Stationery, art materials and school supplies

• Directive 2009/48/EC — Toy Safety for products intended for children under 14
• Regulation (EU) 2023/988 — GPSR
• Regulation (EC) No 1272/2008 — CLP
• Regulation (EC) No 1907/2006 — REACH

Who has to appoint one

Manufacturers and sellers outside the Union placing writing, drawing and craft materials on the EU market. Classification depends on the intended user: finger paints, modelling clay and children's craft kits are toys, while professional art materials are consumer products with chemical duties.

Thresholds and exemptions

None. What changes is the regime: a product designed for play by children under 14 is a toy with CE marking and EN 71, while the same chemical sold to artists is a mixture under CLP.

What must appear on the label

For toys: CE marking, manufacturer and EU operator details, age marking and the Annex V warnings. For chemical products: CLP pictograms, signal word, hazard and precautionary statements, the supplier's EU details and, for classified mixtures, the UFI code. Products imitating food are prohibited outright under the food-imitating products rules.

Marketplace fields

Marketplaces suppress art and craft listings missing the responsible person block, and remove scented or food-shaped erasers and markers, which fall under the food-imitating products prohibition.

Documentation you must hold

For toys: safety assessment, technical documentation, EN 71 test reports and the declaration of conformity. For chemicals: CLP classification file, safety data sheet, poison centre notification with UFI, and REACH compliance evidence.

Standards and testing

EN 71-3 migration of elements for toys, EN 71-7 for finger paints, EN 71-9 to 11 for organic chemical compounds, and the CLP classification testing or calculation for mixtures. Solvent-based markers and glues face additional scrutiny on volatile organic compounds.

Language requirements

Warnings, hazard statements and instructions in the language of each member state of sale.

When it applies

Before placing on the market, with poison centre notification preceding the first sale of any classified mixture in each country.

How long records are kept

Ten years for the technical documentation and the classification file.

What happens if you do not comply

Withdrawal, Safety Gate alerts and fines. Scented and food-shaped stationery is removed under the food-imitating products rules because of choking and ingestion risk, and this is enforced without warning.

Who enforces it

National market surveillance and chemicals authorities, and customs at import.

Where the boundary lies

The food-imitating products prohibition is the trap here: erasers shaped like fruit, glitter glue in food-style tubes and scented markers resembling drinks are prohibited regardless of the rest of the compliance file. And a craft kit sold for children is a toy even where its components are ordinary stationery.

Questions we are asked

Are colouring pencils toys?

If they are designed or intended for play by children under 14, yes, which brings CE marking and EN 71-3 testing. Professional pencils sold to artists are not.

Why were our scented erasers removed?

Products that resemble food and can be confused with it are prohibited under the food-imitating products rules, a prohibition that predates GPSR and remains in force.