CROSS-STANDARD public interest · Toys & children's products

China-to-EU Toy Compliance Gap Matrix

AI-compiled from official public sources — cross-checked by multiple AI models, not human-verified. Informational only; see disclaimer. Public-interest, source-linked comparison of common China toy certification (CCC / GB 6675 series) against EU CE marking requirements under the Toy Safety Directive 2009/48/EC, EN 71 series, EN IEC 62115, and REACH.

Dataset 2026-06-11 Last verified 2026-06-12 6 rows

GAP MATRIX

Compliance Gap Matrix

Gap matrix
Compliance item Common China baseline European Union (CE / Toy Safety Directive) Gap / action Source + verification date
Chemical Safety — Migration of Elements (EN 71-3) & REACH GB 6675.3-2014 (Safety of toys — Part 3: Migration of certain elements) is China's equivalent to EN 71-3, aligned with ISO 8124-3. It sets migration limits for 8 elements: antimony, arsenic, barium, cadmium, chromium, lead, mercury, selenium — the original 1994 EN 71-3 element set. The 2019 EU revision expanded to 19 elements and introduced the three-material-category migration testing methodology; GB 6675.3-2014 uses only the original 8-element/single-category framework. China also has GB/T 22788 and related standards for specific chemical hazards in children's products, but these do not map 1:1 to REACH Annex XVII restrictions. There is no direct Chinese equivalent of the REACH SVHC notification system.GB 6675.3-2014 — National toy safety standard — Part 3: Migration of certain elements (CNCA/SAMR, 8 elements, ISO 8124-3 aligned)
GB/T 22788-2008 — Toys: determination of total content of certain elements (supplementary screening method)		 Toys placed on the EU market must meet the chemical essential safety requirements of Toy Safety Directive 2009/48/EC and the directly applicable restrictions in REACH Regulation (EC) No 1907/2006. EN 71-3:2019+A1:2021 (Safety of toys — Part 3: Migration of certain elements) is a voluntary harmonised standard that can give presumption of conformity for covered migration hazards under the Toy Safety Directive; alternative technical solutions are allowed if conformity with the Directive is demonstrated. EN 71-3 sets migration limits for 19 elements across three material categories: dry/brittle/powder material, liquid/sticky material, and scraped-off material. REACH Annex XVII separately restricts hazardous substances in toy materials, including phthalates, azo dyes, and polycyclic aromatic hydrocarbons. EN 71-9:2005+A1:2007 covers specific organic chemicals in toys as voluntary technical guidance where used. EU SVHC candidate list substances above 0.1% w/w in articles trigger REACH communication duties and may trigger SCIP notification.Directive 2009/48/EC — Toy Safety Directive, Annex II Part II (Chemical safety essential requirements)
EN 71-3:2019+A1:2021 — Safety of toys — Part 3: Migration of certain elements
EN 71-9:2005+A1:2007 — Safety of toys — Part 9: Organic chemical compounds
Regulation (EC) No 1907/2006 — REACH (Registration, Evaluation, Authorisation and Restriction of Chemicals), Annex XVII
Regulation (EC) No 1272/2008 — CLP (Classification, Labelling and Packaging)		 Significant gaps exist on both the voluntary EN 71-3 presumption-of-conformity route and directly binding REACH restrictions: (1) EN 71-3 gap: the EU 2019 revision covers 19 elements vs. 8 in GB 6675.3. The three-material-category method means manufacturers relying on EN 71-3 normally need migration evidence for dry/brittle, liquid/sticky, and scraped materials rather than only the older single-category method. (2) REACH gap: phthalates (DEHP, DBP, BBP restricted to <0.1% in accessible parts), azo dyes releasing carcinogenic amines (>30 mg/kg), PAHs, and heavy-metal paints are REACH-restricted and need supplier material declarations and/or third-party chemical analysis. (3) EN 71-9 organic compounds — no direct GB equivalent; specific compound testing may be appropriate where that voluntary guidance is used. Full chemical compliance typically needs a dedicated EU REACH/RoHS compliance review of all material inputs.[INFORMATIONAL] The chemical safety gap between China and EU is the largest in toy compliance. EN 71-3:2019+A1:2021 is a voluntary harmonised route that expanded to 19 elements with a three-category methodology not present in GB 6675.3-2014. REACH phthalate, azo dye, and PAH restrictions are directly binding and require material evidence — GB 6675 does not address these. Chinese manufacturers typically need a full chemical compliance programme including EU-specific migration evidence, REACH substance screening, and supplier material declarations before EU market entry. EUR-Lex / Official Journal of the European Union2026-06-12 · unverified
CE Conformity Assessment, EU Declaration of Conformity & EU Authorised Representative China requires CCC (China Compulsory Certification) for most toys sold in mainland China, administered by CNCA (Certification and Accreditation Administration). CCC requires a designated Chinese-approved certification body (e.g., CQC) to conduct factory inspection and product testing — it is not a self-declaration system. The CCC mark must be affixed to the product. CCC certificates are issued to the Chinese manufacturer and are non-transferable to third parties. There is no equivalent to the EU Authorised Representative concept — importers to China hold their own distribution obligations but are not co-responsible in the same regulatory framework as an EU AR.China Compulsory Certification (CCC) — CNCA-C13-01 toy certification scheme (CNCA administered)
Certification and Accreditation Administration (CNCA) — CCC scheme operator		 Before placing toys on the EU market, the manufacturer (or EU importer/authorised representative acting on their behalf) must complete the conformity assessment procedure under Toy Safety Directive 2009/48/EC Article 18. Two routes exist: (1) Internal production control (Module A) — available only if all applicable harmonised standards are fully applied; the manufacturer compiles a Technical File and issues an EU Declaration of Conformity (EU DoC) without a Notified Body. (2) EC type-examination (Module B+C) — required when no harmonised standards exist, harmonised standards are not fully applied, or when a harmonised standard covers a hazard inadequately. A Notified Body must examine a product sample and issue an EC type-examination certificate. The CE mark must be affixed visibly, legibly, and indelibly on the toy or its packaging. An EU Authorised Representative (a natural or legal person established in the EU) is required for manufacturers not established in the EU — the AR is jointly responsible for regulatory compliance and is the EU enforcement contact point.Directive 2009/48/EC — Toy Safety Directive, Articles 10–20 (Conformity assessment, DoC, CE marking, Authorised Representative obligations)
Decision No 768/2008/EC — Common framework for marketing of products (Module A and Module B+C definitions)		 Chinese manufacturers must: (1) Appoint an EU Authorised Representative (a physical EU-resident entity) — this is a legal obligation, not optional. The AR's name and address must appear on the product or packaging. (2) Compile a Technical File (TF) in one EU official language: product description, design drawings, hazard analysis, test reports (EN 71-1/-2/-3, EN IEC 62115 if applicable), and production quality measures — retained for 10 years after last production. (3) Issue an EU Declaration of Conformity (EU DoC) referencing the Directive(s), harmonised standards applied, identification of the product, and the AR/manufacturer. (4) If Module A is unavailable (e.g., novel toy type, standard partially applied), engage a Notified Body for EC type-examination. CCC documentation, certificates, and Chinese-language technical files do NOT satisfy any of these EU requirements.[INFORMATIONAL] Non-EU toy manufacturers must appoint an EU Authorised Representative, compile a Technical File, and issue an EU Declaration of Conformity before CE marking and EU market placement. This is a complete administrative rebuild from CCC — Chinese certification documentation does not satisfy any element of the EU conformity assessment obligation. Budget for EU AR appointment fees (commercial AR services exist), translation costs, and test report re-issuance to EN standards. EUR-Lex / Official Journal of the European Union2026-06-12 · unverified
Electric Toy Safety (EN IEC 62115) GB 19865-2005 (Electric toys — Safety) is China's mandatory standard for electric toys, technically aligned with IEC 62115:2004 (the 2005 edition). As of 2024, China has not yet adopted the 2020 revision of IEC 62115 as a national standard; GB 19865 remains the mandatory reference under CCC. The standard covers similar areas (voltage limits, insulation, battery compartments, motor temperatures) but is based on a 20-year-older edition of the IEC base standard. Testing and CCC certification to GB 19865 is NOT accepted for EU CE marking under the Toy Safety Directive or LVD.GB 19865-2005 — Electric toys — Safety (CNCA/SAMR, CCC mandatory; aligned with IEC 62115:2004, not the 2020 revision) Toys powered by electricity (mains-operated or battery-operated) must meet the essential safety requirements of Toy Safety Directive 2009/48/EC and, where applicable for mains-operated products, Low Voltage Directive 2014/35/EU. EN IEC 62115:2020+A11:2020 (Electric toys — Safety) is a voluntary harmonised standard that can give presumption of conformity for the hazards it covers; alternative technical solutions are allowed if the manufacturer demonstrates conformity with the Directives. The standard covers: maximum supply voltage guidance; protection against electric shock (insulation, creepage and clearance distances); motor and transformer temperature limits; battery compartment requirements (polarity, short-circuit protection); charging circuit requirements; protection against overloading; requirements for remote-controlled toys. Note: the Toy Safety Directive generally restricts toys from using mains voltage directly accessible to children — mains toys typically operate via a safety transformer.Directive 2009/48/EC — Toy Safety Directive, Annex II Part IV (Electrical properties essential safety requirements)
Directive 2014/35/EU — Low Voltage Directive (applies to mains-operated toys above safety extra-low voltage thresholds)
EN IEC 62115:2020+A11:2020 — Electric toys — Safety (harmonised under both TSD and LVD)		 For electric toys exported to the EU, relying on EN IEC 62115:2020+A11:2020 is a common voluntary route to presumption of conformity, but it is not the only route. Compared with the 2004 base used by GB 19865, key review points include: (1) updated voltage/current limits and temperature test methods in the 2020 edition; (2) mains-operated toys must also satisfy LVD 2014/35/EU where that Directive applies, with conformity assessment chosen according to the product risk and legislation; (3) remote-controlled and IoT-connected toys may additionally need EMC (Directive 2014/30/EU) and Radio Equipment Directive (2014/53/EU) compliance if they incorporate radio modules — these are NOT covered by EN IEC 62115. Chinese manufacturers often hold CCC under GB 19865, but EU technical documentation normally needs fresh evidence mapped to EU legislation and any harmonised standards used. For radio-enabled toys, separate RED compliance is needed.[INFORMATIONAL] Electric toys need CE marking under the Toy Safety Directive and, for applicable mains-operated toys, the LVD. EN IEC 62115:2020+A11:2020 is a voluntary harmonised standard that can support presumption of conformity; Chinese GB 19865 (based on a 2004 IEC edition) does not by itself demonstrate EU conformity. Radio-enabled and IoT toys need additional EMC and RED compliance not covered by EN 62115. Manufacturers should compile EU-specific evidence and retest or justify alternatives where needed. EUR-Lex / Official Journal of the European Union2026-06-12 · unverified
Warnings, Age-Grading & Labelling Requirements GB 6675.1-2014 (General requirements) includes labelling requirements for Chinese-market toys: mandatory age-grading warnings (similar '0–3 years' concept), manufacturer name and address, product name, material description, and recommended age. Warnings must be in Chinese (Mandarin). The CCC mark must appear on the product. CN labelling rules require Chinese-language-only warnings; multi-language labelling is not required and is uncommon on products designed for the domestic market. There is no Chinese equivalent of the EU's specific Annex V warning category system (e.g., the specific aquatic/functional/chemical toy categories).GB 6675.1-2014 — National toy safety standard — Part 1: General requirements, Section 7 (Labelling) (CNCA/SAMR)
CNCA-C13-01 — CCC toy certification scheme labelling requirements		 Toy Safety Directive 2009/48/EC Article 11 and Annex V mandate specific warnings and labelling: (1) Age warnings: toys not suitable for children under 36 months must bear the '0–3' warning (crossed-out child with age 0–3 symbol) plus a text warning in all official languages of the destination EU member state(s). (2) Functional toys (e.g., toy irons, toy kitchen appliances) must bear warnings specifying that adult supervision is required. (3) Chemical toys (chemistry sets, etc.) must bear 'Not for children under 12 years' and 'Adult supervision recommended'. (4) Toys for children over 36 months that have inherent small parts must bear appropriate warnings. (5) Aquatic toys must bear warnings about use only with adult supervision in water. (6) CE marking placement: on the toy or its packaging, in a visible, legible, and indelible manner; minimum height 5 mm for CE mark. (7) Manufacturer name and address (or EU Authorised Representative name and address) must appear on the toy or packaging. (8) Batch/model/type number for product identification. All warnings must appear in the official language(s) of the EU member state where the toy is sold.Directive 2009/48/EC — Toy Safety Directive, Article 11 (Warnings) and Annex V (Specific warnings and conditions of use)
Directive 2009/48/EC — Article 4 (Manufacturer obligations including labelling), Article 7 (Importer obligations)
Regulation (EU) 1169/2011 — Food information (does not apply to toys, noted for comparison only)		 EU labelling requires a complete rework for Chinese-manufactured toys: (1) All warnings must be in the official language(s) of EACH destination EU member state — e.g., German, French, Polish, Spanish, etc. This is a translation and printing cost, not a testing cost. (2) The '0–3' warning symbol must be the specific EU graphical symbol (not the Chinese equivalent symbol). (3) EU Authorised Representative name and address must appear on product/packaging (does not exist on CCC-compliant packaging). (4) Batch/lot/type number for traceability must be present. (5) Annex V category-specific warnings (aquatic, functional, projectile, etc.) must be assessed and applied. Chinese domestic packaging is typically in Chinese only and lacks all of these EU elements. Relabelling or full packaging redesign is typically required.[INFORMATIONAL] EU warnings and labelling requirements are extensive and mandatory — they require multi-language text, specific graphical symbols, and EU Authorised Representative details not present on Chinese-market packaging. This is a logistical and printing obligation, not a testing one, but non-compliant labelling constitutes grounds for EU market surveillance removal. Full packaging redesign targeting each destination EU market's official language(s) is typically required. EUR-Lex / Official Journal of the European Union2026-06-12 · unverified
Mechanical & Physical Safety (EN 71-1) China's mandatory toy safety standard GB 6675.1-2014 (General requirements) and GB 6675.2-2014 (Mechanical and physical properties) are technically aligned with ISO 8124-1 and closely mirror EN 71-1. They are enforced under the CCC (China Compulsory Certification) scheme administered by CNCA/SAMR for most toy categories. The small-parts test cylinder dimensions, sharp-edge/point requirements, and magnet requirements in GB 6675.2 are substantially similar to EN 71-1, but specific limit values and age-grading breakpoints may differ. CCC certification to GB 6675 is NOT recognised as equivalent to EN 71-1 testing for the EU CE pathway.GB 6675.1-2014 — National toy safety standard — Part 1: General requirements (CNCA/SAMR, CCC mandatory)
GB 6675.2-2014 — National toy safety standard — Part 2: Mechanical and physical properties (CNCA/SAMR)		 Toys placed on the EU market must meet the mechanical and physical essential safety requirements of Toy Safety Directive 2009/48/EC. EN 71-1:2014+A1:2018 is a voluntary harmonised standard that can give presumption of conformity for the hazards it covers; alternative technical solutions are allowed if the manufacturer demonstrates conformity with the Directive. The standard addresses issues such as sharp points or edges accessible to children, small parts for children under 36 months, excessive noise levels, strangulation hazards from strings/cords, projectile kinetic energy, and accessible magnets with high magnetic flux index. For toys intended for children under 36 months, detachable small parts are a critical safety concern under the Directive.Directive 2009/48/EC — Toy Safety Directive (EU)
EN 71-1:2014+A1:2018 — Safety of toys — Part 1: Mechanical and physical properties		 Chinese manufacturers commonly obtain EN 71-1 testing from an accredited laboratory to support presumption of conformity, but the legal obligation is conformity with the Toy Safety Directive, not mandatory use of EN 71-1. CCC/GB 6675.2 test reports do not by themselves satisfy the EU conformity assessment evidence package. Key divergences to verify: (1) magnet flux index limits — EU tightened these significantly; (2) noise limits — verify dB(A) thresholds align; (3) age-grading boundary definitions. A Notified Body is not automatically needed when a harmonised-standard route fully covers the hazards, but may be needed if standards are absent, partly applied, or inadequate. Documentation includes EU Declaration of Conformity, CE marking, and age-grade warnings in all EU official languages of destination markets.[INFORMATIONAL] Mechanical and physical safety conformity is mandatory under the Toy Safety Directive, and EN 71-1 is a voluntary harmonised route to presumption of conformity. Chinese GB 6675.2 / CCC certification does not by itself satisfy the EU pathway. EU-specific evidence, often including EN 71-1 testing by an accredited laboratory, should be prepared. Pay particular attention to magnet flux index limits and age-specific small-parts requirements, which may require product redesign. EUR-Lex / Official Journal of the European Union2026-06-12 · unverified
Flammability Safety (EN 71-2) GB 6675.4-2014 (Safety of toys — Part 4: Flammability) is China's equivalent, technically aligned with ISO 8124-2 and substantially similar to EN 71-2. It is mandatory under CCC for applicable toy categories. Material classification, small-flame test methodology, and prohibited materials (celluloid) are substantially similar. As with other GB 6675 parts, CCC test reports to GB 6675.4 are not accepted as substitutes for EN 71-2 testing under the EU conformity assessment pathway.GB 6675.4-2014 — National toy safety standard — Part 4: Flammability (CNCA/SAMR, CCC mandatory for applicable categories) Toy flammability is governed by the essential safety requirements in Toy Safety Directive 2009/48/EC. EN 71-2:2011+A1:2014 is a voluntary harmonised standard that can give presumption of conformity for covered flammability hazards; alternative technical solutions are allowed if conformity with the Directive is demonstrated. The standard addresses categories such as toys not intended to enter the mouth, disguise costumes, and soft-filled toys for children under 3, and includes material classification and burn-rate thresholds. Certain easily ignitable materials are restricted or prohibited under the Directive's essential requirements.Directive 2009/48/EC — Toy Safety Directive (EU), Annex II Part III (Flammability essential safety requirements)
EN 71-2:2011+A1:2014 — Safety of toys — Part 2: Flammability		 Where a manufacturer relies on EN 71-2, EU-specific test evidence from an accredited or otherwise competent lab is commonly used to support presumption of conformity. The technical gap between EN 71-2 and GB 6675.4 is relatively small (both derive from ISO 8124-2), but CCC reports should be mapped carefully to EU legal requirements and any harmonised standards cited. Disguise costumes are a higher-risk category — verify burn-rate thresholds match. Documentation should reference the Toy Safety Directive and any voluntary harmonised standards applied. A Notified Body is not automatically needed for flammability when the harmonised-standard route fully covers the hazard, but may be needed if that route is unavailable or incomplete.[INFORMATIONAL] Flammability safety conformity is mandatory under the Toy Safety Directive, and EN 71-2 is a voluntary harmonised route to presumption of conformity. Chinese GB 6675.4 / CCC test reports do not by themselves complete the EU pathway. The technical requirements are largely ISO 8124-2-derived and closely aligned, but EU-specific evidence, often including EN 71-2 testing by an accredited lab, should be prepared. Disguise costumes require extra scrutiny on burn-rate thresholds. EUR-Lex / Official Journal of the European Union2026-06-12 · unverified

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