How to Import Toys from China to the UK: GB and NI Checklist

Which UK toy rules apply: Great Britain or Northern Ireland?

The Toys (Safety) Regulations 2011 (SI 2011/1881) apply to toys designed or intended, whether or not exclusively, for use in play by children under 14. The Office for Product Safety and Standards (OPSS) publishes separate statutory guidance for Great Britain (England, Scotland and Wales) and for Northern Ireland, and the legislation text itself has separate versions. Under the Windsor Framework, Northern Ireland aligns with relevant EU rules.

If your customers are in both parts of the UK, you are dealing with two sets of marking and documents, not one 'UK' rule. The guidance here is about new toys; Trading Standards' Business Companion notes that second-hand toys fall under the General Product Safety Regulations 2005.

CE or UKCA: what does GOV.UK say today?

GOV.UK's guidance on placing manufactured goods on the market in Great Britain also lists the Toys (Safety) Regulations 2011 among the regulations where CE recognition applies indefinitely. Commercial summaries sometimes differ on this point; rely on GOV.UK and the legislation, and note the date you checked.

For Northern Ireland, the OPSS guidance says CE remains the marking for the Northern Ireland and EEA markets where an EU-recognised body is used. If a UK body carries out the assessment, the UKNI marking must be affixed as well as CE, and a product with both CE and UKNI cannot be placed on the EEA market.

The Chinese factory chooses the route and applies the marking, so your job is to ask which route was used and to check that the marking, the declaration of conformity and the test report agree. How to read the report is covered in our toy test report guide.

What does a UK importer of toys have to do?

Regulation 26 says an importer must not place a toy on the market unless it has ensured that the manufacturer followed the conformity assessment procedure, drew up the technical documentation, affixed the marking, marked the toy with identifying information and manufacturer details, and supplied instructions, safety information and warnings. OPSS summarises the importer's duties as follows.

1. Make sure the manufacturer has fulfilled its obligations before you place the toy on the market, including the declaration of conformity, technical documentation and marking.
2. Make sure your name, registered trade name or trade mark, and a contact address are marked as required (regulation 27).
3. Make sure storage and transport conditions do not affect compliance.
4. Carry out sample testing of marketed toys.
5. Investigate and record complaints and keep a register of them.
6. Bring non-conforming toys into compliance or withdraw or recall them, and notify the enforcement authorities of safety risks.
7. Keep a copy of the declaration of conformity and keep the technical documentation available to the authorities for 10 years (regulation 31).
8. Identify the other economic operators in the Great Britain supply chain.

Private label changes your status. OPSS defines a manufacturer as a person who makes, or has made, a toy and markets it under their own name or trade mark. If your brand is on the toy, the manufacturer's duties (safety assessment, technical documentation, declaration of conformity, marking) are yours, even though the factory does the production.

The labelling transition to 31 December 2027 lets UK suppliers of goods from the EEA or Switzerland put their details on packaging or accompanying documents. It does not cover toys from China. For those, regulation 27 requires your details on the toy, and the packaging or an accompanying document is allowed only where the toy's size or nature prevents marking, or where you would have to open the packaging to mark it. Trading Standards enforce the Regulations; OPSS lists compliance notices, withdrawal and recall notices, and offences that can lead to fines and up to six months' imprisonment.

Which documents should you hold before the toys ship?

The factory usually holds the technical documentation. You need to make sure it can be made available to an enforcement authority on request, so agree in the purchase terms who holds it, in what language, and how quickly it is produced.

What must the toy and its packaging show?

• Conformity marking (UKCA or CE) affixed visibly, legibly and indelibly to the toy, a label or the packaging; where marking the toy itself is not possible, a label not attached to it or an accompanying leaflet may be used.
• Identification and manufacturer: a type, batch, serial or model number, the manufacturer's name, trade name or trade mark, and a single contact address, on the toy or, where size or nature prevents it, on the packaging or an accompanying document (regulation 19).
• Importer details: your name, registered trade name or trade mark and a contact address (regulation 27).
• Warnings and instructions in English, each warning preceded by the word 'Warning' or 'Warnings' (regulation 20).
• Age warnings visible before purchase, including in online listings, when they affect the decision to buy (regulation 20(9)).
• Category warnings from Schedule 5. Examples: a toy not intended for children under 36 months needs a warning such as 'Not suitable for children under 36 months' or a graphic, with the specific hazard; a functional toy must say 'To be used under the direct supervision of an adult'; a toy inside food must say 'Toy inside. Adult supervision recommended.'

Trading Standards' Business Companion adds that the under-three symbol must never appear on a toy that is suitable for children under three. Mistakes here are cheap to fix at the artwork stage and expensive after printing, so approve a proof against this list before the factory prints.

What are the EORI, commodity code, duty and VAT basics for toys?

GOV.UK says you need an EORI number starting with GB to import into England, Wales or Scotland (Northern Ireland movements may need one starting with XI). The commodity code on the import declaration determines the rate of duty and whether you need an import licence. You also declare the value of the goods, which is used to calculate duty and VAT. A trade agreement or other relief may reduce or remove duty, and VAT-registered businesses can reclaim import VAT using the import VAT certificate (C79).

Toys fall in chapter 95 of the UK Global Tariff, 'Toys, games and sports requisites; parts and accessories thereof'. Heading 9503 covers wheeled toys, dolls and doll carriages, other toys, scale models and puzzles; heading 9504 covers video game consoles and machines and table and parlour games; heading 9505 covers festive, carnival and entertainment articles. Which subheading fits your product is a classification decision for the Trade Tariff tool or a customs broker, made on the exact product, and worth documenting.

We do not quote duty or VAT percentages here: they depend on the commodity code, origin and customs value on the day of import. The step-by-step process is in our UK import guide, and the full cost build-up is in the China landed cost checklist.

Which pre-shipment checks are specific to toys?

1. Approve the artwork firstCheck marking, importer details, age grade and warnings on the printed proof before the factory prints packaging.
2. Match report to sampleThe test report and the declaration must describe the production sample you approved: model, materials, colour, packaging.
3. Inspect finished goodsCheck unit and carton markings, batch or model numbers, warnings and packaging against the approved artwork and sample.
4. Take a sample for your own testingSample testing of marketed toys is an importer duty under the Regulations, so keep production samples.
5. Keep a batch recordLink each shipment to its report and declaration. A complaint or a recall needs that trail.

LYBAM coordinates samples and agreed inspection steps before production or shipment, project by project. That is a project-based check, not a certified third-party audit, and it does not replace your own duties as importer. See our toy sourcing service.

Common mistakes when importing toys from China to the UK

• Treating 'the UK' as one market and using Great Britain documents for Northern Ireland.
• Assuming the factory's CE mark covers you without comparing the declaration and the test report with the product.
• Relying on the 2027 labelling transition for toys from China.
• Putting your brand on the toy without taking the manufacturer's duties.
• Accepting a 'certificate' with no test report behind it.
• Forgetting the 10-year retention of the declaration of conformity and technical documentation.
• Leaving the age warning out of the online listing.

Frequently asked questions

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