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Vietnam Announces New Technical Regulation for Toy Safety

Photo: Toys
Photo: Toys

In 2017, Vietnam informed the World Trade Organization (WTO) of its draft QCVN 3:2017/BKHCN ‘National Technical Regulation on Safety of Toys’ (SafeGuards 1/18).

In September 2019, the Vietnamese Ministry of Science and Technology announced the nation’s new technical regulation on toy safety.  The new QCVN 3:2019/BKHCN technical regulation, published under Circular Number 09/2019/TT-BKHCN of September 30, 2019 (the Circular), contains several important changes to QCVN 3:2009/BKHCN:

  • Revising the version of standards for physical and mechanical properties, flammability and migration of certain elements in table below

  • Adding requirements for six phthalates – three phthalates for (all) toys and three phthalates for toys which can be placed in the mouth

  • Requirements for labeling in accordance with Decree No. 43/2017/ND-CP of April 14, 2017.
In addition to the above changes, other important provisions in the new technical regulation include:

  • Declaration for toys conforming to the technical requirements (Section 2) in the regulation, conformity mark (CR mark) and labeling before they are placed on the market.

  • Toys manufactured domestically or imported are required to undergo certification using Mode 5 or 7 – the certificate is valid for three years

  • Declaration of Conformity (DoC) for domestically manufactured toys

  • Imported toys to be registered for inspection on their quality (Circular 28/2012/TT-BKHCN)

  • List of HS Codes for toys falling under the scope (Appendix I)

  • List of products not considered as toys (Appendix II)
There are two effective dates:
  • December 31, 2019 for the Circular other than Section 2 ‘Technical Regulations’ to the QCVN 03:2019/BKHCN national technical regulation

  • January 1, 2021 for Section 2 ‘Technical Regulations’ to the QCVN 03:2019/BKHCN national technical regulation (requirements for physical, flammability, chemicals, accessible liquids, electric safety and labeling)
According to the Circular, toys that are compliant with the QCVN 3:2009/BKHCN national technical regulation under Circular Number 18/2009/TT-BKHCN of June 26, 2009 may remain on the market until December 31, 2021.

Highlights on the technical requirements between QCVN 3:2019/BKHCN and QCVN 3:2009/BKHCN are summarized in the table below.
National Technical Regulations on Safety of Toys

QCVN 3:2019/BKHCNQCVN 3:2009/BKHCN
ScopeToys for children under the age of 16Toys for children under the age of 16
Physical and mechanical propertiesTCVN 6238-1: 2017
(ISO 8124-1: 2014)
TVCN 6238-1:2008
(ISO 8124-1:2000)
Flammability
TCVN 6238-2: 2017
(ISO 8124-2: 2014)
TVCN 6238-2:2008
(ISO 8124-2:2007)
Migration of certain elementsTVCN 6238-3:2011
(ISO 8124-3:2010)
TCVN 6238-3:2008
(ISO 8124-3:1997)
Accessible liquids3 ≥ pH ≤103 ≥ pH ≤10
Formaldehyde in accessible toy materials for children under the age of 3

≤ 30 mg/kg content (textiles)

≤ 30 mg/kg content (paper)

≤ 80 mg/kg release (resin bonded wood)

≤ 30 mg/kg content (textiles)

≤ 30 mg/kg content (paper)

≤ 80 mg/kg release (resin bonded wood)

Phthalates

≤ 0.1% for each of BBP, DBP and DEHP in toys

≤ 0.1% for each of DIDP, DINP and DNOP in toys which can be placed in the mouth

(TCVN 6238-6:2015 (ISO 8124-6:2014))

N/A
Primary aromatic amines (PAA)≤ 5 mg/kg each listed PAA≤ 5 mg/kg each listed PAA
Electric safety

≤ 24V for nominal input voltage (toy)

≤ 24V for nominal or instantaneous voltage (toy or part of toy)

≤ 24V for nominal input voltage (toy)

≤ 24V for nominal or instantaneous voltage (toy or part of toy)

LabelingDecree No. 43/2017/ND-CP of April 14, 2017In accordance with law on labeling and corresponding standards
Effective dateJanuary 1, 2021In force


Definitions

1. BBP = Benzyl butyl phthalate

2. DBP = Di-n-butyl phthalate

3. DEHP = Di-(2-ethylhexyl) phthalate

4. DIDP = Di-iso-decyl phthalate

5. DINP = Di-iso-nonyl phthalate

6. DNOP = Di-n-octyl phthalate


SGS offers a wide range of services to ensure that your products comply with the EU Toy Safety Directive. For further information, please visit https://www.sgs.com/toys-and-juvenile-products.

Email SGS Hong Kong Ltd. at mktg@sgs.com for enquiry or visit: www.sgs.com.

Content provided by SGS Hong Kong Limited
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