Lesson #7 – Child Safety Testing

This week, Dan takes us through his experience with child-safety testing of his game Dino Dude Ranch. For designers thinking about making games for children, this must-read post covers everything from who he used to test, to the costs of doing it, and whether he feels like it actually helped.

I wanted to write a post about child safety testing as this seems like something that comes up often.  I would like to preface this post with the statement that I AM NOT A LAWYER. I am posting the information I have gathered in researching the process and my best understanding of what I have learned. I did have safety testing performed for Dino Dude Ranch when it was printed and I plan to go into detail about why I had that performed and what it entailed.

What tests did I have performed?

I had all of the tests that conform to European Union standards EN71-1, EN71-2, and EN71-3
1.EN71–Part1: 2014 Mechanical and Physical Properties
2.EN71–Part2: 2011+A1:2014 Flammability
3.EN71 – Part 3:2013 + A1 :2014 — Migration of certain elements

There are more than just these three parts of EN71 (There are actually nine). These are the only three that applied to my (and most) board game.

Safety testing for the EN71 standards is what allows you to place the CE mark on the box signifying that it conforms to safety standards.

Complying with EN71 also overlaps with the United States’ standards ASTM F963. So doing this set of test will assure compliance for both European Union and United States standards (It may also comply with other countries’ standards as well, I just have not looked them up to compare).

Here is a neat little chart breaking down safety standards in different countries and how they overlap:
http://industries.ul.com/wp-content/uploads/sites/2/2014/01/InternationalToyPamphlet_12132013_TBLOD_Web.pdf
It also includes some nifty information on general markings to put on the box etc.

Who performed the testing?

Product Technology Service (Ningbo) Co., Ltd.
6&7F, 59#, Huayu Road,
Yinzhou District, Ningbo 315192 P.R. China

How did I set this up and how long did it take?

I informed my contact at WinGo that I wanted the safety testing done and he is the one who informed me that for board games, you want to be in compliance with EN71-1, EN71-2, and EN71-3 and they set the rest up. When they printed my physical proof, they printed an additional copy to be sent to the testing center. By the time I had made changes based on my proof and had corrected all of the issues I could see, the testing was completed and the results were mailed to me.  This was a pretty quick turnaround of about 2-3 weeks. I received a PDF copy of the results almost immediately and WinGo packed the paper copy of the certifications in with my games when they shipped the mass printing to me.

How much did it cost?

The cost for the Dino Dude Ranch safety testing totaled $1,016.00.  There are a lot of components in the game and although I am assuming it would cost less for something with fewer components (i.e. cards only) I have no basis for this assumption. If anyone has had safety testing performed with a game containing fewer components, please comment about it and let us know!

Are there ways to be exempt from the child safety testing?
Yes, if you are distributing in the US only and you are producing less than 7,500 units of the product in question AND you had a gross revenue of all consumer products under $1,086,627 in the previous year, you can ask to be placed on the small batch manufacturer’s registry. More information can be found at:
http://www.cpsc.gov/en/Business–Manufacturing/Small-Business-Resources1/Small-Batch-Manufacturers-and-Third-Party-/

Why did I have child safety testing performed if it was not absolutely required?
I felt that my game definitely warranted an 8+ rating on the box. The art and game play both scream “FOR A YOUNGER AUDIENCE” and I felt this age rating was completely appropriate.  Furthermore, I wanted this game to be available not just in game shops but in museums and toy shops as well I felt that having the appropriate age on the box was important if I wanted the game to be sold in more mainstream places like Science Museums.
I worked with Ideaspatcher for fulfillment of Dino Dude Ranch and they informed me that customs would require documentation of child safety testing if the 8+ rating was placed on the box being imported.  Furthermore, I wanted to send the game to Oppenheim Toy Portfolio for assessment in regards to their game awards and child safety testing is required for submission.

Will putting 13+ on a younger kids game allow you to be exempt from safety testing?
Yes and no. I am sure that if I put 13+ on the box, I would not have had to worry about the safety testing for distribution in the EU.  However, the Consumer Product Safety Commission in the US states clearly on their site that the age-range on the box is not the only factor they use in determining the age appropriate level of a product. They take into account the art on the box, who the game/game play appeals to, and who it is marketed to. This means that if you have a game with artwork geared towards a young audience and you market it to kids and the game play is aimed at very young children, putting 13+ on the box might not get you around having to worry about child safety testing. I would like to point out though that this is something that does not seem to be pursued very often in the board game industry and usually is only something worried about by larger companies.  I do recommend though that if you have a game geared towards a young audience and you are not going to have the safety testing performed, I would make sure you get on the small batch manufacturer registry that I linked earlier so that you can sleep with peace of mind.

Please let me know if you have any questions. As I previously stated, I am not a lawyer and do not pretend to be.  I hope you found this information useful and feel free to contact me if you have any questions. Good luck in your ventures and happy gaming!

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