By implementing these alternative solutions, toy manufacturers can address the most common reasons for toy recalls and ensure the safety and well-being of children. It is vital to prioritize safety throughout the design, production, and marketing of toys to build trust with consumers and create a positive impact on the lives of children.
Choking Hazards: Small parts that can be detached and swallowed by young children. This is a major safety concern, especially for babies and toddlers.
Alternative Solutions:
- Design larger parts: Ensure all parts are at least 3 cm in diameter and 6 cm in length to prevent choking hazards.
- Use stronger adhesives: Securely attach small parts to the main body of the toy, ensuring they cannot be easily detached.
- Clearly label age warnings: Clearly state the minimum recommended age on the packaging and toy itself to warn parents of potential choking hazards.
- Offer age-appropriate versions: Create different versions of the toy with larger parts or fewer detachable components for younger children.
- Conduct thorough testing: Utilize choking hazard testing equipment and procedures to ensure the toy complies with safety regulations.
Example:
VTech InnoTab Max Tablet Recall: https://www.vtechkids.com/recall
The recall of the VTech Shake and Sing Elephant Rattle due to choking hazards on its detachable ears highlights potential areas for improvement in the manufacturer's safety practices. Here are some ways VTech could have prevented this incident:
1. Design Modifications:
The detachable ears of the rattle violated the Toys (Safety) Regulations which states that "toys shall be designed and constructed in such a way that no small part can be detached and ingested or inhaled by a child." Additionally, the ASTM F963-17 standard includes specific requirements for small parts testing, which the rattle may have failed.
2. Improved Testing and Quality Control:
The detachable ears were likely not adequately tested for choking hazards, violating Regulation 4 of the 2011 Regulations which requires risk assessments and testing to ensure compliance with safety standards. Additionally, quality control measures may have been insufficient, allowing faulty rattles with detachable ears to reach consumers.
3. Clearer Warnings and Labeling:
The packaging and the rattle itself lacked clear and prominent warnings about the choking hazard associated with the detachable ears. These warnings should have been easily visible and understandable to parents and caregivers, potentially preventing choking incidents.
4. Post-Market Monitoring and Reporting:
VTech may not have had a robust system for collecting and analyzing reports of incidents and injuries associated with their products. This hindered their ability to identify the choking hazard associated with the detachable ears and take prompt action.
An example of another infant products but not related to chocking:
Preventing Rock 'n Play Sleeper Fatalities: A Missed Opportunity
Infant Deaths: Fisher-Price Rock 'n Play Sleeper (recalled in 2019)
The tragic deaths of over 100 infants associated with the Fisher-Price Rock 'n Play Sleeper raise serious questions about the manufacturer's role in preventing these tragedies. Fisher-Price notes that in some of the reports, it has been unable to confirm the circumstances of the incidents or that the product was a Rock ‘n Play Sleeper.
While some reports remain unconfirmed, the available information suggests several ways Fisher-Price could have acted to prevent these fatalities:
1. Design Changes:
The Rock 'n Play Sleeper's design may had violated several regulations from both The Toys (Safety) Regulations 2011 and the ASTM F963 standard:
- Inclination Angle: Inclined sleeping products for infants -- ASTM F963-17 requires that "the angle of inclination of any sleeping surface intended for infants 0-12 months of age shall not exceed 10°." The Rock 'n Play Sleeper's 30° incline significantly exceeded these limits, increasing the risk of rolling and suffocation.
- Safety Restraints: "sleeping products for infants shall be fitted with a harness system that complies with the relevant harness standards." ASTM F963-17 includes specific performance requirements for harness systems, including the ability to restrain a child firmly and prevent them from rolling over. The lack of adequate restraints in the Rock 'n Play Sleeper violated these regulations.
- Breathable Mattress: ASTM F963-17 requires that "the mattress used in a sleeping product for infants shall be designed and constructed to minimize the risk of suffocation." The Rock 'n Play Sleeper's mattress material could have contributed to suffocation risk, potentially violating this regulation.
2. Improved Warnings and Labeling:
The Rock 'n Play Sleeper's warnings and labeling might have been insufficient, violating Regulation 14 of the 2011 Regulations which states that "warnings shall be clear, concise, unambiguous, and easy to understand and shall be prominently displayed on the product and on any packaging." The age warnings were inadequate, and the instructions lacked critical safety information regarding the dangers of rolling and suffocation.
3. Enhanced Testing and Monitoring:
Regulations require manufacturers to conduct risk assessments and ensure that their products comply with all relevant safety standards. Fisher-Price's testing and monitoring practices were insufficient, potentially violating these regulations. They failed to identify the significant risk of rolling and suffocation associated with the Rock 'n Play Sleeper's design.
4. Responsible Marketing and Sales Practices:
Regulations prohibits misleading or inaccurate advertising and marketing practices. Fisher-Price's marketing of the Rock 'n Play Sleeper as a safe and comfortable sleep solution for infants may have violated this regulation, as it did not accurately represent the product's potential risks.
Fisher-Price Rock 'n Play Sleeper Recall: https://www.cpsc.gov/Recalls/2023/Fisher-Price-Reannounces-Recall-of-4-7-Million-Rock-n-Play-Sleepers-At-Least-Eight-Deaths-Occurred-After-Recall
Chemical Hazards: Toxic materials like lead, phthalates, or BPA can be harmful to children's health. These chemicals can cause various health problems, including developmental delays, cancer, and hormone disruption.
Alternative Solutions:
- Use safe materials: Select materials that are certified non-toxic and comply with international safety standards.
- Regularly test materials: Conduct independent testing to ensure the materials used in the toy are free of harmful chemicals.
- Improve manufacturing processes: Implement stricter quality control measures and monitor for potential contamination during the manufacturing process.
- Provide transparent information: Clearly disclose the materials used in the toy on the packaging and website.
- Offer alternative materials: Explore safer alternative materials for parts that traditionally contain harmful chemicals.
Examples:
This recall involved CultureFly’s L.O.L. Surprise! Trick or Treat-themed boxes sold with metal doll pins. The purple boxes have an image of three dolls, spiderwebs, skulls and bats; and the phrases L.O.L. Surprise! and Trick or Treat are printed on top. The metal doll pin has blue, pink and purple hair in pigtails, blue eyes, pink shoes and bra and underwear. They include magnetic, cutout clothes to dress the doll.
Remedy was:
Consumers should immediately take the recalled metal doll pins away from children, stop using them and contact CultureFly for a $10 refund. Consumers will receive an e-mail with instructions to return or dispose of the recalled metal doll pins in accordance with local state laws. Consumers will be contacted directly by CultureFly.
Mechanical Hazards: Sharp edges, points, or pinch points can cause injuries to children. Additionally, poorly designed toys can pose a risk of entanglement or strangulation.
Alternative Solutions:
- Round sharp edges and points: Ensure all edges and points are smooth and rounded to prevent cuts or scratches.
- Cover pinch points: Use protective covers or design the toy to eliminate any potential pinch points.
- Test for mechanical hazards: Conduct thorough mechanical testing to identify and address any potential hazards.
- Use safer materials: Choose materials with softer textures and properties to minimize the risk of injuries.
- Provide clear instructions: Include clear and detailed instructions on the packaging and website explaining how to safely use the toy.
Electrical Hazards: Electrical toys can pose a risk of electrical shock or fire if not properly designed and manufactured.
Alternative Solutions:
- Comply with electrical safety standards: Ensure the toy complies with all relevant electrical safety standards and regulations.
- Use insulated wires and components: Ensure all electrical components are properly insulated and shielded to prevent contact with children.
- Implement battery safety features: Include automatic shut-off mechanisms and use secure battery compartments to prevent leaks or explosions.
- Provide clear warnings: Include clear warnings on the packaging and toy regarding potential electrical hazards.
- Offer battery-free alternatives: Consider offering a battery-free version of the toy to eliminate electrical hazards altogether.
Flammability: Toys made from flammable materials can pose a fire hazard.
Alternative Solutions:
- Use flame-retardant materials: Select materials that are certified flame-retardant and comply with fire safety standards.
- Minimize the use of flammable materials: Limit the use of flammable materials in the toy's design and construction.
- Include fire safety instructions: Provide clear instructions on the packaging and toy regarding fire safety precautions.
- Offer non-flammable alternatives: Consider offering a non-flammable version of the toy made from safer materials.
- Conduct flammability testing: Conduct thorough flammability testing to ensure the toy meets safety regulations.
Allergic Reactions: Certain materials used in toys can trigger allergic reactions in some children.
Alternative Solutions:
- Use hypoallergenic materials: Choose materials known to be hypoallergenic and unlikely to cause allergic reactions.
- Clearly label allergens: Clearly identify any potential allergens on the packaging and toy itself.
- Offer alternative materials: Provide options for individuals with allergies by offering versions of the toy made with different materials.
- Conduct allergy testing: Conduct thorough allergy testing to identify any potential allergens in the toy's materials.
- Provide information on allergens: Include information on the packaging and website about the materials used in the toy and potential allergens.
Excessive Noise Levels: Toys that produce loud or excessive noise levels can damage children's hearing and disrupt their sleep.
Alternative Solutions:
- Limit noise levels: Design the toy to produce sound levels within safe limits as defined by safety regulations.
- Offer volume control: Include a volume control feature on the toy
Magnetic Hazards: Powerful magnets used in toys can be ingested by children and cause serious internal injuries.
Alternative Solutions:
- Use weaker magnets: Limit the strength of magnets used in the toy to prevent them from causing internal injuries.
- Encapsulate magnets: Encase magnets in a secure casing to prevent them from being detached and swallowed.
- Clearly label warnings: Include clear warnings on the packaging and toy regarding the potential dangers of magnets.
- Offer magnet-free alternatives: Consider offering a version of the toy without magnets to eliminate the risk altogether.
- Conduct magnetic force testing: Conduct tests to ensure the magnets used in the toy do not exceed safe force limits.
Small Batteries: Button batteries used in some toys can be easily swallowed by children and cause serious internal injuries.
Alternative Solutions:
- Use larger batteries: Use larger batteries that are too big for children to swallow.
- Secure battery compartments: Design secure battery compartments that require a tool to open, preventing children from accessing the batteries.
- Include bitter coating: Apply a bitter coating to the batteries to discourage children from putting them in their mouths.
- Offer battery-free alternatives: Consider offering a battery-free version of the toy or utilize alternative power sources.
- Provide clear warnings: Include clear warnings on the packaging and toy regarding the dangers of button batteries.
Lacerations and Puncture Hazards: Sharp edges or pointed parts on toys can cause cuts, punctures, or other injuries to children.
Alternative Solutions:
- Round sharp edges and points: Ensure all edges and points are smooth and rounded to prevent lacerations and punctures.
- Use softer materials: Choose materials with softer textures and properties to minimize the risk of injuries.
- Cover sharp edges: Use protective covers or design the toy to eliminate any potential sharp edges.
- Conduct thorough testing: Conduct rigorous testing to identify and address any potential laceration or puncture hazards.
- Provide clear warnings: Include clear warnings on the packaging and toy regarding potential sharp edges or points.
Inadequate Instructions: Unclear or incomplete instructions can lead to misuse of the toy, increasing the risk of injuries.
Alternative Solutions:
- Provide clear and concise instructions: Include detailed and easy-to-understand instructions on the packaging and website.
- Use visuals and diagrams: Supplement written instructions with images, diagrams, and illustrations to enhance clarity.
- Offer different language options: Provide instructions in multiple languages to ensure they are accessible to a wider audience.
- Test instructions with target audience: Conduct user testing with children and parents to ensure the instructions are clear and easy to follow.
- Offer online resources: Provide additional resources online, such as video tutorials or FAQs, to further explain the assembly and use of the toy.
Risk of Entrapment: Toys with small openings or compartments can pose a risk of entrapment, trapping children's fingers, limbs, or hair.
Alternative Solutions:
- Design larger openings: Ensure all openings are large enough to prevent entrapment of fingers or limbs.
- Avoid small compartments: Minimize the use of small compartments that could trap children's objects.
- Use flexible materials: Consider using flexible materials for parts that could potentially trap children to minimize the risk of injury.
- Conduct thorough testing: Conduct rigorous testing to identify and address any potential entrapment hazards.
- Provide clear warnings: Include clear warnings on the packaging and toy regarding potential entrapment risks.
Improper Labeling: Missing or inaccurate information on the packaging can mislead consumers about the age appropriateness and safety of the toy.
Alternative Solutions:
- Comply with labeling regulations: Ensure the toy labeling complies with all relevant regulations and includes all required information.
- Clearly state age warnings: Clearly indicate the minimum recommended age for the toy on the packaging and toy itself.
- List all materials used: Clearly disclose all materials used in the toy on the packaging and website.
- Include safety warnings: Include clear and concise warnings about potential hazards associated with the toy.
- Provide multilingual labels: Consider offering labels in multiple languages to cater to a wider audience.
Design Flaws: Poorly designed toys can be unstable, prone to breakage, or have features that pose a risk of injury.
Alternative Solutions:
- Conduct thorough design reviews: Conduct rigorous design reviews to identify and address potential safety concerns.
- Use robust materials: Choose durable materials that can withstand normal wear and tear.
- Test for stability and breakage: Conduct rigorous testing to ensure the toy is stable and can withstand typical use without breaking.
- Eliminate unnecessary features: Remove features that are not essential to the toy's function.
Data Privacy Concerns: Toys that collect children's data raise concerns about privacy and security.
Alternative Solutions:
- Implement strong data security measures: Ensure all data collected is encrypted, securely stored, and accessed only with parental consent.
- Provide clear privacy policies: Clearly explain on the packaging and website how children's data is collected, used, and shared.
- Offer opt-out options: Allow parents to opt out of data collection and choose what data is collected and shared.
- Limit data collection: Minimize the amount of data collected to what is necessary for the toy's functionality.
- Partner with reputable companies: Collaborate with companies that have strong data privacy and security practices.
Potential for Misuse: Toys can be misused in ways that could lead to injuries, such as using them as projectiles or weapons.
Alternative Solutions:
- Design toys for intended use: Ensure the toy's design encourages safe and appropriate play.
- Provide clear instructions and warnings: Include clear instructions and warnings on the packaging and toy regarding safe use and potential misuse.
- Promote responsible play: Partner with child development experts to create educational resources that promote safe and responsible play.
- Consider age-appropriate limitations: Design features that discourage misuse, such as age-appropriate challenges or limitations.
- Monitor trends and adapt: Stay informed about emerging trends in toy misuse and adapt designs or warnings accordingly.
Durability Issues: Toys that are not durable may break easily, posing choking hazards or other safety concerns.
Alternative Solutions:
- Use high-quality materials: Choose materials that are durable and can withstand normal play.
- Conduct rigorous testing: Conduct thorough testing to ensure the toy is durable and can withstand expected wear and tear.
- Offer warranties and guarantees: Offer warranties or guarantees on the toy to demonstrate confidence in its durability.
- Provide repair options: Make repair parts readily available or offer repair services to extend the life of the toy.
- Design for disassembly and recycling: Design the toy to be easily disassembled and recycled to minimize environmental impact and promote responsible consumption.
Sensory Overload: Some toys may be overly stimulating for children, leading to sensory overload and negative reactions.
Alternative Solutions:
- Offer adjustable features: Allow parents to adjust features like sound, light, and movement to suit individual needs.
- Provide sensory guidance: Offer suggestions on how parents can adjust the toy and the environment to create a positive sensory experience.
- Include sensory warnings: Clearly label toys with potential sensory overload triggers to guide parental choices.
- Offer a range of sensory options: Develop diverse toys with varying levels of sensory stimulation to cater to different preferences.
- Partner with sensory experts: Collaborate with sensory experts to ensure toys are inclusive and accessible to children with sensory sensitivities.
Ethical Concerns: Concerns may arise regarding the ethics of toy production, such as labor practices, environmental impact, and cultural appropriation.
Alternative Solutions:
- Partner with ethical manufacturers: Collaborate with manufacturers who adhere to fair labor practices and environmental sustainability standards.
- Use sustainable materials: Choose eco-friendly materials and production processes to minimize environmental impact.
- Respect cultural sensitivities: Conduct research and consult with cultural experts to avoid appropriation or insensitivity.
- Promote ethical sourcing: Clearly disclose the origin of materials used in the toy and ensure they are ethically sourced.
- Support ethical organizations: Partner with or donate to organizations promoting ethical practices in the toy industry.
Lack of Consumer Awareness: Consumers may not be aware of safety recalls or potential hazards associated with toys.
Alternative Solutions:
- Promote awareness campaigns: Partner with consumer protection agencies and other organizations to raise awareness about toy safety.
- Provide clear recall information: Clearly and readily communicate recall information through various channels, including websites, social media, and product packaging.
- Encourage product registration: Encourage consumers to register their toys with the manufacturer to receive recall notifications directly.
- Offer educational resources: Develop and provide educational resources on toy safety for parents and caregivers.
- Promote responsible toy purchasing: Encourage consumers to research toys before purchasing and choose safe and age-appropriate options.
Improper Testing: Toys that have not undergone proper testing may have hidden risks that are not discovered until after they are released to the market.
How can I test my toys for safety?
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Toy Design Evaluations and Safety Assessments: The Toy Association provides a guide for toy inventors and designers that includes evaluating whether a toy idea is unique, marketable, cost-effective, and safe1. Eurofins Toys & Hardlines explains how to conduct a toy safety assessment, which includes analyzing the chemical, physical, mechanical, electrical, flammability, hygiene, and radioactivity hazards that the toy may present2.
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Human Factors Evaluations: A study conducted by Edelbrock and Sugawara (1978) found that children are more likely to play with gender-stereotypical toys due to their peer interaction3.
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Chemical Management: The Toy Association provides a webinar recording that discusses what chemical management in toys is, why companies need it, and how to begin the process of getting it4. Eurofins Toys & Hardlines provides suggestions on how to prevent chemical risks in your toy supply chain5.
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Toxicological Risk Assessments: Eurofins Toys & Hardlines explains how to conduct a toy safety assessment, which includes a Toxicological Risk Assessment to fully manage the chemical risks not covered in EN71-32. They also provide a detailed explanation of what a Toxicological Risk Assessment is and how it is conducted6.
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Mechanical and Physical Testing: Worms Safety provides an overview of the mechanical and physical properties tests that are part of the EN 71-1 standard, including tests for structural integrity, surfaces or edges that could cause lacerations, and dimensions of a toy in relation to potential choking hazards7. Compliance Gate provides practical examples of processes that can be part of an EN 71 testing procedure, including a flammability test, sharp points test, and small parts test8.
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Flammability Testing: Compliance Gate provides an overview of the EN 71-2 flammability test as part of the toy safety testing procedure8.
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Heavy Metals Testing: The U.S. Consumer Product Safety Commission provides guidance on testing for heavy elements in toys9. API HK also provides an overview of the heavy metals testing requirements under the ASTM F963-17 regulations10.
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Small Parts Testing: Worms Safety provides an overview of the tension test, which evaluates whether small parts snap off the main body of the toy when tension is applied and create a choking hazard7.
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Quality and Defect Inspection Services: HQTS provides a range of quality control services for toys, including pre-production inspection, pre-shipment inspection, container loading and unloading inspections, and product testing and certification11. Tetra Inspection provides a range of toy quality control services, including visual inspections, functionality tests, chemical testing, physical testing, flammability testing, electrical safety testing, durability testing, age suitability testing, labeling and packaging testing, and environmental testing12.
Learn more:
1. toyassociation.org
2. eurofins.com
3. studocu.com
4. toyassociation.org
5. eurofins.com
6. eurofins.com
7. wsafety-news.com
8. compliancegate.com
9. cpsc.gov
10. api-hk.com
11. hqts.com
12. tetrainspection.com
13. cpsc.gov
14. studocu.com
15. saicmknowledge.org
16. sdg.iisd.org
17. stc.group
18. centexbel.be
19. cemarking-handmadetoys.co.uk
20. ul.com
21. childcare.extension.org
22. tukes.fi
23. tuv.com
24. eurofins.com
25. compliancegate.com
26. qima.com
27. cpsc.gov
28. ttl-labs.com
Additional Resources:
Toy Safety Testing Labs in 2023: A Guide
1. SGS:
- Website: https://www.sgs.com/en
- Headquarters: Geneva, Switzerland
- Global Presence: Over 2,600 offices and laboratories worldwide
- Accreditation: ISO/IEC 17025, CPSC-accepted
- Services: Chemical testing, mechanical testing, electrical safety testing, flammability testing, age-appropriate testing, toy safety consulting, toy safety training, and supply chain audits.
- Highlights: SGS boasts a vast global network, expertise in various safety areas, and a strong reputation for reliability and quality. (Source: https://www.sgs.com/en/services/toy-testing-and-certification-services)
2. TÜV Rheinland:
- Website: https://www.tuv.com/world/en/
- Headquarters: Cologne, Germany
- Global Presence: Over 500 locations in 65 countries
- Accreditation: ISO/IEC 17025, CPSC-accepted
- Services: Chemical testing, mechanical testing, electrical safety testing, flammability testing, age-appropriate testing, toy safety consulting, and toy safety training.
- Highlights: TÜV Rheinland possesses extensive experience in toy safety testing, a strong reputation for quality and reliability, and a commitment to innovation. (Source: https://www.tuv.com/world/en/)
3. Intertek:
- Website: https://www.intertek.com/
- Headquarters: London, UK
- Global Presence: Over 1,000 laboratories and offices in more than 100 countries
- Accreditation: ISO/IEC 17025, CPSC-accepted
- Services: Chemical testing, mechanical testing, electrical safety testing, flammability testing, age-appropriate testing, toy safety consulting, toy safety training, and product recalls support.
- Highlights: Intertek offers a global reach, comprehensive service range, and a focus on innovation, making it a one-stop solution for various toy safety needs. (Source: https://www.intertek.com/toys-childrens-products/)
4. Bureau Veritas:
- Website: https://group.bureauveritas.com/
- Headquarters: Neuilly-sur-Seine, France
- Global Presence: Over 1,600 offices and laboratories worldwide
- Accreditation: ISO/IEC 17025, CPSC-accepted
- Services: Chemical testing, mechanical testing, electrical safety testing, flammability testing, age-appropriate testing, toy safety consulting, factory inspections, and supply chain management services.
- Highlights: Bureau Veritas prioritizes technical expertise, adheres to ethical and sustainable practices, and offers additional services beyond testing to provide comprehensive support for manufacturers. (Source: https://www.cps.bureauveritas.com/needs/toy-product-safety-testing-and-compliance)
5. UL Solutions:
- Website: https://www.ul.com/
- Headquarters: Northbrook, Illinois, USA
- Global Presence: Over 140 locations in 46 countries
- Accreditation: ISO/IEC 17025, CPSC-accepted
- Services: Chemical testing, mechanical testing, electrical safety testing, flammability testing, age-appropriate testing, toy safety consulting, toy safety training, and risk assessment services.
- Highlights: UL Solutions has a strong US market reputation, possesses electrical safety expertise, and offers services tailored to specific product needs. (Source: https://www.ul.com/industries/products-and-components/toys-and-childrens-products)
6. UL Consumer Products:
- Website: https://secure.consumertesting.com/
- Headquarters: Northbrook, Illinois, USA
- Global Presence: Over 140 locations in 46 countries
- Accreditation: ISO/IEC 17025, CPSC-accepted
- Services: Chemical testing, mechanical testing, electrical safety testing, flammability testing, age-appropriate testing, toy safety consulting, toy safety training, and risk assessment services.
- Highlights: UL Consumer Products offers a wide range of services tailored to specific product needs, including expertise in electrical safety and a strong reputation in the US market.
7. TÜV SÜD:
- Website: https://www.tuvsud.com/en
- Headquarters: Munich, Germany
- Global Presence: Over 1,000 locations in more than 50 countries
- Accreditation: ISO/IEC 17025, CPSC-accepted
- Services: Chemical testing, mechanical testing, electrical safety testing, flammability testing, age-appropriate testing, toy safety consulting, toy safety training, and factory inspections.
- Highlights: TÜV SÜD boasts extensive experience in safety testing, a global reach, and a strong commitment to quality and innovation.
8. Intertek Consumer Goods:
- Website: https://www.intertek.com/consumer/consumergoods-overview/
- Headquarters: London, UK
- Global Presence: Over 1,000 laboratories and offices in more than 100 countries
- Accreditation: ISO/IEC 17025, CPSC-accepted
- Services: Chemical testing, mechanical testing, electrical safety testing, flammability testing, age-appropriate testing, toy safety consulting, toy safety training, and product recalls support.
- Highlights: Intertek Consumer Goods provides a comprehensive range of services, a global reach, and a focus on innovation, making it a one-stop solution for various toy safety needs.
