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# India Toy Safety: BIS IS 9873 and Toys QCO 2020

India's Toys Quality Control Order 2020 made BIS CRS certification mandatory for all toys sold in India — a sweeping change that affected thousands of importers. IS 9873 has multiple parts covering mechanical safety, flammability, and chemical migration. Most toys require testing to at least three parts, and the requirements for toys intended for children under 3 are particularly strict.

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At a glance

IS 9873 parts

8

Age group categories

4

Application steps

5

## IS 9873 structure — applicable parts

IS 9873 Part 1Safety aspects related to mechanical and physical properties — sharp edges, small parts, small ball test, integrity of toys

IS 9873 Part 2Flammability — ignition and burn rate requirements for different toy materials and categories

IS 9873 Part 3Migration of certain elements (chemical safety) — limits for lead, cadmium, antimony, arsenic, barium, chromium, mercury, selenium

IS 9873 Part 4Experimental sets for chemistry and related activities — chemical kits and science experiment toys

IS 9873 Part 5Chemical toys (sets) other than experimental sets

IS 9873 Part 7Finger paints — migration and chemical safety requirements for paints used by young children

IS 9873 Part 9Organic chemical compounds — phthalates, formaldehyde, and other restricted organic chemicals

IS 9873 Part 13Olfactory board games, cosmetic kits, and gustatory games

## Age group requirements

### 0–3 years (infants and toddlers)

**Requirements:** Strictest standards — no small parts detachable under force (small ball test), no sharp edges or points, rope lengths limited, no balloons, no foam beads below minimum size

**Labeling:** Mandatory warning: 'Not suitable for children under 3 years' NOT required — product must actually be safe for use by children under 3

### 3–6 years

**Requirements:** Reduced small parts threshold but still strict. Toy must withstand drop test and use test for this age group. Functional toys must include safety instructions.

**Labeling:** Age suitability must be clearly marked. Warning labels for any hazards.

### 6–14 years

**Requirements:** Focus on structural integrity, electrical safety (for electronic toys), and chemical safety. Toys must include clear assembly instructions.

**Labeling:** Age range marking required. Specific warning labels for hazards.

### 14+ years / hobby and craft sets

**Requirements:** Adult supervision may be specified. Focus on chemical safety for chemistry sets and art materials. Manufacturer must determine and mark intended age range.

**Labeling:** Age appropriateness must be clearly marked to avoid under-3 restrictions being misapplied.

## CRS application process for toys

01

### Determine applicable IS 9873 parts for your toy category

A single toy may require testing to multiple parts of IS 9873. For example, a soft toy with painted features needs Part 1 (mechanical), Part 2 (flammability), and Part 3 (chemical migration). Identify all applicable parts before initiating testing.

02

### Get product tested at BIS-recognized laboratory

Toys must be tested by a BIS-recognized laboratory specifically recognized for IS 9873. For imported toys, labs outside India may be accepted if ILAC-accredited and BIS-recognized for the specific IS standard parts.

03

### Complete age group determination and labeling design

Determine the minimum age group the toy is safe for. Design all required warning labels, age markings, and safety instructions per IS 9873 requirements before submitting for BIS CRS.

04

### Submit CRS application with complete documentation

Submit on BIS portal with test reports for all applicable IS 9873 parts, product descriptions, factory details, and label artwork. Foreign manufacturers must submit through their AIR.

05

### Maintain compliance and renew within 2-year window

CRS is valid for 2 years. If the toy design changes (materials, coatings, components) in a way that affects compliance parameters, a new or amended CRS application is required before selling the updated product.

## Frequently asked questions

### Does the Toys Quality Control Order 2020 apply to all toys sold in India?

Yes. The Toys (Quality Control) Order 2020 made BIS CRS registration mandatory for all toys sold in India — both domestically manufactured and imported. There are no category exemptions for toy types. The order was a landmark regulation that transformed India's toy market from largely unregulated to compulsory certification. Products marketed as 'children's products' or 'educational toys' are also covered.

### Are stuffed animals and plush toys covered under IS 9873?

Yes. Soft stuffed toys must comply with IS 9873 Part 1 (mechanical and physical properties) and Part 2 (flammability). If the plush toy has painted elements, buttons, or eyes, Part 3 (chemical migration of heavy metals from surface coatings and plastic components) also applies. The fill material must also meet flammability requirements. Many imported plush toys fail IS 9873 Part 1 due to detachable small parts (eyes, noses) that fail the small ball test for toys marketed for children under 3.

### What is the small ball test and why does it matter?

The small ball test is a key IS 9873 Part 1 test for toys intended for children under 3. Any component that detaches from the toy under standardized force, and fits entirely into a test cylinder (45mm diameter, 57mm deep), is classified as a 'small part' that creates a choking hazard. Toys intended for under-3 use must have no components that generate small parts. This test is one of the most common failure points for imported toys seeking CRS registration.

### Can I import toys to India without BIS CRS if they have CE or ASTM certification?

No. CE marking (EU) or ASTM F963 (USA) certification does not substitute for BIS CRS under India's Toys QCO 2020. India requires testing per IS 9873, which aligns with EN 71 (European standard for toys) in many respects, but is not identical. Some BIS-recognized labs can test to both EN 71 and IS 9873 simultaneously, reducing the cost of parallel certification. A complete BIS CRS application is mandatory regardless of other certifications held.

**Disclaimer:** This guide reflects IS 9873 requirements under the Toys QCO 2020. Standards are periodically revised. Always verify the current IS 9873 version and QCO requirements before commencing testing.

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