CEN/TR 16411:2012

SLOVENSKI STANDARD
01-december-2012
Izdelki za otroke - Leta 2012 zbrane interpretacije in razlaga standardov CEN/TC
Child use and care articles - 2012 compiled interpretations of CEN/TC 252 standards
Artikel für Säuglinge und Kleinkinder - Gesammelte Interpretationen der CEN/TC 252-
Normen 2012
Articles de puériculture - Compilation des interprétations des normes du CEN/TC 252 en
Ta slovenski standard je istoveten z: CEN/TR 16411:2012
ICS:
97.190 Otroška oprema Equipment for children
2003-01.Slovenski inštitut za standardizacijo. Razmnoževanje celote ali delov tega standarda ni dovoljeno.

TECHNICAL REPORT
CEN/TR 16411
RAPPORT TECHNIQUE
TECHNISCHER BERICHT
September 2012
ICS 97.190
English Version
Child use and care articles - 2012 compiled interpretations of
CEN/TC 252 standards
Articles de puériculture - Compilation des interprétations Artikel für Säuglinge und Kleinkinder - Gesammelte
des normes du CEN/TC 252 en 2012 Interpretationen der CEN/TC 252-Normen 2012

This Technical Report was approved by CEN on 6 August 2012. It has been drawn up by the Technical Committee CEN/TC 252.

CEN members are the national standards bodies of Austria, Belgium, Bulgaria, Croatia, Cyprus, Czech Republic, Denmark, Estonia,
Finland, Former Yugoslav Republic of Macedonia, France, Germany, Greece, Hungary, Iceland, Ireland, Italy, Latvia, Lithuania,
Luxembourg, Malta, Netherlands, Norway, Poland, Portugal, Romania, Slovakia, Slovenia, Spain, Sweden, Switzerland, Turkey and United
Kingdom.
EUROPEAN COMMITTEE FOR STANDARDIZATION
COMITÉ EUROPÉEN DE NORMALISATION

EUROPÄISCHES KOMITEE FÜR NORMUNG

Management Centre: Avenue Marnix 17, B-1000 Brussels
© 2012 CEN All rights of exploitation in any form and by any means reserved Ref. No. CEN/TR 16411:2012: E
worldwide for CEN national Members.

Contents Page
Foreword .3
Introduction .3
1 Scope .5
2 00252009 – EN 1888:2003, Child care articles - Wheeled child conveyances - Safety
requirements and test methods .6
3 00252039 – EN 1888:2003/A1:2005, Child care articles - Wheeled child conveyances -
Safety requirements and test methods . 10
4 00252040 – EN 1888:2003/A2:2005, Child care articles - Wheeled child conveyances -
Safety requirements and test methods . 10
5 00252041 – EN 1888:2003/A3:2005, Child care articles - Wheeled child conveyances -
Safety requirements and test methods . 11
6 00252046 - EN 12586:2007, Child use and care articles – Soother holder – Safety
requirements and methods . 12
7 00252048 - EN 12790:2009, Child use and care articles - Reclined cradles . 20
8 00252049 - EN 12221-1:2008, Child use and care articles - Changing units for domestic
use – Part 1: Safety requirements . 21
9 00252050 - EN 12221-2:2008, Child use and care articles - Changing units for domestic
use - Part 2: Test methods . 23
10 00252054 - EN 1466:2004+A1:2007, Child use and care articles - Carry cots and stands —
Safety requirements and test methods . 24
11 EN 14350-2:2004, Child use and care articles - Drinking equipment - Part 2: chemical
requirements and tests . 27
12 EN 1400-3:2002, Child use and care articles - Soothers for babies and young children -
Part 3: chemical requirements and tests . 27
13 EN 14372:2004, Child use and care articles - Cutlery and feeding utensils - Safety
requirements and tests, and, . 28
Annex A (informative) Interpretation 3 on the 3.9 and 5.1.4.2 of the EN 12586:2007, Child use and
care articles – Soother holder – Safety requirements and method (WI 00252046) . 29
Annex B (informative) Reply to interpretation 3 on the 3.9 and 5.1.4.2 of the EN 12586:2007, Child
use and care articles – Soother holder – Safety requirements and method (WI 00252046) . 32
Annex C (informative) Reply to interpretation 1 on the 5.1.10 of the EN 12586:2007, Child use and
care articles – Soother holder – Safety requirements and method (WI 00252046) . 34
Bibliography . 40

Foreword
This document (CEN/TR 16411:2012) has been prepared by Technical Committee CEN/TC 252 “Child use
and care articles”, the secretariat of which is held by AFNOR.
Introduction
Interpretations and no-action decisions
This Technical Report contains replies to requests for interpretation and clarifications with regard to the
understanding of clauses in the standards elaborated within the CEN/TC 252. The replies concern those
requests which have resulted in an interpretation or the decision that no action is necessary.
An interpretation does not have the same status as the text of the standard, nor can it overrule the text of the
standard. However, following an interpretation should give assurance that the relevant clause of the standard
has been correctly applied. An interpretation shall only be regarded as a clarification of the meaning of the
standard.
Disclaimer
The interpretations and clarifications have been derived by expert groups of CEN/TC 252. The information
contained herein is for guidance only and does not reflect the formal approval by CEN or CEN member
bodies. It should be noted that the interpretations are neither part of any standard nor have been referenced in
the Official Journal of the European Union.
Requests for interpretation
Requests for interpretations may be submitted by a CEN member body through its national committee or by a
CEN/TC 252 liaison (but not directly by an individual or a company) - in accordance with the interpretation
protocols agreed by CEN/TC 252. The requests are then channelled to the relevant CEN/TC 252 working
group which will deal with the request.
A request for an interpretation may lead to:
a) An interpretation of the standard
This should reflect a reasonable interpretation of how the standard should be used, taking into account
 the wording of the standard
 the rationale of the standard
 the history of the standard
b) A no-action decision
This is applicable when it is agreed that the standard appropriately specifies how a child care article shall
be assessed.
c) A proposal for an amendment of the standard
This is applicable when it is agreed that the standard is deficient in some way.
NOTE Interpretation and no-action decisions are published in CEN/TR 16411, which will be updated on a regular
basis.
Proposals for amendments will be progressed as new work item proposals in accordance with CEN rules.
Answers to requests for interpretations
Since requests for interpretations are submitted through a CEN member body, it is assumed that the member
body will keep itself informed about decisions concerning the request and its progress and will itself inform the
originator of the request as appropriate.
1 Scope
The purpose of this CEN Technical Report is to provide replies to requests for interpretations and clarifications
of:
 EN 1888:2003, Child care articles - Wheeled child conveyances - Safety requirements and test methods
 EN 1888:2003/A1:2005, Child care articles - Wheeled child conveyances - Safety requirements and test
methods
 EN 1888:2003/A2:2005, Child care articles - Wheeled child conveyances - Safety requirements and test
methods
 EN 1888:2003/A3:2005, Child care articles - Wheeled child conveyances - Safety requirements and test
methods
 EN 12586:2007, Child use and care articles – Soother holder – Safety requirements and methods
 EN 12790:2009, Child use and care articles - Reclined cradles
 EN 12221-1:2008, Child use and care articles - Changing units for domestic use – Part 1: Safety
requirements
 EN 12221-2:2008, Child use and care articles - Changing units for domestic use - Part 2: Test methods
 EN 1466:2004+A1:2007, Child use and care articles - Carry cots and stands — Safety requirements and
test methods
.
2 00252009 – EN 1888:2003, Child care articles - Wheeled child conveyances - Safety requirements and test methods
Table 1 — Summary table of the request for interpretations classified in the order of the clauses/subclauses of the EN 1888:2003
Clause/Subclause Title Interpretation n°
6.1.5 Attachment of mechanical parts 6
6.1.7 Pram body or seat unit internal lining 4
11 Locking devices for the folding mechanism 2
11.2 Test for locking devices 1
18 Dynamic strength 3
21.1 General (Product information) 5
Table 2 — Interpretations
Clause/ Paragraph/
N° Subclause/ Figure/ Question Reply
Annex Table/Note
After performing some comparative tests in different laboratories
on the same item (a stroller), we found that test method for test
11.2 is not completely defined in EN 1888:2003; as a matter of
fact, different methods applied by different laboratories lead to
completely different results (failure or approval). In particular, the
sentence "Restrain the vehicle without impeding its folding" can
1 11.2
be interpreted in different ways, leading to these extreme testing
situations:
 put the stroller with the front wheels against some stops and
restrain the vehicle to avoid its tipping over, for example by
attaching a cord under the stroller to fix it to the floor. Pull
then the handle with a force of 200N. In case of separate
Clause/ Paragraph/
N° Subclause/ Figure/ Question Reply
Annex Table/Note
handles pull each handle separately with 200N.
This test is supposed to assess the strength of the
locking devices during use. Therefore "without impeding
 put the stroller on the floor without stopping the front wheels
its folding" means that during test, the vehicle is still
and restrain the vehicle to avoid its movement and tipping
able to absorb the force applied.
over by fixing one of the rear wheels to the floor. Pull then the
The requirement of subclause 11.1 ("when tested in
handle with a force of 200N. In case of separate handles pull
accordance with 11.2, any subsequent folding travel
each handle separately with 200N.
shall comply with the requirements of 6.1.1, 6.1.2 and
1 11.2
The two test methods distribute the force on the frame of the
6.1.3. The vehicle shall not fold and the locking
stroller in a very different way and this may lead to different
device(s) shall not be released") shall be checked after
results for the “same” test. It is necessary to amend the current
the force has been applied and the product being
test method in order to clearly define the testing conditions in
erected for use again (all locking devices locked), in
such a way that every laboratory will get the same results when
order to control if any effect such as strain may create
testing the same item with the same method.
entrapment hazards, crushing hazards, and dangerous
edges or corners due to failure of any locking device.
a) NO, it is not the intention of the committee to fail
this kind of product.
b) Development
Locking devices are required to prevent a vehicle
folding whilst a child is in the vehicle, and also
during the process of the child being put in and
taken out of the vehicle. Any locking device(s) for
the folding mechanism shall be positioned so that it
is not possible to operate more than one device in a
single action.
2 11
To avoid the hazards due to inadvertent operation
by the adult or operations by a child, there shall be
at least two locking devices, to be released, one of
them shall require:
1) two separate operations acting on two

separate parts of the vehicle; or
Key
2) two consecutive actions, the first being
1 Push up to unlock with left foot
maintained while the second is carried out.
2 Push down with right foot, to release and enable folding
To avoid the hazards due to incomplete
Clause/ Paragraph/
N° Subclause/ Figure/ Question Reply
Annex Table/Note
Figure 1 — Stroller with a standard folding lock deployment at least one of the locking devices shall
engage automatically.
Illustrated above is a picture of a stroller with a standard folding
lock arrangement of a type that has been supplied for many c) Proposal for interpretation
years, without adverse safety comments.
Release: if (when the product is fully erected and
ready for use) any of the locking devices
considered has to be maintained operated, it shall
not be considered as being released.
The design of the folding mechanism lock complies with the
requirements of the UK standard BS 7409: 1996. A UK test
laboratory has failed folding mechanisms of this type to EN
1888:2003 clause 11 (Locking devices for the folding
In that case check if the system complies with b),
mechanism), in their opinion neither one of the 2 locking devices
considering that the second operation or action
satisfies 11.1a) or b).
may be operated on the second device.

As mentioned strollers with this type locking device have been
⌦⌦⌦⌦ Clause 11 of the consolidated version of EN 1888
supplied in large quantities by many different manufacturers for
shall be amended.
more that a decade without any adverse reports of inadvertent
operation of the locking devices etc.
Is it the intention of the committee that this type of design should
fail EN 1888?
After test in accordance with 18.2, the vehicle shall not be a) The aim of the requirement is to check the strength
damaged such as its safety is impaired. .This is verified following of the attachment devices for the seat unit or pram
order of tests given in clause 4.2. body to the chassis.
The prambody or seat unit shall not be displaced by more than 10 b) Soft carry cots attached to the chassis shall comply
mm on the chassis after testing in accordance with 18.2 in every with this requirement.
direction.
⌦⌦ Risks linked to the use of soft carry cots fitted to a
⌦⌦
Lets consider a carrycot attached to a pushchair by the mean of
3 18 pram body or seat unit shall be addressed by revision of
straps fitted with clips, requirements of clause 14 being met. EN1888.
NOTE Carrycots fitted on a pushchair are considered as seat units
in accordance with the definition given in clause 3.3.
a) What is the rationale of the requirement 18.1 (no
displacement greater than 10 mm) ?
b) Is this requirement applicable to soft carrycots?
Clause/ Paragraph/
N° Subclause/ Figure/ Question Reply
Annex Table/Note
We need clarification on the meaning of tension of internal lining The risk to be covered is the risk of suffocation due to
of the pram body or seat unit. loose fabric parts.
4 6.1.7
Which risk should be covered? The standard is clear enough to cover the risk.
An European standard, the CEI/TR 62017-1:2001
Product information – General : the standard precises:
dealing with product information gives details.
"The warning sentences shall be written in letters at least 10
A typographic ruler (normograph) can be used to
points in height. The word "WARNING" shall be written in upper
directly check that the height of letters is 10 points.
5 21.1
case."
⌦⌦⌦⌦ The wording will be changed in the revision of the
a) What is the measurement to assess this requirement?
standard to be in line with CEN/CENELEC Guidelines
b) Are all letters concerned?
11.
We need precision on the type of parts for which this clause
The proposal is not an interpretation, but changes the
applies and how.
standard.
As the 90 N force corresponds to the force that a child is able to
6 6.1.5
This clause is applicable to the whole product.
apply on parts and in line with relevant risk analysis we decide to
apply this requirement within the access zone, as described within
⌦⌦⌦⌦ Wording will be improved during the revision work.
previous clauses of the standard.

3 00252039 – EN 1888:2003/A1:2005, Child care articles - Wheeled child conveyances - Safety requirements and test
methods
Table 3 — Summary table of the request for interpretations classified in the order of the clauses/subclauses of the EN 1888:2003/A1:2005
Clause/Subclause Title Interpretation n°
15.1.2 Harness anchorage points 1
Table 4 — Interpretations
Clause/ Paragraph/
N° Subclause/ Figure/ Question Reply
Annex Table/Note
The amendment A1 requires in subclause 15.1.2:
"Seat units and pram bodies with an internal length greater than
The 800 mm internal length refers to prambodies.
800 mm (see 6.2.1) shall be fitted with two harness anchorage
The aim of these attachment points is to allow a carer to
points for each position that a child can occupy"
1 15.1.2 use a separate harness.
As a seat unit shall be equipped with a child restraint system
Even a seat unit fitted with a child restraint system shall
conforming to the requirements of the standard and its
be fitted with two anchorage points.
amendment, shall we ask for additional anchoring points ?
What does "for each position that a child can occupy" mean ?
4 00252040 – EN 1888:2003/A2:2005, Child care articles - Wheeled child conveyances - Safety requirements and test
methods
Table 5 — Summary table of the request for interpretations classified in the order of the clauses/subclauses of the EN 1888:2003/A2:2005
Clause/Subclause Title Interpretation n°
4.5.2.8 Test mass F 1
Table 6 — Interpretations
N° Question Reply
Clause/ Paragraph/
Subclause/ Figure/
Annex Table/Note
The amendment A2 requires in subclause 4.5.2.8 a test mass F,
initially designed to be used for tests of combinations pushchair /
group 0+ car seat.
The standard as it is cannot be changed and until the
revision the 15 kg test mass shall be used.
1 4.5.2.8 The use of this test mass has not been described in some clauses
for relevant tests. As the limit of use of such products is 13 kg in
⌦⌦ This shall be addressed during a revision.
⌦⌦
weight, is it possible to use this test mass F where it is relevant?
(i.e. stability, parking device as irregular surface tests …)

5 00252041 – EN 1888:2003/A3:2005, Child care articles - Wheeled child conveyances - Safety requirements and test
methods
Table 7 — Summary table of the request for interpretations classified in the order of the clauses/subclauses of the EN 1888:2003/A3:2005
Clause/Subclause Title Interpretation n°
6.1.8 Attachment of textile parts with child retention purpose 1
Table 8 — Interpretations
Clause/ Paragraph/
N° Subclause/ Figure/ Question Reply
Annex Table/Note
As it is written, the text may be applicable to any existing product,
This requirement is only applicable to seat units
as soon as a textile part is provided, where it gives the impression
convertible into a prambody by adding textile parts and
that a retention purpose is met.
1 6.1.8 which are not equipped with a restraint system
 This wording shall be clarified and improved. adjustable to the child's size from birth and complying
with clause 15.
 It shall be clearly determined, when the test is applicable.

6 00252046 - EN 12586:2007, Child use and care articles – Soother holder – Safety requirements and methods
Table 9 — Summary table of the request for interpretations classified in the order of the clauses/subclauses of the EN 12586:2007
Clause/Subclause Title Interpretation n°
5.1.10 Permanent fasteners 1
3.9 ventilation hole 3
5.1.4.2 Ventilation holes 3
5.1.4.2 Migration of certain elements 4
5.1.4.2 & B.10 Surface dimension and ventilation holes 5
5.1.4.2 Hole for soother older when dealing with toy functions 6
5.1.4.2 25 mm diameter circle for ventilation hole needs? 6
5.1.12.4 & 5.1.4.2 Hole for soother older when dealing with toy functions 7
Table 10 — Interpretations
Clause/ Paragraph/
N° Subclause/ Figure/ Question Reply
Annex Table/Note
This subclause does not specify the checking condition of the
product.
If there is a movable part on the holder that can be placed over a
The final opinion of CEN/TC 252/WG 5 is reported in
1 5.1.10 hole of the fastener, over part of a hole of the fastener in a way to
Annex C of the current document.
reduce the passage, shall the operator check this subclause with
the movable part in all possible positions, in all possible positions
when in use, in the positions given in the instruction for use, in the
most onerous condition ?
Clause/ Paragraph/
N° Subclause/ Figure/ Question Reply
Annex Table/Note
The main purpose of the clarification requested in Annex A is to
seek guidance regarding ventilation holes in soother holder
There were no requirements in EN 12586:2007 which
fasteners, which do not necessarily follow the examples provided
3.9 & would suggest a failure of the examples given in the ASI
in EN 12586:2007. In addition the question is posed whether it is
5.1.4.2 Interpretation request. The final opinion of WG 5 is
possible for a ventilation hole, which entirely meets the dimension
reported in Annex B of the current document.
requirements of EN 12586:2007, to have another function – such
as a facility to attach a strap. (see details in annex B)
TC 252 WG5 follows in all of its standards the principles
of determination of certain elements as given in EN71-
The application of the analytical correction of EN 71-3 is not clear
3.
for the EN 1400-3:2002, EN 12586:2007, EN 14350-2 :2004 & EN
Therefore we agree that the analytical results should be
14372:2004.
4 6.2.1
corrected as explained in EN71-3:1995 (4.1 and 4.2)
Do the analytical results shall be adjusted by subtracting the
even though this maybe
analytical correction in table 2 of EN 71-3 standard?
not stated specifically in some TC 252 WG5
standards.
Clause 5.1.4.2 states that any permanent fastener which
The answer to 1) is No. The first and primary
protrudes past the base of guides 1 and 2 shall be provided with
requirement (5.1.4.2) is for ventilation holes when any
ventilation holes.
permanent or detachable fastener or any permanent or
detachable supplementary component protrudes past
Clause 5.1.4.2 also states that any surface area encompassing a
the base of guides 1 and 2. This is regardless of
25mm diameter circle shall include at least one ventilation hole.
whether there is a surface encompassing a 25 mm
1) Does it mean that if the surface on a fastener, which protrudes
diameter circle.
past the base of guides 1 and 2, does not encompass a 25mm
The rest of the clause describes the requirements for
diameter circle, then no ventilation hole is required on this
5.1.4.2 & these ventilation holes and includes: "Any surface area
fastener?
B.10 encompassing a 25 mm diameter circle shall include at
2) If the reply is “yes”, then how to consider the following extract
least one ventilation hole."
of Annex B.10 :”It is considered that if any fastener or
If the permanent or detachable fastener or permanent
supplementary component is bigger than guides 1 and 2, then the
or detachable supplementary component protrudes past
risk of stuck in mouth and stuck in throat is minimal. Therefore a
the base of guides 1 and 2, and is less than 25 mm
provision for ventilation hole is not required. However, if these
diameter it shall still have a minimum of two 4 mm
objects are smaller than guides 1 and 2, then ventilation holes
ventilation holes or one 12 mm hole as described in
need to be provided. ?
5.1.4.2.
This last sentence seems to indicate that ventilation holes are
If the permanent or detachable fastener or permanent
required provided the fastener protrudes past the base of guides
Clause/ Paragraph/
N° Subclause/ Figure/ Question Reply
Annex Table/Note
1 and 2, and without considering the presence or not of a surface or detachable supplementary component protrudes past
of 25mm diameter. the base of guides 1 and 2, and is more than 25 mm
diameter, then one of the ventilation holes must be
Note that Annex B.10 does not explain the rationale for the
included in any 25 mm diameter circle. This is prevent
surface of 25mm diameter.
manufacturers placing ventilation holes at the very edge
of the fastener for example as shown in Example 1:

Example 1
In example 2, wherever the 25 (dotted) circle is drawn,
at least one of the ventilation holes is included.

Example 2
The 25 mm diameter circle requirement appears in the
original standard (EN 12586:1999) and in every
subsequent revision. Therefore as there was no change
in EN 12586:2007, a rationale was not outlined.
However, the dimension was formulated by considering
every soother holder on the market in the late 1990's.
Question 1:
This requirement is difficult to apply when assessing this kind of
6 5.1.4.2
We were interested to note the comment from AFNOR:
soother holder:
"….was it the intention of WG5 to fail such products?"
Clause/ Paragraph/
N° Subclause/ Figure/ Question Reply
Annex Table/Note
Although EN 12586:2007 makes several references and
indeed requirements for soother holders with toy
functions, we believe soother holders have a very
utilitarian role and therefore do not feel comfortable with
soother holders which are designed also to be used as
a toy.
We also feel that the statement: "there is no safety
issue for such components" is not entirely correct when
we consider the hazard of either permanently attached
components or such components becoming detached,

entering the child's throat.
Question 1 :
Specific to the example provided by AFNOR, we feel
What are the components of a soother holder concerned by this
that such a chain with wooden or plastic parts would be
provision? Is this provision applicable to beads of different shape
quite heavy and would pull out the soother from the
which form the strap of this soother holder?
child's mouth quite easily. Although not a direct danger,
it is opposite from what is intended for a "simple"
soother holder" and perhaps would discourage the carer
from using it.
That being said, Clause 5.1.4.2 (in summary) states
means that every permanent or detachable
supplementary component protruding past the base of
guides 1 and 2 shall be provided with ventilation holes.
A strict interpretation of this clause would mean that
every bead and shape as shown in AFNOR's diagram
would require ventilation holes which we feel is correct.
However, we will reconsider this issue when the soother
holder standard comes up for revision.
Clause/ Paragraph/
N° Subclause/ Figure/ Question Reply
Annex Table/Note
Question 2:
How is the wording “any surface area encompassing a 25 mm
diameter circle”? Question 2 (request of clarification):
How is this provision applicable to the different shaped beads We feel it is a relatively simple task to use a 25 cm
which form the strap of this soother holder? diameter circle to judge which part of the component
6 5.1.4.2 requires a ventilation hole.
Extract of EN12586 – for reference
Although, AFNOR has used the term "……apply a 25
If any permanent or detachable fastener (see 5.1.10 and 5.1.11)
mm diameter disc to any component…." This can of
or any permanent or detachable supplementary component (see
course be an open circle (like a ring).
5.1.12.4 and 5.1.12.5) protrude past the base of guides 1 and 2
(see Figure 15 and Figure 16) when tested in accordance with
6.1.9 it shall be provided with ventilation
We have recently answered an almost exact
European notified bodies have different requirements for
interpretation request from AFNOR. Therefore for
ventilation holes in supplementary components. So we ask for the
conformity, the following answer is the same in all
official and binding regulation for ventilation holes in the body and
significant respects to that issued previously.
head of the figure (or other supplementary components) in
Although EN 12586:2007 makes several references and
following design :
indeed requirements for soother holders with toy
functions, we believe soother holders have a very
utilitarian role and therefore do not feel comfortable with
soother holders which are designed also to be used as
a toy.
5.1.12.4 & We also feel that the statement: "No suffocate on
5.1.4.2 hazard – ventilation holes not required." is not entirely
correct when we consider the hazard of either
permanently attached components or such components

becoming detached, entering the child's throat.
picture 1 – wooden soother holder
Specific to the example provided by DIN, we feel that
5.1.12.4 Supplementary components permanently attached to
such a chain with wooden or plastic parts would be
the strap or to the fasteners (see
quite heavy and would pull out the soother from the
B.12)
child's mouth quite easily.
“…………….All supplementary components permanently attached
Although not a direct danger, it is opposite from what is
to either the strap or to a fastener shall be tested in accordance
intended for a "simple" soother holder" and perhaps
with 6.1.9 in combination with the component to which it is
would discourage the carer from using it.
Clause/ Paragraph/
N° Subclause/ Figure/ Question Reply
Annex Table/Note
attached. That being said, Clause 5.1.4.2 (in summary) states
means that every permanent or detachable
When tested in accordance with 6.1.9 if the combined component
supplementary component protruding past the base of
protrudes past the base of guides 1 and 2, it shall be provided
guides 1 and 2 shall be provided with ventilation holes.
with a ventilation hole or holes (see 5.1.4.2).”
A strict interpretation of this clause would mean
1. point of view:
that every bead and shape as shown in the example
the figure does not protrude past the base of the guides 1 and 2
would require ventilation holes which we feel is correct.
However, we will reconsider this issue when the soother
holder standard comes up for revision.

Picture 2
except in the vertical direction:
the figure passes through the base of the guides 1 and 2
1.
Picture 3
Clause/ Paragraph/
N° Subclause/ Figure/ Question Reply
Annex Table/Note
Picture 4
Our opinion:
The parts (supplementary component) of the figure cannot block
airways.
Conclusion: No suffocation hazard - ventilation holes not required.
2. point of view:
5.1.4.2 Ventilation holes (see 3.9 and B.11)
If any permanent or detachable fastener (see 5.1.10 and 5.1.11)
or any permanent or detachable supplementary component (see
5.1.12.4 and 5.1.12.5) protrude past the base of guides 1 and 2
(see Figure 15 and Figure 16 when tested in accordance with
6.1.9 it shall be provided with ventilation holes as follows: at least
2 ventilation holes, having a combined total area of at least 40
mm2 and each allowing the .thickness of the material or an
area of at least 115 mm2 shall be provided.
Any surface area encompassing a 25 mm diameter circle
shall include at least one ventilation hole.
5.1.4.2, sentence 2, will be considered without checking the
condition of sentence 1 (protruding of the component):
Body and head of the figure have a surface area which includes a
circle with a 25 mm diameter.
Clause/ Paragraph/
N° Subclause/ Figure/ Question Reply
Annex Table/Note
Picture 5
Conclusion of notified bodies : ventilation holes required.
Consequence of this view: any supplementary component with a
surface area > a circle diameter of 25 mm would require
ventilation holes, even if it is so big that it will not fit into a mouth
/protrude the guides.
Please explain application of 5.1.4.2, sentence 2, in this
respect.
Picture 6
The supplementary component do not pass the guide 1 (A) or 2 .
Please confirm our understanding of point 5.1.4.2 that each
supplementary component from which no part will protrude past
the base of guides 1 and 2 must not have ventilation holes.
7 00252048 - EN 12790:2009, Child use and care articles - Reclined cradles
Table 11 — Summary table of the request for interpretations classified in the order of the clauses/subclauses of the EN 12790:2009
Clause/Subclause Title Interpretation n°
5.8.3 Unintentional release of locking mechanism(s) 1
Table 12 — Interpretations
Clause/ Paragraph/
N° Subclause/ Figure/ Question Reply
Annex Table/Note
Concerning is the paragraph 5.8.3 a) measurement. Shall it be
realised with or without test mass?
Indeed, a mass in the product during measurement can have an
even negative positive effect on the mechanisms of locking?
The intention of CEN/TC 252/WG 1 experts was to use
In parallel, the paragraph “5.8.1 - general information” can let
6.6.2 to assess the fulfilment of requirements of 5.8.3 –
believe that the test must be carried out in the 2 configurations
Unintentional release of locking mechanism(s).
(with and without mass in the products).
The first sentence of 5.8.3 shall be read as:
1 5.8.3 a)
The French standardization committee estimates that paragraph
nd
5.8.2 brings an answer to the 2 subparagraph of subclause “To avoid the hazards due to unintentional release,
5.8.1 – General.“Locking mechanism(s) is required to prevent a when tested in accordance with 6.6.2, the reclined
reclined cradle folding whilst the child is in the cradle and also cradle shall not collapse and one of the following
during the process of a child being put in and taken out of the conditions shall be fulfilled:”
cradle”.
In regard with the subclause 5.8.3 a), the commission estimates
that the measurement of the 50 N is to be realized with the mass
in the product.
8 00252049 - EN 12221-1:2008, Child use and care articles - Changing units for domestic use – Part 1: Safety
requirements
Table 13 — Summary table of the request for interpretations classified in the order of the clauses/subclauses of the EN 12221-1:2008
Clause/Subclause Title Interpretation n°
1 7
Changing tables (additional unit attached to the cot)
3.1 Type of "changing unit" covered by standard 2
4.1 Dimensions: Definition of "length" 3
5.11 Confusion in key for figure 3 4
5.4 "Wall mounted" refer to ? 5
Table 14 — Interpretations
Clause/ Paragraph/
N° Subclause/ Figure/ Question Reply
Annex Table/Note
Clause 4.1 provides for the distinction of 2 types of
The 1999 edition covered two types of units which were defined in
changing units also, depending on the age of the child
3.1.1 and 3.1.2. Why was this distinction, depending on the age of
for which the product is intended.
2 3.1
the child, eliminated even though 4.1 in the new edition does refer
⌦⌦ The EN 12221-1:2008 will be amended in order to
⌦⌦
to type 1 and type 2 ?
take back the two definitions.
⌦⌦ The EN 12221-1:2008 will be amended in order to
⌦⌦
add the following text to subclause 4.1:
The previous edition defined the length as "the intended
longitudinal position of the child". The elimination of this definition
“The length of the changing area is the intended as the
leads to disagreements with manufacturers of some changing
3 4.1 dimension measured along the longitudinal position of
units. This also affects the location of the barrier (5.1.1).
the child on the unit.
Was this considered?
The width of the changing area is the measurement
perpendicular to the length.”
Clause/ Paragraph/
N° Subclause/ Figure/ Question Reply
Annex Table/Note
Clause 5.11 Figure 3: "w" is an internal dimension while "l" is an The graphic description is purely indicative (the same
external dimension (the same as in Fig. 10 in the previous was in the previous edition).
4 5.11 Figure 3
edition).
Width and length are measured according to
Is there a reason for this differentiation? subclauses 5.2.1 and 5.2.2 of EN 12221-2:2008.
Regarding the last sentence of clause 5.4,
No, “wall mounted” refers only to “changing units”.
Wall mounted changing units and changing board flaps are
⌦⌦⌦⌦ The EN 12221-1:2008 will be amended in order to
excluded from this requirement
5 5.4 replace the last sentence by:
We understand that "wall mounted" refers to both "changing units"
“Wall mounted changing units and all changing board
and "changing board flaps".
flaps are excluded from this requirement”.
Is this correct?
The reason of this enquiry is to clarify if the changing tables that The changing units that are part for example of some
are placed on travel cots (combined articles) are in the scope of
folding cots are covered under the scope of EN 12221-1,
standard EN 12221: 2008. See example below. that generally says that
“This part of EN 12221 specifies safety requirements for
changing units for domestic use for children with a body
weight no more than 15 kg.
EN 12221 only covers the function of the item as a
changing unit. If the changing unit can be converted or
used as another function it shall comply with other
relevant standards, e.g. cots, storage furniture, etc.”
7 Figure 1
According to the definition in 3.1, a changing unit is an
“elevated structure designed to support a child in a lying

position for the purpose of allowing a caregiver to change
It is clear this product should complies with EN 716 as cot for the child’s nappy”: the changing units that are part of
folding cots can fit quite well under this definition.
domestic use, but when a additional changing table is attached to
the cot would the standard EN 12221 be applicable to whole
Of course the folding cot shall have to comply with any
product ?
other standard that is applicable to that product due to its
We have the impression that the safety requirements and test functionalities (EN 716 for cot function, EN 12227 if the
product can be converted into a playpen, EN 1130 if the
methods described in EN 12221 would not cover the main
hazards of the product taking into account the combined use of product can be converted into a crib, and so on, these are
Clause/ Paragraph/
N° Subclause/ Figure/ Question Reply
Annex Table/Note
this kind of article (one child in the cot and close to changing table just examples).
without supervision).
9 00252050 - EN 12221-2:2008, Child use and care articles - Changing units for domestic use - Part 2: Test methods
Table 15 — Summary table of the request for interpretations classified in the order of the clauses/subclauses of the EN 12221-2:2008
Clause/Subclause Title Interpretation n°
4.11 Test beam 1
5.2 Measurement of changing area 1
Table 16 — Interpretations
Clause/ Paragraph/
N° Subclause/ Figure/ Question Reply
Annex Table/Note
The intention of the working group was to build the test
We have a problem with the test method in EN 12221-2:2008,
beam as shown in figure 7 (clause 5.2.1) with the
Changing units for domestic use: Test methods, clause 4.11 –
minimum width/length measured from the external sides
Test beam, as follows:
of the two rods.
If we drill holes in the test beam with a diameter of 8 mm so that
The sentence in subclause 4.11 shall be changed as
"the distances between their centre points are equal to the
follows:
minimum length and width specified in clause 4.1 of EN 12221-
1 5.2 & 4.11
1:2008", and we have a changing area (without sloping sides),
“There shall be pairs of holes with distances between
where the changing width and / or length are exactly the minimum
their centre points equal to the minimum length and
width and / or length, the two measuring rods will not be able to
width specified in clause 4.1 of EN 12221-1:2008 minus
extend, at all, below the top of the changing surface, and the unit
8 mm, in such a way that the distance between the
will fail the test and be rejected even though its dimensions are
furthest points of two holes is equal to the minimum
acceptable.
length and width specified in clause 4.1 of EN 12221-
1:2008. An additional hole is required at the centre point
We suggest that the words, "centre points" be replaced by
of the test beam"
"extreme diameter points" or similar wording to avoid this
inconsistency.
⌦⌦⌦⌦ The wording of 4.11 will be corrected to be in line
with the drawing through an amendment to the EN
I hope that our explanation is clear.
12221-2:2008.
10 00252054 - EN 1466:2004+A1:2007, Child use and care articles - Carry cots and stands — Safety requirements and
test methods
Table 17 — Summary table of the request for interpretations classified in the order of the clauses/subclauses of the EN 1466:2004+A1:2007
Clause/Subclause Title Interpretation n°
5.1.4 Cords, straps ribbons and other narrow fabrics 1
5.2.1.2 Internal height of rigid carry cot 2 & 6
5.3.5 Castors/Wheels of stands 3
8.1 General 4
Annex A Order of tests 5
Table 18 — Interpretations
Clause/ Paragraph/
N° Subc
...