Toy R&D - TOY R&D

In toy development, the most expensive compliance problem is not always a failed test.

Sometimes the bigger problem starts earlier: a new regulation is interpreted in a certain way, the product is redesigned around that interpretation, and the redesign then triggers a different set of safety requirements.

What looks like a conflict between two regulations may actually be a chain reaction caused by an earlier design decision.

We recently came across a good example involving a rechargeable electronic toy. The case is useful because it shows why compliance should not be treated as something that happens only after a sample arrives at the laboratory.

At ToyRD, this is exactly the kind of problem we like to examine from the development side: not only *what does the standard say?*, but also *what product definition did we create before the standard was applied?*

The Original Product Was Never Designed for Consumer Battery Replacement

Rechargeable rocking toy enclosure showing the difference between a sealed housing and a screw-secured battery-service design. — Battery serviceability changes the enclosure design and must be considered alongside toy-safety requirements.

The product was a rechargeable electronic toy with sound and light functions.

Internally, it contained the usual components: a PCB, a rechargeable lithium-polymer battery, a speaker, LEDs, and a charging circuit.

The original enclosure was simple. The upper and lower plastic housings were joined by ultrasonic welding.

From a product-use perspective, there was no reason for the consumer to open the housing. The user could charge and operate the toy normally, while the battery remained inside the product.

In other words, the original design logic was:

Rechargeable product, sealed enclosure, no user battery replacement.

Then the EU Batteries Regulation entered the discussion.

"The Battery Must Be Replaceable" Became "The Consumer Must Replace It"

Regulation (EU) 2023/1542 introduced new requirements for the removability and replaceability of portable batteries.

Article 11 establishes a general rule that portable batteries incorporated into products should be readily removable and replaceable by the end-user during the lifetime of the product. It also explains that commercially available tools may be used; "removable" does not necessarily mean tool-free.

The requirement under Article 11 applies from 18 February 2027.

When the customer first heard about this requirement, the interpretation was understandable:

The battery can no longer be permanently sealed inside the product.

But the next assumption was more consequential:

Therefore, the consumer must be able to open the toy and replace the battery personally.

That assumption immediately became a mechanical-design decision.

The original ultrasonic-welded enclosure was changed to a screw-closed enclosure.

On the surface, this looked like a straightforward compliance improvement:

Ultrasonic welding = cannot open. Screws = can open.

But something more important than the fastening method had changed.

The product's serviceability definition had changed.

It was no longer merely a rechargeable product with an internal battery. It was moving toward being defined as a product whose internal battery was intentionally accessible for replacement by the user.

That distinction matters.

One Sentence in the Instructions Changed the Compliance Path Again

Later, the customer prepared the user instructions and included wording stating that the consumer could open the product and replace the internal battery.

That sentence reinforced the new product definition.

From a compliance perspective, the laboratory was no longer looking only at a rechargeable toy with an internal battery. The documentation now explicitly described a product that the user was expected to open in order to access and replace that battery.

That naturally raised another set of questions.

If the user is expected to open this part of the toy:

How is access controlled?
Can a child gain access to the battery?
What happens to the screws after the cover is opened?
Are the fasteners part of the battery-safety system?
Does the battery compartment construction meet the applicable toy electrical-safety requirements?

This is where EN IEC 62115 entered the picture.

The laboratory was not contradicting the EU Batteries Regulation. It was evaluating the product that had now been presented to it: a toy with an intentionally openable battery-access structure.

Then the 20 N for 10 Seconds Requirement Appeared

Rechargeable toy battery access, design review, and mechanical testing of the battery-compartment fastening system. — When a battery-access design is intended for users, its fastening and safety functions must be validated as a complete system.

EN IEC 62115:2020+A11:2020 includes requirements for fasteners used to secure doors or covers that provide access to a battery compartment.

Clause 13.4.6 addresses captive battery-compartment fasteners. Where the clause applies, the screw or similar fastener is expected to remain with the door, cover, or equipment after opening.

The associated test applies a force of 20 N for 10 seconds to the fastener.

An important engineering detail is that this is 20 N of force, not a torque value.

From the laboratory's perspective, this requirement makes sense. If a screw is part of the system that prevents inappropriate access to a battery, losing that screw after opening the compartment could undermine the safety function during later use.

But from the project team's perspective, the situation suddenly looked contradictory:

The EU wants the battery to be replaceable.

while at the same time:

The toy-safety standard places additional restrictions on the construction used to access the battery.

The natural reaction is to ask:

Which rule are we supposed to follow?

The better question is:

Did the first rule actually require us to define the product this way?

Go Back Upstream: What Does the EU Batteries Regulation Actually Require?

Article 11 of Regulation (EU) 2023/1542 does establish a strong general principle of battery removability and replaceability.

For many products, the intention is clear: a battery should not unnecessarily turn an otherwise usable product into waste simply because the battery has reached the end of its useful life.

But the regulation also recognizes that end-user replacement is not always compatible with product safety.

Article 11 includes derogation mechanisms under which certain products may be designed so that the battery is removable and replaceable only by independent professionals.

That distinction is critical.

"The battery must be replaceable" does not always mean "the ordinary consumer must personally open the product and replace it."

For a child-related product, that difference can completely change the engineering solution.

A product may need to be serviceable without being designed as a consumer-openable battery compartment.

July 2026 Made the Toy Case Much More Relevant

On 14 July 2026, the European Commission adopted Commission Delegated Regulation C(2026) 5031 final, supplementing the Batteries Regulation with additional derogations from the end-user removability and replaceability requirement.

One of the specifically listed categories is:

electric toys that incorporate rechargeable batteries

The proposed derogation applies until 31 July 2030 where, due to the nature or size of the toy, the derogation is necessary to ensure the safety of the toy.

Under that route, the rechargeable battery may be removable and replaceable only by independent professionals, rather than by the end-user.

This is an important development for rechargeable toy design.

It reflects a basic safety reality: the policy goal of making batteries replaceable should not force a toy manufacturer to introduce a new child-access hazard simply to make the battery easier for a consumer to reach.

There is, however, an important status note.

At the time of writing, 30 August 2026, C(2026) 5031 has been adopted by the European Commission but is still within the European Parliament and Council scrutiny process. EUR-Lex lists 14 October 2026 as the foreseen end of the objection period. The act enters into force only after the required procedure and publication in the Official Journal are completed.

So it should not yet be described as a fully effective exemption without that qualification.

The 2030 Toy Safety Rules Show the Same Direction

The regulatory direction becomes even clearer when we look at Regulation (EU) 2025/2509, the new EU Toy Safety Regulation, which will replace the current Toy Safety Directive from 1 August 2030.

Its electrical-safety provisions state that batteries constituting small parts must not be accessible without a tool. It also provides that, where the size or nature of the toy requires it, a rechargeable battery may instead be made inaccessible and removable or replaceable only by independent professionals.

This helps explain why the 2026 delegated act provides a temporary toy-related derogation through 31 July 2030.

The policy direction is not:

Make every rechargeable toy easy for a consumer to open.

It is closer to:

Make battery replacement possible, while preserving the safety level required for the toy.

Those are very different design objectives.

Now the Original Project Becomes Much Easier to Understand

If we map the project as a development chain, the problem is clearer:

EU Batteries Regulation introduces battery removability and replaceability requirements

↓

interpreted as

The consumer must personally replace the internal battery

↓

therefore

Ultrasonic welding is replaced by screws

↓

the instructions state

The consumer can open the product and replace the battery

↓

the product is now presented as

User-openable with accessible battery replacement

↓

the laboratory evaluates the resulting structure under the relevant battery-access requirements of EN IEC 62115

↓

additional requirements appear, including

battery-compartment fastener / captive-screw requirements

The key point is this:

The Batteries Regulation did not directly create the EN IEC 62115 fastener problem.

The intermediate product-definition decision did.

That is why describing the situation simply as "two regulations are conflicting" misses the most useful lesson.

Do Not Start by Asking How to Make the Screw Pass

Once a laboratory raises the 20 N / 10 s requirement, the immediate engineering reaction is often:

How do we redesign the screw?

Maybe use a captive screw. Maybe change the thread. Maybe modify the housing. Maybe change the cover.

Those may eventually be necessary.

But at ToyRD, we would first move one step upstream and ask:

Does this product actually need to be defined as consumer battery-replaceable?

That question should be answered before committing to another structural redesign.

If the applicable regulatory route allows this particular rechargeable toy to use independent-professional battery replacement, then the product design, risk assessment, instructions, and laboratory test definition should all follow that same logic.

The instructions should not simultaneously tell an ordinary consumer to open the toy and replace the battery themselves.

On the other hand, if the commercial decision is genuinely to provide consumer battery replacement, then the product should be engineered from the beginning as a proper user-serviceable battery system, with all the corresponding toy-safety requirements considered.

Simply changing ultrasonic welding into several ordinary screws is not the same as designing a compliant consumer-accessible battery compartment.

Deleting One Sentence from the Manual Is Not the Whole Solution

A toy designed for safe professional battery servicing, with the battery and internal electronics maintained by trained personnel. — Battery replacement must remain possible without turning a child-safe toy into a consumer-openable battery compartment.

In this case, removing the statement that the consumer can replace the battery may be part of the correction.

But changing the manual alone is not enough.

The project needs four things to agree with each other:

Regulatory path → Product design → User instructions → Laboratory test definition

If the intended route is professional battery replacement, the product and instructions should consistently reflect that.

If the intended route is end-user replacement, the enclosure and battery-access system should be designed accordingly.

A compliance document should describe the product that actually exists.

It should not be used to create a different product definition after the engineering work has already been completed.

This Is Why ToyRD Focuses on Design-Stage Compliance

Compliance is often treated as the last step of product development:

Design → Tooling → Sample → Laboratory → Pass or fail

That approach works until a test failure reveals that the problem started much earlier.

By the time the laboratory identifies the issue:

the enclosure may already be tooled;
the PCB may already be frozen;
production samples may exist;
manuals may be written;
packaging may be in artwork;
schedules may already be committed.

At that stage, a misunderstanding that originally cost nothing to correct can become an expensive engineering change.

At ToyRD, we prefer a different question:

Before changing the product, are we sure we are solving the requirement that actually applies?

This is part of what we mean by a development-stage Second Opinion.

Sometimes the most valuable compliance input is not another test.

It is stopping a design change long enough to verify why that change is being made.

Four Questions Before Changing a Toy Because "The EU Requires It"

Whenever a new regulatory requirement reaches the engineering team, these four questions are worth asking before modifying the product.

1. What regulation or standard are we actually talking about?

"The EU requires it" is not a specification.

Find the regulation, article, standard, clause, or official guidance behind the request.

2. What does the original requirement actually say?

A regulatory objective and an engineering solution are not the same thing.

"The battery must be replaceable" is a regulatory requirement.

"Therefore the consumer must remove four screws and replace it personally" is an engineering interpretation.

There may be other compliant routes.

3. Does this exact requirement apply to this exact product?

Battery type, toy category, age grading, safety risks, product construction, intended use, and placing-on-the-market date can all affect the answer.

Compliance should always return to the actual product.

4. Will this design change trigger another requirement?

This is where engineering and compliance have to meet.

Changing one fastening method may change:

battery accessibility;
child access;
small-parts risks;
fastener requirements;
servicing method;
instructions;
risk assessment;
laboratory test conditions.

A product is evaluated as a system, not one regulation at a time.

Regulatory Misinterpretation Has a Real Development Cost

There is a type of product-development cost that rarely appears in a BOM:

Regulatory Misinterpretation Cost.

A tooling modification costs money.

Another prototype round costs money.

Another laboratory submission costs money.

Updating the manual and packaging costs money.

A delayed launch costs money.

But sometimes all of those costs begin with a sentence like:

"We heard the EU will require this."

The purpose of good compliance work is therefore not only to tell a team which clause to test.

It is also to help the development team determine what that clause means before it becomes plastic, tooling, documentation, and production inventory.

For ToyRD, that is an important part of R&D intelligence:

Understand the regulation. Define the product correctly. Then design the solution.

Sometimes a useful Second Opinion does not add another feature or another test.

Sometimes it simply asks, before the mold is changed:

Are we solving the right problem?

Disclaimer: This article discusses product-development and regulatory reasoning and is not legal advice. Applicability depends on the specific product, battery, intended use, age grading, market-entry date, final legislation in force, and assessment by competent compliance professionals or laboratories.

References

1. Regulation (EU) 2023/1542 on batteries and waste batteries — Article 11, removability and replaceability of portable batteries. https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32023R1542

2. European Commission, "Commission adds exemptions to rules on removability of portable batteries," 14 July 2026. https://environment.ec.europa.eu/news/commission-adds-exemptions-portable-battery-removal-rules-2026-07-14_en

3. Commission Delegated Regulation C(2026) 5031 final, adopted 14 July 2026. https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=intcom:C(2026)5031

4. Regulation (EU) 2025/2509 on the safety of toys — Annex II, Part IV, Electrical Properties. https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32025R2509

5. EN IEC 62115:2020+A11:2020 — Electric toys — Safety, Clause 13.4.6, Battery compartment fasteners. Consult an authorized copy of the standard for the full normative text.

When a toy project begins, most people naturally focus on the idea.

Is the design attractive enough? Is the function innovative? Will customers like it? Will it make people stop and take a closer look at a trade show?

But after spending enough time in product development, I have gradually come to believe that many projects do not fail because of the idea. They fail because of execution.

A good concept may miss a customer’s internal review simply because the sample was two weeks late. A project that was already close to approval may slowly lose momentum because the supplier keeps delaying the sample. A product that still has room for cost optimization may end up in endless price negotiations simply because the quotation only shows one total number, with no visibility into where the cost actually comes from.

None of these sound like “technical problems.”

But in reality, they often have a bigger impact on whether a project succeeds than the technical problems themselves.

Deadlines Matter, but a Deadline Alone Does Not Prevent Delays

Toy manufacturing checkpoint board, supplier update, test checklist, fabric samples, and electronics board. — Smaller, verifiable checkpoints make delays visible early enough to act.

When we work with suppliers, we normally give them a clear deadline.

For example, a prototype, tooling sample, PCB sample, or packaging sample may need to be completed by a certain date. To be safe, we usually start following up one or two days before the deadline.

This is a very common approach.

But the reality is simple:

Even if you start chasing in advance, the sample can still be late.

I used to think the main reason was that the supplier lacked execution, or that our project was not high enough on their priority list.

Those situations certainly happen.

But I later realized that the bigger problem is this:

By the time you discover that the project is going to be delayed, it is often already too late.

A deadline is only the final point in time.

Imagine that a supplier originally planned to prepare materials on Monday, process parts on Tuesday, assemble on Wednesday, and test on Thursday.

If something already went wrong on Tuesday, but you do not ask about progress until Thursday, then no matter how urgently you chase them, the lost time is already gone.

So instead of only “chasing the deadline,” a more effective method is to break one large deadline into several smaller checkpoints that can actually be verified.

For example:

Have the raw materials arrived?
Has machining started?
Has the PCB been soldered?
Has the plush sewing been completed?
Has the mold gone onto the machine?
Can you send a photo of the current sample status?
What exactly is blocking progress today?

The purpose of these questions is not to put more pressure on the supplier.

The value is that they help you discover earlier when the project has already started drifting away from the original plan.

If you know on Tuesday that a key part still has not arrived, the R&D team still has time to decide:

Should we wait?

Should we switch suppliers?

Should we build a functional sample first?

Should we send the completed parts to the customer for early confirmation?

The real value is not how much faster you can push the supplier at the end.

It is knowing a few days earlier that the target date may no longer be realistic.

Those few days are often where project management can actually recover time.

One Core Part of R&D Management Is Making Risk Visible Earlier

A lot of R&D work appears to be about managing the product.

Drawing, revising structures, confirming electronics, testing functions, approving samples, following tooling, following packaging.

But if you step back, you realize that a large part of what an R&D manager actually deals with every day is information.

Who is working on what?

Which part of the project is already at risk?

When a supplier says “no problem,” is there really no problem — or have they simply not started yet?

When must the customer see the sample?

Which issue, if left unresolved today, will affect the whole project three days later?

So project management is not only about assigning a completion date.

More importantly, it is about creating a mechanism that allows bad news to appear as early as possible.

That may sound counterintuitive.

Everyone likes to hear “yes,” “no problem,” and “we can make it.”

But in product development, the earlier you know that something may not make it in time, the safer the project becomes.

Because there is still time to adjust.

The most dangerous situation is not that a problem exists.

It is that the problem has already existed for days while everyone still believes the project is on track.

Quotation Works the Same Way: One Total Price Is Often Not Enough

Toy components, cost sheet, calculator, packaging notes, and product sketch used to review toy development cost. — A transparent quotation makes cost a design decision, not just a negotiation.

Another interesting thing I have seen is how some highly experienced buyers handle quotations.

When they receive a price, they rarely look only at the final number.

They keep breaking it down.

How much is the plastic?

How much is the electronics?

How much is the speaker?

How much is the plush material?

How much is the packaging?

How much is the labor?

How much could be saved by removing one printing process?

How much could be saved by changing one component to a different material?

At first, this style of purchasing can feel like the buyer is simply trying to negotiate every line item down.

But over time, I have come to appreciate the logic behind it.

Because professional cost control is not really asking:

“Can you make it cheaper?”

It is asking:

“Where is the cost coming from?”

These two questions may sound similar, but they lead to completely different conversations.

The first usually has only one outcome: the supplier gives up a little more margin.

The second can actually change the product.

For example, a product may be too expensive not because the supplier’s margin is too high, but because:

one component uses an unnecessarily high material specification;
there are too many printing processes;
a metal part is structurally too complicated;
the packaging volume is too large;
the PCB includes components that are not really necessary;
one cosmetic effect requires an additional production process;
the order quantity is too small to spread fixed costs efficiently.

Once these costs are broken down, R&D, purchasing, and the customer can make much better decisions together.

Maybe the customer wants to keep the appearance but remove one function.

Maybe the electronics specification cannot be reduced, but the packaging can be optimized.

Maybe one expensive component is actually a key selling point, and another cost item should be changed instead.

The purpose of breaking down a quotation is not only to push the price lower. It is to turn cost into something that can be understood, discussed, traded off, and designed.

Good R&D Is Not Just About Getting the Product Made

I used to think of R&D mainly as “solving technical problems.”

Now I think that definition is too narrow.

A mature R&D engineer — or a mature R&D team — does not only need to make the product work.

They also need to keep asking several very practical questions:

Is the timeline still under control?

Are we spending money on the parts that truly create value?

Are risks being discovered early enough?

Are the supplier, purchasing team, engineers, and customer all working with the same information?

Very often, what determines whether a toy project succeeds is not one brilliant idea.

It is a collection of small, unglamorous execution details.

Was the deadline broken into process checkpoints?

When the supplier said “almost finished,” did anyone verify the actual progress?

When the quotation came in, did anyone understand the real cost structure?

When a risk appeared, was it discovered on the final day — or one week earlier?

These things rarely appear in a product brochure.

And people rarely talk about them.

But they are a very real part of toy development.

That is also what I hope to keep documenting on ToyRD:

Not only how a toy should be designed, but how a toy is actually developed and made inside a real supply chain.

Tag: Toy R&D

When Battery Replaceability Creates a Toy-Safety Problem