Toys: EN 71-1:2014+A1:2018 with a restriction — clauses 3.19 and 4.15.1 give no presumption of conformity for wave rollers; Germany pointed to a risk of crushing and shearing fingers at the wheel, CEN/TC 52 asked whether a 5 mm or 12 mm rod had been inserted in the gap
Commission Implementing Decision (EU) 2025/1785, published on 10 September 2025, replaces row 1 of the list of harmonised standards for Toy Safety Directive 2009/48/EC (Implementing Decision (EU) 2023/740). EN 71-1:2014+A1:2018 “Mechanical and physical properties” stays on the list, but as regards clause 3.19 (definition of “driving mechanism”) and clause 4.15.1 it gives no presumption of conformity with Article 10(2) and Part I point 3 of Annex II to the Directive for wave rollers.
- A wave roller according to the decision is a children’s vehicle ridden in a sitting position, steered and propelled by the feet, whose wheels are within reach of the child’s hands. Germany’s objection of January 2024 (published in the notification system on 28 February 2024): there are no requirements protecting against crushing, shearing, jamming and trapping of body parts where the wheel is close to the seat and the child’s hands are free and low above the ground — fingers can be drawn into the gap between the wheel fork and the wheel.
- According to Germany, the EN 71-1 requirements for children’s vehicles are partly product-specific (bicycles, scooters) or concern certain parts (driving mechanisms, folding and sliding mechanisms), and the definition of “driving mechanism” in clause 3.19 does not cover wave rollers. General hazard-based requirements for crushing, shearing and trapping points for fingers and hands are missing, including when turning the handlebar and under the pulling force of the wheel.
- Dispute over testing: CEN/TC 52 asked whether the rod shown in the objection had a diameter of 5 mm or 12 mm — in the photo a smaller test rod was inserted into the gap between wheel and frame, while the larger probes of the standard’s test method apparently would not have fitted, which would mean the vehicle did not comply with clause 4.15.1.6 c) (general requirement on finger entrapment). The committee also acknowledged that the draft revised clause 4.15 introduces new requirements on finger crushing and shearing.
- Outcome: after discussion in the committee under Article 22 of Regulation (EU) No 1025/2012 (18 April 2024) and in the Toy Safety Expert Group, the Commission accepted Germany’s analysis; the other clauses of EN 71-1 still confer a presumption of conformity. The original row 1 of Decision 2023/740 listed EN 71-1:2014+A1:2018 without restriction. The decision entered into force on the day of publication — wave rollers can no longer be assessed on clauses 3.19 and 4.15.1 alone.