Pet Product Import Compliance | EN71, ASTM, REACH

Compliance is where pet product imports most often go wrong, and it goes wrong quietly: goods clear customs, sit in your warehouse, and then fail at the point of sale or in a market surveillance check. This page sets out what each major market expects, what you need in your documentation set, and where the responsibility sits.

The principle to start from

The importer of record is responsible for the goods being lawful in the destination market. That responsibility cannot be delegated to a factory, and it cannot be delegated to us. What a sourcing partner can do is make sure the right testing is done, on the right goods, with the right documentation, and that you receive a complete set of paperwork. That is a large part of what removes the risk, but the legal responsibility remains yours.

European Union

The EU framework is more demanding than most buyers expect before they start, and it applies to products placed on the market, not only to those sold online.

CE marking. Required for toys (under the Toy Safety Directive), for anything falling within the General Product Safety framework as a harmonised standard, and for electrical items. CE marking is a declaration by the importer that the product complies — the technical file must exist and be retained.
EN 71 for toys. The toy safety standard series, including mechanical and physical properties, flammability, and specific migration requirements. For toys intended for children under three, this also triggers the stricter chemical requirements.
REACH. The chemical framework covering restricted substances in articles. For pet products this matters for soft toys, fabric, coatings, printing inks and metal components. REACH is an access requirement rather than a certification — a supplier can issue a declaration of compliance, and that is usually sufficient provided the substance list is current.
Packaging and labelling. Under the packaging waste rules, packaging must be minimised and marked with the material code where sorting is required. For pet products sold to consumers, the label must carry the identity of the manufacturer or importer, the product’s identity and the batch or lot identifier.
GPSR. The General Product Safety Regulation adds a requirement for a named economic operator responsible for EU compliance, a traceable product identification, and safety information in the language of the destination country. For pet products the responsible person must be identified on the product or its packaging.

United Kingdom

Great Britain applies the same underlying toy and chemical frameworks, with UK-specific requirements layered on: a UK Responsible Person must be named, product marking must show a UK importer or manufacturer, and distance-selling listings must display the required information. Northern Ireland continues to follow EU rules, so a GB-only label will not cover the whole UK. This is one of the most common and most expensive labelling mistakes in the trade.

United States

ASTM F963 is the toy safety standard for the US market, and it differs from EN 71 in ways that matter. A toy that passes EN 71 does not automatically pass ASTM F963, and vice versa. Testing for both markets is normal practice and is usually done in one test house to save time.
CPSIA requires third-party testing by a CPSC-accepted laboratory, a Children’s Product Certificate, and tracking labels on the product. Lead content and phthalate limits apply.
State law. Several US states have their own chemical restrictions and labelling requirements, including California Proposition 65 warnings. If you sell into those states, the labelling obligation is yours to meet.
FDA and USDA apply to pet food and treats, with registration and, in some cases, prior approval. This is why pet food is handled differently from every other category on this site.

Canada and Australia

Canada runs its own consumer product safety regime with requirements that are broadly comparable to the US but not identical, including bilingual English and French labelling for many consumer products. Australia requires Australian responsible supplier information and compliance to the relevant Australian standards, with the responsible supplier named on the product or packaging.

What your documentation set should contain

Commercial invoice, packing list and bill of lading, with the invoice description matching the physical goods.
Certificate of origin where required for preferential duty treatment.
Test reports for the correct standard and the correct market, issued for the production batch rather than a pre-production sample where the standard requires it.
Material or substance declarations for restricted-substance frameworks where a declaration is the accepted form of compliance.
Conformity documentation for products requiring it, with the technical file retained and available.
Labels and artwork approvals, with the production version matching what was approved.
Import records: the invoice is retained for the period your jurisdiction requires, which is commonly several years.

The timing point that matters most

Testing takes longer than most people assume, and it happens after production, not before. If the goods are already finished and the test fails, you do not have a delay, you have a container of unsellable goods. This is why specification and testing requirements should be settled before the production run, and why we raise compliance questions at quotation stage rather than after the first sample.

A reasonable sequence: confirm the destination market, confirm the applicable standard and the documentation form, have the test house quote alongside the factory, allow the test timeline in your delivery schedule, and confirm the labelling against the specific market before printing.

Frequently asked questions

Do all pet products need testing?

No, but many do. Toys need toy safety testing for their market. Electrical products need electrical safety testing. Items that come into contact with food or the mouth may have specific requirements. For products with no specific harmonised standard, the general product safety framework still applies, which usually means a documented risk assessment rather than a laboratory test report. We will tell you which applies to your specific product and destination.

Can I use the same test report for the EU and the US?

Generally not. EN 71 and ASTM F963 are different standards with different test methods and limits. Some data can be shared between test houses to reduce cost and time, but the report itself is market-specific. Products for both markets are usually tested once in a laboratory accredited for both.

Who signs the Declaration of Conformity?

The importer or the EU-established economic operator for the product. A factory can prepare the technical file and draft the declaration, but the signature and the legal responsibility sit with the party placing the goods on the market in the EU.

Is a factory’s “certificate” enough?

Sometimes, and it depends on what the certificate actually is. A test report from an accredited laboratory has a defined meaning. A supplier’s own certificate that says “our products comply with EN 71” has a much weaker evidential position, and in a market surveillance action it may not be enough. We tell you which kind you are being given.

What about chemical restrictions in soft toys and fabric?

REACH restricted substance limits apply to articles. In practice this means declarations covering the fabric, coatings, printing inks, adhesives and metal components, with the substance list current at the date of the declaration. If the product contains PVC, elastomers or certain pigments, it is worth having a specific test rather than a generic declaration.

Can you handle compliance paperwork for us?

We coordinate the testing, arrange for reports to be issued against the correct standard and market, and make sure the documentation set is complete and matches the order before loading. We cannot take over your importer-of-record obligations, and we will say clearly where a decision remains yours.

What happens if a test fails?

The options depend on how the goods were produced. If the failure is fixable — a different material batch, a corrected label, a reworked component — rework is usually possible and we pursue it with the factory. If the failure is structural to the design, you have a commercial decision to make about whether to rework, scrap or accept the risk. It is worth remembering that a failed test is a good outcome, because it happened before the container was loaded rather than after.

Do I need different labelling for different markets?

Yes, and this is one of the most expensive mistakes available in this trade. The UK requires GB marking plus a named UK responsible person, Northern Ireland requires EU compliance, and the US has state-level variations. If you are serving more than one market, the packaging plan needs to be designed for that from the start, because relabelling a loaded container is a very poor substitute for planning it properly.