TR CU 007/2011 is a technical regulation for the safety of products intended for children and adolescents. The correct assessment route depends on the product category, the age group, its materials, its design and its intended use. Contact with the skin can also change the evidence required and the form of assessment.
Start by identifying those inputs before requesting a certificate, declaration or state registration certificate. TR CU 007/2011 should not be applied to every product associated with children. Toys have a separate regulation and should not be presented as covered solely by TR CU 007/2011.
What TR CU 007/2011 covers
TR CU 007/2011 concerns products intended for children and adolescents, but the product category must be identified before its requirements can be assessed. A general description such as “children’s product” is not enough to select an assessment form.
The product category determines which parts of TR CU 007/2011 are relevant. The age group determines how the product is considered. The material composition provides evidence about what the product contains. The design and intended use explain how the product is expected to be used.
- The product category is the starting point for classification.
- The age group can change the evidence and assessment form.
- The materials can change the evidence and assessment form.
- Contact with the skin can change the evidence and assessment form.
- The intended use distinguishes products that may otherwise appear similar.
Why the product description matters
A product description is useful only when it identifies the object clearly. The assessment cannot rely on the product name alone because similar names may describe different designs, materials or uses.
The applicant should prepare the product’s age group, composition, design and intended use. These inputs connect the product with the relevant category and help determine what evidence is needed.
Age group
The age group is an assessment input, not a marketing detail. A change in the intended age group can change the evidence and assessment form under TR CU 007/2011.
State the intended age group in the product information used for the assessment. Do not assume that one assessment route applies to all products for children and adolescents.
Composition and materials
The composition identifies the materials used in the product. Materials can affect the evidence needed for the assessment under TR CU 007/2011.
Provide the composition in a form that allows the product to be distinguished from another product with a similar appearance. An incomplete material description can prevent a reliable assessment route from being selected.
Design and intended use
The design shows what the product is and how it is made. The intended use shows how the product is expected to be used by the relevant age group.
These details matter when products have similar materials but different functions. Describe the product itself rather than relying on a broad label such as “children’s goods”.
Contact with skin
Contact with the skin is a separate practical input. Skin contact can change the evidence and assessment form under TR CU 007/2011.
Record whether the product is intended to contact the skin and identify the parts that do so. This information should be considered together with the age group, composition, design and intended use.
How to choose the assessment route
The assessment route should be selected after the product has been described. Do not select a certificate, declaration or state registration certificate solely because the product is intended for children.
- Identify the exact product category.
- Record the intended age group.
- Describe the composition and materials.
- Describe the design and intended use.
- Record whether the product contacts the skin.
- Check the relevant product list.
- Check the specific labelling rules.
- Confirm the evidence and assessment form for that product.
The relevant product list supports the category decision. The specific labelling rules support the information that must accompany the product. Both checks should be made for the identified product rather than for a broad product family.
Certificate, declaration or state registration certificate
TR CU 007/2011 does not allow a reliable document type to be assigned from the product name alone. The evidence and assessment form depend on the product inputs.
A product may require a certificate, a declaration or a state registration certificate, but the correct form must be confirmed for the specific product. The available facts do not support assigning one document to every product in this subject area.
Use the age group, category, composition, design, intended use and skin contact information to establish the applicable route. If one of these inputs is missing, the document choice remains unconfirmed.
How toys are treated
Toys have a separate regulation. A toy must not be presented as covered solely by TR CU 007/2011 because it is intended for children or adolescents.
First decide whether the product is a toy or another product category. Then identify the regulation relevant to that category and check its product list and labelling rules. The same age group does not make two different product categories subject to the same regulation.
Product lists and labelling rules
The relevant product list helps confirm whether the product falls within the intended scope of the assessment. The specific labelling rules establish what product information must be checked for that category.
Do not treat a general reference to children’s products as a substitute for these checks. The product category must be matched with the relevant list, and the resulting category must be matched with its labelling rules.
Labelling should be reviewed for the identified product. This review should use the product’s age group, composition, design and intended use because those details define the object being assessed.
Evidence to collect before assessment
The first evidence package should identify the product and its intended use. It should not begin with an assumed document type.
- Product category.
- Intended age group.
- Composition and materials.
- Design description.
- Intended use.
- Information about contact with the skin.
- Product-list classification.
- Applicable labelling rules.
This information allows the assessment to follow the product rather than a generic keyword. It also makes it possible to identify when the product belongs under a separate regulation, such as the regulation for toys.
Frequently asked questions
Does TR CU 007/2011 cover every product for children?
No. The product category must be identified first. Toys have a separate regulation, so a toy should not be presented as covered solely by TR CU 007/2011.
Can the age group change the assessment?
Yes. The age group can change the evidence and assessment form. Record the intended age group before selecting the assessment route.
Does skin contact affect the assessment?
Yes. Contact with the skin can change the evidence and assessment form. Identify whether contact is intended and which product parts contact the skin.
Can a certificate, declaration or state registration certificate be assigned from the product name?
No. The correct form cannot be assigned reliably from the product name alone. Confirm the product category, age group, composition, design, intended use, skin contact, relevant product list and specific labelling rules first.
TR CU 007/2011 should therefore be assessed through the product’s exact category and use, not through the keyword alone.
Distinguish the three assessment routes in Article 12
Article 12 provides for certification, declaration or state registration followed by a declaration, depending on the product group. Certain first-layer underwear and knitted hosiery for children under three are examples of the state-registration-plus-declaration route. Compare the exact product and age group against the current wording before selecting evidence.
Compare the certificate and declaration routes and check what evidence applies to your product.