UKCA Help

Understand UKCA and EN71

A plain-English overview of UKCA and what EN71-1, EN71-2 and EN71-3 cover for 3D-printed toys.

What UKCA compliance means for toy makers

If your product is a toy, it must meet the applicable requirements of the Toys (Safety) Regulations 2011 before it is placed on the market in Great Britain.

For most 3D-printed toys, this means you will need to:

  1. Assess the toy's risks.
  2. Identify the safety requirements that apply.
  3. Test and assess the finished toy.
  4. Obtain suitable evidence for its materials and components.
  5. Create the Technical File.
  6. Prepare a UK Declaration of Conformity.
  7. Apply the UKCA mark, manufacturer details, product identification and any required warnings.
  8. Maintain records showing that continued production remains compliant.

The EN71 toy safety standards provide recognised methods for assessing many of these safety requirements.

What is UKCA?

UKCA stands for UK Conformity Assessed.

The UKCA mark indicates that the manufacturer has assessed the product against the applicable Great Britain product safety requirements and takes responsibility for its conformity.

It is not:

  • A quality award
  • A certificate purchased for the finished toy
  • Approval from the government
  • Proof that Trading Standards has inspected the product
  • A replacement for testing or a Technical File

The mark is not the first step

You do not simply place the UKCA logo on a toy. You must first complete the applicable conformity assessment process and hold the evidence supporting your declaration.

Who is the manufacturer?

For 3D-printing businesses, the manufacturer is normally the person or business that makes the toy and sells it under their own name or brand.

This remains the case if:

  • You purchased the digital model from a designer.
  • You use filament made by another company.
  • A testing laboratory supplied material evidence.
  • Someone else prints part of the product for you.
  • You assemble the toy using bought-in components.

The manufacturer of the finished toy is responsible for ensuring that the finished product complies.

A designer, filament manufacturer, component supplier or testing laboratory may provide information and evidence, but they do not take over your responsibility for the toy you place on the market.

What is EN71?

EN71 is a series of safety standards for toys. The standards describe recognised requirements and test methods that manufacturers can use to help demonstrate compliance with the Toys (Safety) Regulations.

The three parts most commonly relevant to ordinary 3D-printed toys are:

  • EN71-1: Mechanical and physical properties
  • EN71-2: Flammability
  • EN71-3: Migration of certain elements

These parts deal with different types of risk. Passing one part does not mean the toy has passed all three.

Some specialist products may require other standards or additional parts of the EN71 series. Electrical toys, activity toys, finger paints, chemical toys and certain other products can have additional requirements.

Standards and the law are not the same thing

The Toys (Safety) Regulations set the legal requirements.

Designated standards provide recognised technical methods that can be used to demonstrate that relevant requirements have been met. Correctly following an applicable designated standard can provide a presumption of conformity for the requirements it covers.

That does not remove the manufacturer's responsibility. You must still:

  • Decide which requirements apply.
  • Assess risks not fully covered by the standards.
  • Use the correct version of the applicable standards.
  • Record the tests, assessments and evidence.
  • Ensure every toy produced continues to comply.

If a relevant designated standard is not followed, does not cover the product fully or has been applied only in part, you may need another valid way to demonstrate compliance. In some circumstances, assessment by a UK Approved Body may be required.

EN71-1: Mechanical and physical safety

EN71-1 examines the toy's design, construction and physical behaviour to identify hazards that could cause injury.

For a 3D-printed toy, the applicable checks may cover:

  • The finished toy and any detached pieces against the small-parts cylinder
  • Parts that could detach during foreseeable use
  • The strength of joints, limbs, accessories and other features under torque and tension
  • Damage caused by dropping the toy
  • Hazards created by impact or compression
  • Sharp edges or sharp points exposed during testing
  • Cords, chains, loops and straps
  • Finger traps in holes, gaps and moving parts
  • Pinching or crushing risks from springs, hinges and mechanisms
  • Hazardous shapes, dimensions or projections
  • Cleanability requirements
  • Appropriate warnings and age restrictions

The exact checks depend on the toy's design, intended age group, features and foreseeable use. Not every test applies to every product, but each one should be considered and the decision recorded.

The finished toy matters

A strong filament does not prove that the finished toy is mechanically safe.

The outcome can be affected by:

  • The model's design
  • Wall thickness
  • Infill
  • Layer height
  • Print orientation
  • Layer adhesion
  • Nozzle and temperature settings
  • Joint clearances
  • Glued or assembled parts
  • Added components
  • Scaling the model up or down

EN71-1 therefore needs to be considered on the finished product in the form in which it will be sold.

A break is not automatically an overall failure

If a toy breaks during an applicable test, you must assess what the break has created.

For example, a detached part may create:

  • A small-part choking hazard
  • A sharp point
  • A sharp edge
  • Access to a hazardous internal component

The result may mean that the toy:

  • Needs a design or construction change
  • Needs to be printed using different settings
  • Is unsuitable for children under 36 months
  • Needs to be tested again
  • Cannot safely be placed on the market in its current form

The result and your decision must be documented.

EN71-2: Flammability

EN71-2 covers the flammability hazards of toys.

It considers how quickly certain toys or toy materials may ignite and how flames may spread. It contains specific requirements for categories such as:

  • Toys worn on the head
  • Toy disguise costumes
  • Toys intended to be entered by a child
  • Soft-filled toys
  • Certain other toys with surfaces that may present a flammability risk

Not every ordinary 3D-printed toy will require the same physical flame test. You must first assess the toy's design, materials and intended use to determine which EN71-2 requirements and tests apply.

What to consider

Your assessment should consider:

  • The type of filament or other material used
  • Soft-filled, textile, furry or hair-like parts
  • Costumes, masks and wearable items
  • Decorations and surface finishes
  • Adhesives, paints or coatings
  • Toys designed to be worn
  • Toys a child can enter or hide inside
  • Designs that could increase exposure to flame

Don't skip the assessment

Do not simply record EN71-2 as "not applicable" without explaining why. Your Technical File should contain the assessment and the reasons for your conclusion.

EN71-3: Migration of certain elements

EN71-3 deals with the migration of certain regulated elements from toy materials.

It is designed to assess the potential for controlled elements to transfer from accessible toy materials under specified test conditions. These include elements such as lead, cadmium, mercury, chromium and others covered by the standard.

For 3D-printing businesses, EN71-3 evidence may be needed for:

  • Filament
  • Paint
  • Coatings
  • Adhesives
  • Resin
  • Flexible materials
  • Metal components
  • Keyboard switches
  • Keyring parts
  • Chains
  • Bells
  • Safety eyes
  • Other accessible components or finishes

EN71-3 usually relates to materials, not the toy's strength

EN71-3 evidence for filament supports the chemical assessment of that specific material. It does not show that the finished toy is mechanically safe or sufficiently strong.

Likewise, passing EN71-1 tests on the finished toy does not prove that its materials meet EN71-3.

The different parts perform different jobs:

  • EN71-1: What happens physically to the finished toy?
  • EN71-2: Does the toy present an applicable flammability hazard?
  • EN71-3: Is there suitable chemical evidence for its accessible materials?

Match the evidence to what you actually use

Material evidence should be relevant and traceable to the material or component used in the finished toy.

For filament, record details such as:

  • Manufacturer or brand
  • Filament range
  • Material type
  • Colour
  • Supplier
  • Batch or lot information
  • Supporting certificate or test report

A report for one brand or filament range does not automatically cover a different manufacturer, range or formulation.

Changing the brand, range, material or another relevant characteristic may require different evidence and a review of the Technical File.

Does every colour need separate testing?

Not necessarily. Different colours may contain different pigments, so the complete colour range must be considered when arranging EN71-3 testing.

One practical approach is representative colour testing. Suitable colours are selected to provide evidence across a wider filament range rather than every colour being tested separately.

Representative CMYK testing

Where the filament range allows it, 3D CertHub uses representative CMYK colour testing:

  • Cyan
  • Magenta
  • Yellow
  • Black

These colours represent the main colour groups used to produce many other colours within a filament range. Testing them can provide relevant supporting evidence for additional colours made using the same base material and formulation.

Representative testing must still be reasonable and supported by the range being assessed. CMYK testing does not automatically mean that every product made by the brand is covered.

The evidence must relate to:

  • The same manufacturer or brand
  • The same named filament range
  • The same material and base formulation
  • Colours covered by the representative testing rationale
  • Relevant supporting information from the manufacturer or supplier

Some colours and finishes may require separate consideration because they can contain different pigments, fillers or additives. Examples may include:

  • White
  • Metallic colours
  • Fluorescent or neon colours
  • Glow-in-the-dark filament
  • Glitter or sparkle finishes
  • Marble or stone effects
  • Wood-filled filament
  • Colour-changing filament

Don't assume coverage

One randomly selected colour does not cover the entire range. CMYK testing for one filament range does not cover another range. A certificate for standard PLA does not cover PLA+, matte PLA, silk PLA or another formulation. Testing one manufacturer's filament does not cover a different manufacturer. Not every special-effect colour is represented by standard CMYK colours.

The certificate or supporting information should clearly identify the filament range, the colours tested and the basis on which additional colours are covered.

What about bought-in components?

A toy must be assessed as a complete product.

Bought-in items such as switches, keyrings, chains, magnets, bells, screws, safety eyes or electronic parts are not automatically suitable for toys simply because they are commercially available.

You should consider:

  • Accessibility of the component
  • The materials used
  • The possibility of it detaching
  • Any mechanical hazards it introduces
  • The available chemical evidence
  • Other legal requirements triggered by the component

A material certificate does not replace mechanical testing of the component after it has been fitted to the finished toy.

Can makers carry out their own testing?

Many ordinary mechanical and flammability assessments can be completed and documented by the manufacturer where the applicable conformity route allows it and the manufacturer has the correct information, equipment and competence.

This does not mean estimating, casually handling the toy or writing "passed" without evidence.

Your records should show:

  • What was tested
  • Which requirement or method was used
  • The equipment and test conditions
  • Photographs or video where appropriate
  • The result
  • Any damage or detached parts
  • The conclusion reached
  • Any design changes and retesting

Chemical migration testing under EN71-3 requires specialist laboratory equipment. Makers normally rely on suitable laboratory reports or certificates for the materials and components they use.

EN71 does not replace the risk assessment

Standards cannot predict every feature or hazard of every 3D-printed toy.

You must also carry out a safety assessment covering the toy's chemical, physical, mechanical, electrical, flammability, hygiene and any other relevant hazards.

The risk assessment helps you identify:

  • The EN71 requirements that apply
  • Specialist requirements triggered by the design
  • Risks not fully covered by a standard test
  • Suitable age grading
  • Required warnings and instructions
  • Design changes needed before sale

Testing and risk assessment support each other. One does not replace the other.

Age grading affects the requirements

The intended age group affects how the toy must be assessed.

A toy intended for children under 36 months is subject to stricter requirements, particularly around small parts and foreseeable behaviour.

A warning such as:

"Not suitable for children under 36 months. Small parts."

may only be used where it is appropriate and does not contradict the toy's intended use.

A warning can't undo the design

A toy that is clearly designed for children under three cannot use an age warning simply to avoid the requirements for that age group. Age grading should be based on the product's design, function, play value, ability required and foreseeable users, not just the manufacturer's preferred market.

Bringing the evidence together

UKCA compliance is not one test or one certificate. It is the complete body of evidence showing that the toy has been properly assessed.

Your Technical File should bring together:

  • A description and identification of the toy
  • Product and construction details
  • Intended use and age grading
  • The safety and risk assessment
  • EN71-1 testing and results
  • The EN71-2 assessment and applicable testing
  • EN71-3 material and component evidence
  • Product photographs
  • Labels, warnings and instructions
  • The UK Declaration of Conformity
  • Batch and material traceability
  • Changes, variants and retesting
  • Evidence that continued production remains compliant

The Technical File and Declaration of Conformity must be retained for the required period. Current government guidance states that manufacturers must keep them for 10 years.

The process in plain English

For a typical 3D-printed toy:

  1. Decide the intended use and age group.
  2. Identify foreseeable hazards.
  3. Confirm which safety requirements and standards apply.
  4. Test and assess the finished toy under EN71-1.
  5. Assess the applicable EN71-2 flammability requirements.
  6. Gather EN71-3 evidence for accessible materials and components.
  7. Resolve any failures or missing evidence.
  8. Record everything in the Technical File.
  9. Prepare and sign the UK Declaration of Conformity.
  10. Apply the UKCA mark, product identification, manufacturer information and applicable warnings.
  11. Maintain batch records and review changes to the product or materials.

Ready for the next step?

Now that you understand what UKCA, EN71-1, EN71-2 and EN71-3 cover, the next step is testing and assessing your finished product.

Continue to product testing

This information is intended to help 3D-printing businesses understand the toy compliance process in Great Britain. It does not replace the legislation, the applicable standards or product-specific professional advice.

Official sources:
Toys (Safety) Regulations 2011: Great Britain
UK designated standards
Placing UKCA or CE-marked products on the market in Great Britain