Compliance Checklist

CE Marking
Toys
Italy 🇮🇹

Complete CE marking compliance checklist for toys on the Italian market. Italian market requirements, CONAI packaging obligations, Italian language requirements and Amazon.it mandatory fields.

Overview

CE marking for toys is mandatory throughout the EU per the Toy Safety Directive 2009/48/EC. In Italy, the Ministry of Enterprises and Made in Italy (MIMIT) together with the Camere di Commercio and the Guardia di Finanza monitor compliance. Additional national requirements apply for the Italian market: all safety warnings and instructions must be in Italian (Codice del Consumo, D.Lgs. 206/2005). Additionally, first importers must register with CONAI (Consorzio Nazionale Imballaggi) for toy packaging and label packaging with material codes and disposal instructions per D.Lgs. 116/2020. The GPSR (Regulation (EU) 2023/988) has supplemented existing requirements since December 2024 with additional obligations such as the EU Responsible Person and enhanced traceability.

Does this apply to my product?

This checklist applies to all economic operators placing toys on Amazon.it. This includes: dolls (bambole), board games (giochi da tavolo), outdoor toys (giocattoli da esterno), craft kits (kit creativi), building blocks (mattoncini), remote-controlled vehicles (veicoli telecomandati), and all products for children under 14. The Toy Safety Directive applies to all products designed exclusively or not exclusively for use in play by children under 14. In Italy, all accompanying documents must be in Italian.

Step-by-Step Guide

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Determine Applicable Directives and Harmonized Standards

Determine all applicable EU directives for your toy product. The Toy Safety Directive 2009/48/EC is the main directive, but depending on the product type, additional directives may apply (EMC for electronic toys, RED for radio-enabled toys).

Estimated time: 1-3 Tage

Identify Toy Safety Directive 2009/48/EC as main directiveRequired

Confirm your product falls under the Toy Safety Directive. Also check whether additional directives apply: EMC Directive 2014/30/EU (for electronic toys), RED 2014/53/EU (for WiFi/Bluetooth toys), RoHS 2011/65/EU (for electrical toys), Battery Directive (for battery-operated toys). Document the results.

Directive matrix with all applicable EU directives

Identify harmonized standards of the EN 71 seriesRequired

Determine the relevant harmonized standards: EN 71-1 (mechanical/physical properties), EN 71-2 (flammability), EN 71-3 (migration of certain elements), EN 71-8 (activity toys for domestic use), EN 71-9 (organic compounds), EN 71-12 (N-Nitrosamines), EN 71-13 (olfactory games, cosmetic kits). For electronic toys additionally EN 62115.

Conduct Conformity Assessment and Testing

Have your toy tested by an accredited testing institute per the EN 71 standard series. For the Toy Safety Directive, internal production control (Module A) is sufficient when harmonized standards are fully applied.

Estimated time: 3-6 Wochen

Have EN 71 tests conductedRequired

Have your toy tested by an accredited laboratory: EN 71-1 (mechanical/physical safety - choking hazards, small parts, sharp edges), EN 71-2 (flammability), EN 71-3 (migration of 19 elements). In Italy, ACCREDIA is recognized as the national accreditation body. Alternatively, ISO 17025 accredited laboratories are internationally accepted.

Test reports EN 71-1, EN 71-2, EN 71-3 (accredited laboratory)

Compile risk analysis and technical documentationRequired

Prepare a comprehensive risk analysis covering all foreseeable hazards for children. Technical documentation must include: general product description, design drawings, risk analysis, test reports, applied standards, manufacturing process description. Documentation must be retained for at least 10 years.

Complete technical documentation (Fascicolo tecnico)

Prepare EU Declaration of Conformity (Dichiarazione di conformita UE)Required

Prepare an EU Declaration of Conformity referencing the Toy Safety Directive 2009/48/EC and any additional directives. The DoC must include manufacturer, product identification, applied standards, and signature. For the Italian market, the DoC should also be available in Italian (Dichiarazione di conformita UE).

EU Declaration of Conformity (signed, ideally bilingual EN/IT)

Apply CE Marking and Italian Product Labeling

Apply the CE marking and ensure complete product labeling for the Italian market. All safety warnings and age recommendations must be in Italian.

Estimated time: 1-3 Wochen

Apply CE marking and age recommendationsRequired

The CE marking must be at least 5mm high, visible, and permanently affixed to the toy or packaging. Age recommendations must appear in Italian: 'Non adatto a bambini di eta inferiore a 3 anni' (Not suitable for children under 3 years). The warning symbol per EN 71-1 is also required. For electronic toys, the WEEE symbol (crossed-out wheelie bin) must additionally be applied.

Final packaging layout with CE marking and Italian age recommendations

Safety warnings and instructions in ItalianRequired

All safety warnings must be in Italian: 'ATTENZIONE - Rischio di soffocamento - Contiene piccole parti' (choking risk), 'ATTENZIONE - Non utilizzare vicino al fuoco' (flammability), 'AVVERTENZA - Utilizzare sotto la sorveglianza di un adulto' (adult supervision). Instructions for use (istruzioni per l'uso) must also be fully in Italian.

Safety warnings and instructions in Italian

Traceability information and manufacturer detailsRequired

Each toy must carry unique product identification: batch number (numero di lotto), model designation, and manufacturer name/address. The EU Responsible Person (Responsabile) must also appear with name and address on the packaging.

CONAI Packaging Registration and Environmental Labeling

In Italy, all first importers of packaged products must register with CONAI. Packaging must be labeled with material codes and disposal instructions per D.Lgs. 116/2020.

Estimated time: 1-2 Wochen

Complete CONAI registrationRequired

Register with CONAI (conai.org) as a packaging first importer. Report all packaging materials (cardboard, plastic, wood, etc.) and pay the Contributo Ambientale CONAI (CAC). Contributions vary by packaging material and are adjusted annually.

CONAI registration confirmation

Packaging labeling per D.Lgs. 116/2020Required

Label the toy packaging with required information: material codes per Decision 97/129/EC (e.g., PAP 21 for corrugated cardboard, LDPE 4 for films), disposal instructions in Italian ('Raccolta differenziata - Verificare le disposizioni del proprio comune'), and the Triman symbol if applicable (if also shipping to France).

Packaging layout with material codes and Italian disposal instructions

Amazon.it Compliance Fields and Market Surveillance

Complete Amazon mandatory fields for Amazon.it and establish market surveillance for the Italian market. MIMIT and the Camere di Commercio conduct regular toy inspections.

Estimated time: 2-5 Tage

Enter GPSR and CE compliance data in Seller Central for Amazon.itRequired

Enter complete data in Amazon Seller Central: EU Responsible Person, manufacturer information, CE declaration of conformity, Italian-language safety warnings. Upload product images showing CE marking and Italian warnings.

Complaint management and reporting channels to Italian authoritiesRequired

Set up a complaint register and define reporting channels to MIMIT and the EU Safety Gate. In Italy, consumers can file complaints via local Camere di Commercio. Regularly monitor Amazon customer reviews and RAPEX/Safety Gate notifications for toy products.

Internal procedure document for product recalls and safety notifications

Common Mistakes to Avoid

Safety warnings only in English or German instead of Italian

Consequence: Violation of the Codice del Consumo (D.Lgs. 206/2005). The Camere di Commercio can impose fines from EUR 1,000 to EUR 100,000. Amazon.it suspends listings with non-Italian safety warnings upon customer complaints.

Prevention: All safety warnings and instructions must be in Italian. Have translations prepared by a qualified translator.

CONAI registration and packaging labeling missed

Consequence: Fines up to EUR 40,000 per D.Lgs. 152/2006. The Guardia di Finanza increasingly inspects CONAI obligations. Missing disposal instructions on packaging lead to additional sanctions.

Prevention: Register with CONAI BEFORE first market placement. Apply material codes and disposal instructions on all packaging. SpaceGoats handles CONAI registration.

CE marking applied without complete EN 71 testing

Consequence: Misuse of the CE marking is a punishable offense. MIMIT can impose sales bans, product recalls, and fines. Injuries to children can result in criminal consequences and compensation claims.

Prevention: ALWAYS conduct complete EN 71 testing before applying CE marking. Use only accredited laboratories (ACCREDIA or ISO 17025).

Only Toy Safety Directive considered, GPSR requirements ignored

Consequence: Listing suspension on Amazon.it due to missing GPSR mandatory fields (EU Responsible Person, contact details). Additional sanctions from market surveillance authorities for missing traceability and market surveillance.

Prevention: Observe GPSR IN ADDITION to the Toy Safety Directive. Designate an EU Responsible Person, complete all Amazon GPSR fields, and establish traceability processes.

Missing batch number or traceability on Italian toy products

Consequence: In case of recall, all units must be recalled instead of just the affected batch. Significant additional costs and reputational damage. MIMIT and the Guardia di Finanza systematically check traceability during inspections.

Prevention: Implement a batch tracking system from the first production run. Each packaging unit must carry a unique identifier (numero di lotto).

Frequently Asked Questions

Q1Do I need to register with CONAI if I sell toys to Italy via Amazon FBA?

Yes. Every economic operator placing packaged products on the Italian market for the first time must register with CONAI and pay the Contributo Ambientale CONAI. This also applies to Amazon FBA sellers. Packaging must also be labeled with material codes and disposal instructions per D.Lgs. 116/2020.

Q2Which authority is responsible for toy safety in Italy?

In Italy, MIMIT (Ministry of Enterprises and Made in Italy) is the central authority for product safety. The Camere di Commercio conduct local market inspections, and the Guardia di Finanza monitors import and export operations. Serious safety defects are reported via the EU Safety Gate.

Q3Do I need separate EN 71 test reports for the Italian market?

No. EN 71 test reports are valid throughout Europe and do not need to be country-specific. If you already have valid EN 71 test reports for the German market, these also apply in Italy. Ensure test reports are current and the laboratory is ISO 17025 or ACCREDIA accredited.

Q4How much does CE marking cost for a simple toy product on Amazon.it?

For a simple, non-electronic toy, expect EUR 800-3,000: EN 71 test reports (EUR 300-2,000), technical documentation (EUR 200-800), CONAI registration (EUR 50-300/year), Italian translation and packaging adaptation (EUR 150-500). For electronic toys, costs can be significantly higher due to additional testing (EN 62115, EMC, RoHS).

Q5How does CE compliance for toys on Amazon.it differ from Amazon.de?

CE requirements (Toy Safety Directive, EN 71 testing) are identical across the EU. However, Italy has additional national requirements: CONAI registration and packaging labeling per D.Lgs. 116/2020, Italian-language safety warnings and instructions per the Codice del Consumo, and specific authority responsibilities (MIMIT, Camere di Commercio, Guardia di Finanza). Authority communication is in Italian.

CE MarkingToysItaly 🇮🇹