Child appealing electrical appliances
Child appealing but not a toy
It is tempting to feature household appliances with eye-catching designs, including designs that attract children.
Frequently asked questions are “should this product be considered as child appealing”, “is the toy safety legislation applicable”, “which standard can I apply for the risk assessment”, and “is it even allowed to sell electrical appliances with child appealing designs”.
Confusion often arises over the concept of ‘play value’ or ‘use in play’. Virtually everything has play value for a child, but this does not make every product fall into the definition of a toy. The Toys Safety Directive applies only to products designed or intended for use in play by children under 14 years. Adding child-appealing designs to appliances comes very close to intended for children, the key question is: is it foreseeable that the child will play with the appliance as it would play with a toy. Even if a child appealing product is not a toy, it still needs to be safe for children in accordance with the provisions of the General Product Safety Regulation (EU) 2023/988.
Child appealing appliances are fully functional household appliances designed with features that appeal to children. The child appealing risk shall be assessed under the General Product Safety Regulation (EU) 2023/988 and the EN IEC 60335 series of standards for electrical appliances. Specific warnings are required to prevent children from mistaking them for toys.
Example: a frog shaped insect killer with UV lamp and fan.
Functional toys perform and are used in the same way as an appliance intended for use by adults, and which often are a scale model of such appliance or installation. As the name implies, these are toys. Non-functional replicas of real appliances intended for play are also classified as toys because they provide a play value rather than real functionality.
Example: a miniature toaster with sounds.
Identifying child appealing features
Article 6 of the General Product Safety Regulation (EU) 2023/988 emphasises key factors to consider when assessing the safety of child appealing appliances that are not toys. Extra precautions are inevitable if the design, packaging, or characteristics make the appliance attractive to children.
To guide economic operators identifying child appealing features, the Coordinated Activities on the Safety of Products (CASP) has published the “Child-appealing (including Food Imitation) Products” Handbook in 2021.
The handbook contains questions that could be part of the risk assessment regarding the accessibility of appliances and possibly child appealing characteristics.
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Questions |
Explanation |
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What is the foreseeable use of the products? Where is the item likely to be stored in the home? Are there indications or warnings on the products? |
Household electrical appliances are often stored in easily accessible places like on the kitchen countertop, so they can be used frequently by all household members. To ensure safety, (power) cords should be kept out of children’s reach and regularly inspected for damage or fraying, and care should be taken not to overload electrical outlets. Clear instructions on the minimum recommended age for use, as well as proper handling of damaged cables, should also be provided.
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What is the level of supervision in relation to consumers? |
Very young children are more likely to be supervised. However, accidents can happen quickly and it is also important to take into account the possibilities over the lifetime of a product that this scenario happens. Instructions might be required about the minimum age of users and supervision. Warnings such as "children should not play with the appliance” or “Children should only clean and maintain the appliance under supervision” might be the outcome of the risk assessment. |
Elements to consider in the identification of child appealing appliances:
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Elements |
Explanation |
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Colour |
Products designed for children under 14 years old are typically featuring bright colours, which are more appealing and attractive to children. |
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Size |
Children’s articles are usually smaller and easier to handle, whereas larger and heavier products are generally less appealing for children to pick up. |
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Pictures |
Including an image or a logo can attract attention to the product but would not necessarily make the item a toy or encourage children to play with it. However, pictures designed for younger children, such as featuring cartoon characters, may increase the risk level, whereas others may be more suitable for an older age group. |
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Marketing |
The marketing of a product plays a key role in identifying its target audience and is reflected in websites, packaging, and advertisements. Packaging showing children using or playing with the product increases its attractiveness to children. |
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Interaction |
Interactive features (lights, sounds, movements) can encourage children to touch, move or adjust a product. For example, an appliance with a start button that plays music when pressed. |
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Play value |
Play is defined as engaging in an entertaining activity, typically for recreation rather than a practical purpose. Play value is usually long term (longer periods), unlike activities that quickly lose interest. While toys are specifically designed for play, other products may have features that encourage interaction and may give rise to repetition actions or play-like behaviour. |
Stricter requirements for child appealing appliances
Standard EN IEC 60335-1 states general safety requirement for household electrical appliances.
While child appealing appliances are not inherently prohibited, they must comply with stricter safety requirements under EN IEC 60335-1.
Clause 22.44 was updated in 2023 and provides the following criteria for child appealing appliances.
The appliance is child appealing if one of the following two criteria is present:
- It is decorated with faces, cartoon like characters, or similar images;
- It is shaped representing animals, characters, persons or scale models.
An appliance is also child appealing if two or three of the following criteria are present:
- It has non-functional lights (excluding illumination lights or status indicators);
- It makes non-functional sounds (e.g. music);
- It has non-functional movement (e.g. decorative spinning parts).
If the appliance is child appealing and:
- It weighs less than 4 kg; and
- It is mounted or normally intended for use at a height below 85 cm,
Then, the following conditions shall be met (summarised):
- Limited surface temperatures to prevent burns;
- No hazardous moving parts;
- No accessible live electrical parts;
- Accessible liquids shall not exceed 38 °C;
- No small, loose parts that could cause choking.
Other products
To clarify if other products shall be classified as child appealing or a toy, refer to the related article in ProductIPedia.
Additionally, search the EU Safety Gate with keyword "child appealing" for recalled products.
