN 62115 for electrical safety, the relevant battery standards and Battery Regulation obligations for the battery. For toys containing button cells, making the battery compartment impossible for a child to open has become a separate requirement — a swallowed button cell is a cause of serious injury.

Sound level is an item that is often overlooked. For toys used close to the ear (toy telephones, rattles, cap-firing toys) the sound pressure is limited; the risk of hearing damage is assessed.

Market regimes differ and do not substitute for one another: the Toy Safety Directive and CE marking in Europe, and in the United States the CPSIA with mandatory ASTM F963 and a third-party laboratory certificate (CPC). The United States also looks at total lead content while Europe looks at migration; the two approaches can produce different results.

Method groups in this field

Mechanical and physical
Small parts assessment, sharp edges and points, entrapment, cord and drawstring safety, dynamic strength, drop and tipping (EN 71-1).
Flammability
Rate of flame spread and ignition behaviour (EN 71-2); decisive for costumes and plush toys.
Element migration
Migration of specified elements in the three material categories (EN 71-3).
Organic chemicals
Phthalates, flame retardants, azo dyes, preservatives and fragrances (EN 71-9 and REACH restrictions).
Electrical toys
Electrical safety under EN 62115; heating, insulation, battery compartment and charging safety.
Sound and other
Sound pressure measurements; the requirements of EN 71-4 and EN 71-5 for chemistry sets and chemical toys.

Commonly confused in this field

Toy safety cannot be demonstrated with a single standard; the mechanical, flammability and chemical parts are assessed together.
Age marking determines which requirements apply; it must be justified in the technical file and not left to marketing preference.
An ASTM F963 report is not accepted in a CE file; the requirements and test arrangements of the two regimes differ.
Migration and total content are different things; the CPSIA looks at total lead while EN 71-3 looks at migration.
If the material category is chosen incorrectly the limit is applied incorrectly too; the category decision is made before sample preparation.
For toys containing button cells, battery compartment safety is a separate requirement; passing electrical safety is not sufficient.

Which decisions these results support

CE marking and the technical file
Determining age marking and warning texts
The CPC certificate and mandatory third-party testing for the US market
Supplier and lot-based acceptance control
Determining the scope of retesting after a design change

Related Tests

Frequently Asked Questions About Toy Cosmetics

If I have a toy certificate, is a cosmetics assessment still needed?

Yes. The component applied to the skin falls under the definition of a cosmetic product and is subject to its own legislation: a responsible person, Product Information File, safety assessment and CPNP notification are separately mandatory.

Are there additional restrictions for children's cosmetics?

Yes. The safety assessment addresses children under three years separately, and some substances cannot be used for this age group. EN 71-13 also defines minimum age requirements for such sets.