Do I need safety warnings on kids’ clothes with detachable parts?

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Jason

Yes, you need safety warnings on children’s clothes with detachable parts when those components pose choking hazards. The General Product Safety Regulation (EU) 2023/988 (GPSR) requires specific warning labels for kids’ clothing with small removable elements that could present safety risks to young children.

What counts as detachable parts on children’s clothing?

Detachable parts include any component that can be removed or separated from the garment through normal use or reasonably foreseeable misuse. Common examples include:

  • Functional elements: Buttons, snaps, toggles, clips, and zippers
  • Decorative components: Bows, appliqués, beads, sequins, and fabric flowers
  • Removable accessories: Hoods, belts, ties, and detachable pockets
  • Embellishments: Rhinestones, patches, and decorative pins

The key consideration is whether these parts can become separated and present a choking hazard. Components that can fit through a small parts cylinder (approximately 3.17cm diameter and 5.7cm deep) typically require safety warnings for children under 36 months.

Age-specific thresholds matter significantly. Parts that might be safe for older children can pose serious risks for toddlers who explore through mouthing. The GPSR considers both the intended age group and whether younger siblings might reasonably access the clothing.

When do safety warnings become legally required for kids’ clothes?

Safety warnings become mandatory under the GPSR when detachable parts present choking hazards for the intended age group or when younger children might reasonably encounter the product. This applies to all children’s clothing placed on the EU market from 13 December 2024.

Age Group Risk Level Warning Required
Under 36 months High (small parts hazard) Always mandatory
3-8 years Medium (depends on part size) Risk assessment required
8-14 years Lower (consider younger siblings) If accessible to younger children

The regulation requires manufacturers to conduct risk assessments considering foreseeable use and misuse. If your risk assessment identifies potential choking hazards from detachable components, warning labels become legally required.

The GPSR applies to all products whether new, used, or reconditioned, covering both physical retail and online marketplace sales.

What should safety warnings on children’s clothing actually say?

Safety warnings must clearly communicate the specific risk and target age group using precise language. Here are the key requirements:

Essential Warning Elements

  • Risk identification: “Small parts” or “Choking hazard”
  • Age specification: “Not suitable for children under 36 months”
  • Action required: “Remove all detachable parts before use”
  • Alert word: “Warning” or “Caution”

Sample Warning Texts

  • “Warning: Small parts. Choking hazard. Not suitable for children under 36 months”
  • “Caution: Remove all detachable parts before giving to children under 3 years”
  • “Warning: Contains small parts that may detach. Adult supervision required for children under 3”

Placement and Format Requirements

Requirement Specification
Attachment Permanently fixed to garment or packaging
Visibility Clearly visible before purchase
Language Official language of each EU member state
Legibility Appropriate font size for readability
Online sales Must appear in product descriptions

For online sales, safety information must appear prominently in product descriptions and digital listings to ensure consumers receive warnings before completing their purchase.

Understanding these safety warning requirements helps protect children while ensuring your products comply with EU regulations. The GPSR emphasizes proactive risk assessment and clear consumer communication. At EARP, we help manufacturers navigate these compliance requirements, ensuring your children’s clothing meets all necessary safety standards for successful EU market access.

If you are looking for support or to learn more, contact our team of experts today

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