Last week we received a phone call from a concerned customer about EN71 testing and the requirements to operate within the law. She was struggling to get a definitive answer so we have looked into the potential issues and together come up with a simple solution.
One of the products she makes like a lot of crafters are Rabbit Ears on a wooden ring (see photo below)
The Rabbit Ears can be removed so that they can be washed. For compliance with EN71 the question is simple “are these Rabbit Ears a cord?”
“length of flexible textile or non-textile including elastic material, monofilament polymeric ribbon, rope, strap, woven and twisted material and string as well as certain weak and long springs”
It seems that the definition covers a wide variety of components and appears to cover more than is actually believed to be a cord by common understanding.
It seems anything that is now “flexible” and has “length” is covered by the definition.
The previous version of EN71-1 also included the word “slender”; this ensured that one of the defining factors of a cord was a length substantially greater than width.
The critical dimension is 220mm length as these products are suitable from birth.
When the product is presented as it is intended yes (will discuss later) it is; however, when the rabbit ears are removed they are over 220mm long and could potentially go around a child’s neck.
Therefore it is NOT complaint!
No toy should be given to a child especially one under 18months of age without being under adult supervision.
Could a child actually remove the Rabbit Ears from the ring? It is highly doubtful but it could be possible, therefore there is a risk. If one ear is pulled all it will do is secure it more tightly to the wooden ring.
Yes in fact there are two that we know but like all creative people there are probably more!
Attach the Rabbit Ears permanently to the wooden ring and the problem of the cord is solved. However this creates another issue the product cannot be washed, as the wooden ring is wipe clean only.
The Rabbit Ears when removed are over the critical length of 220mm so the length needs to be under this amount. The fix is quite simple if the Rabbit Ears are sewn together at the bottom then they can still be removed for cleaning and they are compliant. We have sewn ours (orange thread) with approximately 1 inch of stitches.
By sewing the ears together it creates a fixed loop, which leads to more compliance issues! The critical length for a fixed loop is 380mm so it cannot go over a head and around a child’s neck and be a potential strangulation risk. The fixed loop we have with our rabbit ears is approximately 150mm and well within scope of the EN71 requirements for compliance.
The seam you added on the Rabbit Ears is a critical addition and needs to be tested under EN71-1. Make sure it is strong enough to withstand the tension test.