PU slow-resilience simulated food toys such as cakes, bread, fruits, and hamburgers are popular on cross-border platforms due to their realistic shapes, vibrant colors, and soft textures.

However, such products typically feature simulated food shapes, scents, surface coatings, and foaming materials, which, in the context of children's use, may pose risks due to biting, crumbling, small parts, and material formulations.

The compliance focus of PU models is to determine the applicable requirements based on the actual structure of the product, and to ensure that the foaming materials, essence, colorants, and mass production processes are consistent with the test samples.

1.What requirements should be paid attention to for PU simulated food models?

1.Applicable requirements for children's toys in the United States

If the product is a children's toy, it should be evaluated based on its actual structure, adhering to the mechanical and physical requirements of ASTM F963-23, reasonable use and abuse testing, small parts, sharp points and edges, lead, phthalates, coatings and contactable materials, tracking labels, and other applicable requirements. The PU material itself does not automatically form a completely independent universal testing scheme, and specific items still need to be determined based on the actual product, age, and material.

2.Additional chemical items are determined based on risk

For items such as formamide, VOCs, odor, or other foam materials, additional assessments can be conducted based on PU formulations, foaming agents, essences, product odor, target markets, customer requirements, platform notifications, and corporate risk control standards. Additional items should have clear bases and purposes, and a fixed set of items cannot be used to cover all PU toys.

3.Establish standard matrices for different sales markets

The regulatory systems of the US market, EU market, and other markets differ. The US market should comply with ASTM F963-23, CPSIA, and applicable CPSC rules; the EU market requires compliance with EN 71, REACH, and other applicable regulations. Reports from different markets cannot be directly substituted for each other.

II.Main risks of PU simulated food products

1.Highly realistic design increases the likelihood of biting

Products such as bread, cakes, and fruits closely resemble real food in appearance and aroma, potentially increasing the likelihood of children putting them in their mouths, biting, or misusing them. Therefore, sellers need to assess age classification, packaging warnings, and reasonably foreseeable usage risks in conjunction with the actual products.

2.Chipping occurs after repeated squeezing

Low-density PU foam, insufficient surface coating adhesion, or unstable foaming process may lead to the production of debris after squeezing, pulling, and gnawing. The detached debris may pose small parts or other mechanical risks.

3.Essence and formula changes

Due to different order batches, the same styling product may undergo changes in PU raw materials, foaming agents, essences, colorants, surface coatings, product density, or production factories. If the mass-produced product does not match the sample submitted for inspection, the original report may no longer support CPC and platform verification.

III.Common pitfalls for sellers

1.Use a PU material report to cover all designs

Products with different sizes, densities, surface coatings, and fragrances may pose varying risks. Individual ingredient reports cannot replace the mechanical and chemical evaluations of complete finished products.

2.The US site directly uses the EU report

The EN 71 report cannot automatically replace the requirements of laboratories recognized by ASTM F963, CPSIA, CPC, and CPSC in the United States. Different markets should separately confirm the applicable regulations and certification processes.

3.There are differences between the submitted samples and the mass-produced products

Common scenarios include: the submitted product lacks fragrance, adding essence to mass-produced products; replacing the foaming agent; adjusting the density of PU; changing the pigment; adding a coating to the surface; and switching to a different production factory.

4.Only add "Not Edible" and "14+" labels

Warning labels can serve as a risk communication measure, but they cannot replace product attribute judgment, testing, and certification. If the product design, packaging, and marketing are clearly targeted at children, relevant materials should still be prepared in accordance with the requirements for children's toys.

IV.Rectification Plan for PU Model

1.Establish formula and process archives

Each ASIN should be recorded:

• PU formula;

• Foaming agent;

• Essence;

• Colorant;

• Coating;

• Product density;

• Production factory;

• Batch;

• Supplier.

2.Evaluate the complete finished product

When submitting for testing, not only should materials be provided, but also actual finished products, packaging, instructions, and age ratings, so that the laboratory can confirm the applicable mechanical, physical, and chemical items.

3.Strengthen quality control of chipping and durability

During mass production, repeated extrusion inspection, pulling inspection, surface coating adhesion inspection, debris inspection, batch sampling, as well as odor and appearance consistency inspection can be added.

4.Conduct timely evaluation after material changes

After changes in essence, foaming agent, colorant, coating, density, supplier, or factory, an assessment should be made to determine whether the affected items require retesting.

5.Ensure that the page is consistent with the product positioning

The product packaging, listing, age labeling, and marketing target should be consistent. ASINs identified by Amazon as children's toys should be processed according to the TIC verification process.

Conclusion

The core of compliance for PU simulation food toys is the complete product risk assessment and consistency of mass production formulas.

Sellers should not only consider whether a product has a PU material report, but also pay attention to changes in chipping, small parts, fragrance, coating, and foaming formula after repeated extrusion.

If you have any questions regarding the applicable standards, additional chemical items, CPC, formula changes, or platform verification requirements for PU products, please feel free to leave a message in the comment section. CanMark Testing can provide targeted assessments based on the actual product and target market.