Product Age Grading in the EU
Under the General Product Safety Regulation (EU) 2023/988, every product must be suitable for its intended user age group. Age grading is a core part of the required internal risk assessment, especially when the product is child-appealing or marketed to teenagers. This article explains the EU legal requirements, guidance documents, and real examples for age grading under the GPSR and Toy Safety Directive.
Legal Foundation for Age Grading
The General Product Safety Regulation (EU) 2023/988 requires all consumer products to undergo risk assessment, including an evaluation of suitability for certain age groups. Article 9 and Annex I state that manufacturers must consider the characteristics and behavior of the intended users, including children and vulnerable groups.
If a product appears suitable for children, it must comply with stricter requirements. The presence of cartoon designs, small parts, or child-oriented packaging may trigger toy classification under Directive 2009/48/EC (Toy Safety Directive).
Guidance for Classifying Products by Age
The EU's Guidance Document No. 11 helps classify toys as suitable for children under or over 36 months. It provides criteria based on function, complexity, size, and foreseeable misuse. This guidance is critical for puzzles, dolls, plush toys, modeling kits, and collectible items.
EN 71 Standards for Toy Safety
If a product qualifies as a toy, it must comply with harmonised EN 71 standards:
- EN 71-1: Mechanical and physical properties
- EN 71-2: Flammability
- EN 71-3: Chemical safety (updated 2024 version applies from June 2025)
- EN 71-6: Age labeling symbols and warnings
These standards are listed under the EU's official harmonised standards portal.
Examples of Age Grading in Practice
- Under 3 Years: A soft plush toy with stitched eyes and no small parts is safe for toddlers. A similar toy with plastic sequins must be tested for choking hazards and may require labeling as "Not suitable for children under 36 months."
- 3 to 6 Years: A puzzle with 24 large pieces is appropriate for age 4+. If the pieces are small or complex, the minimum age must be raised and supported by testing.
- 7 to 14 Years: A craft kit with scissors and glue sticks is typically 8+. Sharp tools or chemicals elevate the minimum age to 12+ or higher.
- 14+: An enamel pin with a sharp metal clasp and collectible packaging may be graded 14+ under GPSR, with justification in the technical file.
- 16+: A DIY electronics kit involving soldering or lithium batteries should be marked 16+ and documented with appropriate risk mitigation.
- 18+: A CNC controller must be labeled 18+ due to electrical risk, moving parts, and software complexity. The technical file should justify this age grade with a risk assessment and include safety instructions, multilingual warnings, and documentation for proper use by trained adults only.
Labeling and Documentation
Every product covered by the GPSR must include:
- Age suitability labeling (e.g., "14+", "Not suitable for children under 36 months")
- Warnings based on unresolved risks identified in the Section 5 risk assessment
- Technical documentation justifying the assigned age category, including references to applicable standards and tests
Age warnings and symbols must be included on the product, packaging, or user instructions, and translated into the official language(s) of each country where the product is marketed. See our article on labelling requirements for GPSR compliance for more detail.
Frequently Asked Questions
Is age grading legally required in the EU?
Yes. Under Article 9 of Regulation (EU) 2023/988, age grading is part of the required product risk assessment and must be included in the technical documentation. For toys, age suitability is also regulated under Directive 2009/48/EC.
What happens if I assign the wrong age grade?
Misclassification can lead to enforcement action, product recalls, or fines. If a product appears suitable for younger users, market surveillance authorities may reclassify it and require full toy safety testing.
Can I label everything as 14+ to avoid toy rules?
No. Authorities assess the product’s appearance, marketing, and likely use. Labeling alone does not exempt a product from toy safety obligations if it looks and functions like a toy.
What supporting documents are needed for age grading?
Risk assessment reports, EN 71 test results (if applicable), design justifications, chemical safety data sheets, and labeling mockups are commonly required. These should be part of the GPSR technical file.
Do I need to translate age warnings?
Yes. Article 22 of the GPSR requires that all safety information, including age warnings, must be in the official language(s) of the country where the product is sold.