EN 71-3 Explained: What Toy Brands Must Know About Chemical Migration Testing in 2025
- Awen Hollek
- Sep 29
- 5 min read
Why EN 71-3 Is One of the Most Critical Compliance Tests for Toys
When it comes to toy safety, chemical exposure is no joke. Children chew, suck, lick, and handle toys in ways that make material safety absolutely essential. That’s why EN 71-3, the European standard that controls chemical migration of toxic elements, is one of the most crucial (and unforgiving) parts of CE marking for toys.
If you’ve ever said, “It’s just paint,” or “It’s safe because it’s wood,” think again. Toys using wood, metal, fabric, plastics, or coatings are subject to strict scrutiny under EN 71-3—especially with new changes taking effect from October 25, 2025.
These aren’t minor tweaks. The EN 71-3:2019 + A2:2024 version introduces tighter controls, more rigorous test methods, and no room for shortcuts.
In this guide, we break down the updates, show you what they mean for your toy business, and explain how Awen Hollek can help you pass compliance with flying colours.
What EN 71-3 Actually Tests For
EN 71-3 is about chemical migration—the release of potentially toxic substances from toys into the human body through contact or ingestion. The focus is on 19 elements, including:
Heavy Metals & Toxic Elements |
Lead (Pb) |
Cadmium (Cd) |
Chromium III & VI (Cr) |
Arsenic (As) |
Mercury (Hg) |
Antimony (Sb) |
Barium (Ba) |
Selenium (Se) |
Tin & Organic Tin (Sn) |
Nickel (Ni) |
Zinc (Zn), Copper (Cu), Cobalt (Co), etc. |
These can come from:
Pigments in paints or coatings
Dyes in plastics or textiles
Fillers, glitter, and colorants
Metals in components or fasteners
🧠 Think about it this way: If your toy has colour, sparkle, or metal—it’s probably subject to EN 71-3 testing.
Why It’s More Relevant Than Ever in 2025
With rising concern about microplastics, PFAS, and heavy metal exposure, regulators are cracking down on even trace amounts of toxins in consumer goods—especially toys.
In 2024 alone, 20+ toys were flagged on RAPEX (EU’s rapid alert system) due to lead, cadmium, and boron migration. Many were recalled, destroying both inventory and brand credibility.
The 2025 EN 71-3 update tightens limits further, demanding more precise and transparent testing methods—and that’s where most small and mid-sized toy brands struggle.
Source:
What’s New in EN 71-3:2019 + A2:2024 (Effective Oct 2025)
The upcoming version of the standard (which becomes mandatory in the EU after October 25, 2025) brings four major changes that every toy brand must understand:
🔍 1. Composite Testing Limits Removed
Until now, similar materials (e.g. multiple red plastic parts) could be tested as a composite sample. This saved money and time—but also allowed hotspots (areas with higher toxicity) to be hidden.
Now, under A2:2024:
Each material or component must be tested separately, unless they are physically inseparable
This applies even to similar-looking items
🎯 Impact: More samples. More tests. More cost. But also more accurate results.
❌ 2. Dewaxing Step Removed
Previous versions allowed toys with coatings (e.g. wax or varnish) to undergo dewaxing—removing surface treatment to test only the core material.
Now, testing must be performed as-is, without removing any coating, varnish, or surface layer.
🧪 Impact: Many “safe-looking” products may now fail, as the coatings themselves may contain banned substances.
💧 3. CEN/TS 17973:2023 Slime Categorization Introduced
The EN 71-3 standard now includes a reference to a new technical specification (TS) that covers:
“Slime-type” toys
Malleable, gooey, or stretchable materials
DIY slime kits and modeling clays
These are now treated as their own test category, with stricter migration protocols due to skin absorption and ingestion risk.
🎯 Impact: Sensory toys must now be labeled, tested, and certified under specific slime regulations.
🧬 4. New Migration Limits for Key Elements
Updated permissible limits for elements such as:
Lead (lowered across all categories)
Chromium VI (a known carcinogen—now ultra low tolerance)
Cadmium, arsenic, boron—subject to reduced thresholds
🎯 Impact: Old test reports using 2019 standards may no longer be valid—even if they passed at the time.
Sources:
Which Toys Are Affected Most by EN 71-3 Updates?
EN 71-3 applies to all toys, but some categories are especially vulnerable:
Slime & sensory kits
Painted wooden toys
Molded plastic figurines
Fabric toys with printed designs
Plush with glitter/foil/metallic parts
Toys with metal rivets, buttons, zippers
If your toy is in one of these segments, you should be preparing now—not next fall.
How to Prepare: Material, Supplier & Lab Coordination
The trick to passing EN 71-3 isn’t just good luck—it’s good prep.
📝 Material Declarations: Get It in Writing
Request detailed safety data sheets (SDS) or material declarations from your suppliers. Look for:
Heavy metal content
Organic tin compound levels
Compliance certificates (EN 71-3:2019+A2:2024, not older)
Source country and pigment breakdowns
Don’t assume. Ask.
🔬 Choosing the Right Lab Test Methods
Make sure your lab:
Tests each material separately
Doesn’t “combine” samples
Uses ICP-OES, AAS, or IC for detection
Issues reports referencing EN 71-3:2019 + A2:2024
⚠️ A test report using old protocols will be invalid after October 25.
🎨 Product Design Tweaks That Help
Use uncoated or naturally pigmented materials
Avoid shiny paints unless EN 71-3 certified
Minimize glued-on plastic gems or metallic trims
Avoid cadmium-based red/orange/yellow pigments
Avoiding Recalls, Retail Delays, and Customs Issues
Don’t let EN 71-3 be the reason your toy misses Q4 launches or gets pulled by Amazon.
Failing to update your compliance protocols can result in:
Customs blocks
Retailer rejections
Withdrawals from marketplaces
Fines, reputation damage, and lost revenue
How Awen Hollek Helps with EN 71-3 Compliance
At Awen Hollek, our compliance-first development process is designed to reduce surprises at the lab stage.
Here’s what we offer:
🧬 Pre-vetted materials with EN 71-3 test history
🔍 Design guidance to avoid risky paints and coatings
🧪 Lab coordination with certified partners
🧾 Review and prep of CE documentation
🌱 Eco-conscious alternatives that are both safe and marketable
FAQs About EN 71-3:2025 Compliance
Q: If my toy passed EN 71-3 before, do I need to retest it?
A: Yes, if you plan to sell it in the EU after October 25, 2025, it must be retested under the updated A2:2024 version.
Q: Can I still composite test similar materials?
A: Only if they are physically inseparable. Otherwise, each must be tested individually.
Q: Do lab reports need to mention A2:2024?
A: Yes. If the report only lists “EN 71-3:2019” or “A1:2021,” it’s not compliant after the deadline.
Q: Are all coatings now tested?
A: Yes. No more dewaxing or removing top layers—the toy is tested as-is.
Q: What about handmade or natural toys?
A: Even “eco” toys must be tested—especially if they have color, prints, or finishes.
Final Thoughts: Safety Isn’t Optional—But Panic Is
Toy brands often treat EN 71-3 like a last-minute checklist item. But in reality, chemical safety is foundational. It’s how you earn retailer trust, CE certification, and parental approval.
And the new rules? They’re stricter—but they’re also manageable.
Especially when you’ve got Awen Hollek in your corner.
We help you design smarter, source safer, and launch toys that children love—and regulators approve.
📬 Let’s start your next product the right way:
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