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Tuesday 20 April 2021

UKCA / CE Testing Home-Made Playdough for sale

Thinking of CE testing and selling playdough? Did you know that to LEGALLY sell homemade playdough you HAVE to have it UKCA / CE certified to get the CE mark (EU) or the UKCA mark (UK) and chemically tested under EN71-3 by an independent lab in order for this to be certified as safe for children? Not just one sample either... each colour of dough needs to be tested separately under the toy safety directives, and if you change your ingredients or supplier then you will have to retest? 

Rainbow coloured tins of playdough from childledplay.co.uk with words UKCA CE Testing playdough

I have been through the UKCA / CE testing process with my own gluten free, homemade playdough which I sell over in my shop - www.childledplay.co.uk. Finding the right information 
was a long, drawn out process and getting the right answers took up a lot of time. If you have found this post due to your own information searching, I hope that this helps you to understand how to start the process of CE testing playdough and how to work out if this is a viable option for you....

The BS EN71 Toy Safety tests for UKCA testing playdough:

The British Standards for the safety of toys under the toy safety directives relating to playdough fall into 3 parts - EN71-1, EN71-2, EN71-3. In order to be CE or UKCA certified you will need to test against all 3 in order to carry the CE mark (EU) or the UKCA mark (UK). You cannot presume safety, even if you're sure it will pass, you have to prove it. It is possible to conduct your own tests against part 1 and 2 at home with the right equipment and guidance, but part 3 needs to be tested in a lab, you cannot do this yourself. 

Lots of wooden toy sellers and soft toy sellers conduct the EN71-1 and EN71-2 tests themselves after having their material,  raw wood or wood sealant tested against EN71-3. This is because every new or different shape and size of wooden toy needs to be tested individually and this can soon add up. It can work out more cost effective to buy a home testing pack and the equipment needed to do the tests than to pay for the lab to do all of these tests. 

There are a couple of different options if you'd like to buy a testing pack to conduct these tests yourself. The two main ones are Conformance (here) and The UKCA Handmade Toys Collective (here). There is also a free resource centre in progress here which gives lots of information about how to carry out these parts of the test. 

You can also download or borrow the British Standards yourself from any university or city library in order to read more about these regulations and tests involved.

(NB: I am not affiliated with either of these companies and I do not receive anything for mentioning them. I have purchased one of these packs myself for testing my own wooden items, but you must do your own research into which is the best option for you and which suits your own needs. )

EN71-1 Mechanical and Physical properties

 These tests involve a number of physical manipulations such as torque tests, drop tests, impact tests and checking for sharp edges and small parts before and after the tests have been performed. For playdough, these tests will take place with the playdough inside it's container which you intend to sell the dough in. I personally paid for the lab to do this test for me on my playdough sample.

EN71-2 Flammability

This test involves timing the burn time of an item by holding it at a certain distance from a certain sized flame for a set amount of time and making sure that a child handling the object would have adequate time to drop the item and move away before it burned. Again, this test was performed by the lab whilst in the intended packaging.

EN71-3 Migration of certain elements

" The Toy Safety Directive (2009/48/EC)  specifies maximum migration limits for three categories of toy materials...The limits for the migration of certain elements are expressed in milligram per kilogram toy material...The purpose of the limits is to minimize children’s exposure to certain potentially toxic elements "

The three categories are: 
I: Dry, brittle, powder like or pliable materials;
II: Liquid or sticky materials;
III: Scraped-off materials.

As playdough is classed as a pliable modelling material under BS EN71-3, it is tested under catergory I.

There are approx 20 elements which the playdough is tested for and this is after simulating the dough being in contact with a replication of gastric juices (should the playdough be ingested) for a period of time. If chromium is found to be an element over a certain amount then further tests will have to then be completed (and paid for in addition).

Here's the thing though: You have to CE test each colour of playdough.

When I found this out there were certain questions I asked:
- Can I say I’m selling it as an educational resource and bypass the CE/UKCA tests?

- Can I colour one sample of dough with all of the colours and test that?

- Can I use colours that have already been CE tested and bypass the testing that way?

Answers: No, no and no. (Unfortunately)

Educational resources are ONLY sold to schools and nursery settings via a website which requires school registration. A private buyer having this delivered to their home address is not classed as  'educational'. 

It is the ‘migration of materials’ that is tested. The particular combination for THAT sample and the way the elements react together and the levels of certain elements they contain.

If I’d had all of this information at the start I don’t think I’d have gone down this route because the expense is huge. You have to sell ALOT of playdough to make that money back.

I get asked these questions by prospective playdough sellers regularly, and it’s always hard to give this info out because I KNOW how deflated they will feel after finding out and I feel like I am the bearer of the expensive bad news.

Which lab should I use to CE or UKCA test my playdough?

There are a number of labs you could choose from when deciding where to send your playdough to be CE tested, and I would recommend contacting them with your individual needs and ask for a quote and a timescale before deciding. Here are a few that either I, or others I know have used:

  • Intertek
  • MTS
  • SGS
  • Bureau Veritas
  • NTH

How much does it cost to CE/UKCA test playdough?

This can vary between different labs, and depending on whether you need further chromium tests or tests under REACH, but as an approximate guide:

  • EN71-1 - approx £100-150
  • EN71-2 - approx £14-£25
  • EN71-3 - approx £56 - £90

Remember, EN71-3 is per colour so you will probably have more than one of these to pay for.

So.... if  you are looking to buy homemade playdough - please support small business sellers who have gone the extra mile to have their dough tested to make sure it is safe for children. There are so many playdough sellers who haven't had their playdough tested - some who use ingredients such as poster paint, powder paint and fragrance oils which can be a real issue if ingested or in contact with the skin for long periods of time. 

My own playdough is made using 100% food grade ingredients and is inclusive for those suffering from a  wheat allergy as all of my ingredients are gluten free too. 

If you are looking to add playdough into your own play sets etc and cannot justify the  cost of testing, I do offer wholesale playdough for resale. Please get in touch with me via my shop Childledplay.co.uk

Sarah x

Disclaimer: I am not a UKCA testing expert, this blog post is based on my own personal experience. You must always do your own research and obtain advice from your lab of choice and your local Trading Standards. If you have any further queries, about this or any other product, please contact Trading Standards for your area.

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UKCA CE testing home made playdough

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