Own-brand toy safety assessment and technical file

Define the toy and take ownership

For Great Britain, a buyer having toys made and marketing them under its own name or trade mark is the manufacturer. Read our toy safety and importer duties guide for the wider obligations. This guide focuses on assembling the evidence behind your own-brand toy.

Start an index identifying the model, intended users, intended play, approved sample and design revision. Record who supplies each document, who reviews it and what remains unresolved. Keep separate variant records where materials or construction differ, with a written explanation wherever evidence is shared.

Write a toy-specific safety assessment

The assessment must analyse chemical, physical, mechanical, electrical, flammability, hygiene and radioactivity hazards, together with potential exposure. Use a hazard register recording the relevant part, how a child could encounter the hazard, the control and the supporting evidence. Explain why a hazard category is irrelevant rather than leaving it blank.

Consider intended play and foreseeable behaviour, including mouthing, pulling, dropping and access after breakage. Connect each conclusion to drawings, material information, tests or another documented justification. Ask a toy safety specialist to review uncertain exposure assumptions before you finalise the testing brief.

Connect components to chemical supplier sheets

The technical documentation must include, so far as relevant for assessment, a detailed design and manufacturing description, component and material lists, and safety data sheets for chemicals used, obtained from chemical suppliers. Build a BOM that identifies plastics, fabrics, fillings, coatings, inks, adhesives and bought-in parts.

Give each entry a material specification, supplier identity and document reference. Match each SDS to the actual chemical product used, checking the product identifier and revision. Ask for clarification where a sheet describes a different coating or only a broad material family. Keep chemical test reports alongside these records, with the tested materials clearly identified.

Use the chemical information to inform the exposure assessment and testing brief; do not treat a supplier sheet as a finished-toy test result. Our UK REACH guide covers the separate chemical compliance questions.

Show how production matches the assessed toy

Record manufacturing and storage addresses in the file. Ask the factory for a process description showing material receipt, assembly, finishing and checks. Attach approved drawings, sample photographs and inspection records so a reviewer can follow the connection between the assessed design and the goods produced.

Manufacturers must ensure continuing production remains in conformity. Agree approval of material, component and process substitutions before use. Keep batch records linking supplied materials to finished toys, record deviations and document their resolution. Use our quality inspection guide to plan the factory checks.

File conformity records and control release

Include the procedure description and declaration of conformity. For internal production control, retain test reports and explain how production conforms to designated standards. For the type examination route, retain the certificate, production conformity explanation and documents submitted to the approved body. Confirm the applicable procedure with your conformity assessor rather than choosing it from a factory report heading.

Before release, check that model identifiers and revisions agree across the assessment, BOM, reports, declaration and packaging artwork. Maintain a gap list with an owner and closure evidence for each item. Keep the technical documentation and declaration for ten years, with copies controlled by your business rather than accessible only through the supplier.