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Dummy clip / Soother Holder Safety

There are mainly 2 types of soother holders/dummy clips:

1) Soother holders/dummy clips intended to be fastened to garment.
2) Soother holders/dummy clips not intended to be fastened to garment.

Soother holders/dummy clips must be designed, tested, and made in conformance to the EU safety regulation BS EN 12586:2007, however other regulations also need to be considered e.g., BS EN 71-3:2019, BS EN ISO 105-E01 2013, BS EN ISO 14184-1 2011, BS EN 14372 2004, BS EN 14362-1 -2, BS EN 71-11 and BS EN 71-9.

The highest risks of soother holders/dummy clips lay in their mechanical and physical properties; thus the most important standards are:
- BS EN 12586 Child use and care articles. Soother holder. Safety requirements and test methods.
- BS EN 71-1 Safety of toys - Part 1: Mechanical and physical properties.

At the moment there are some inconsistencies between standards BS EN 12586 and BS EN71-1 relating to requirements and test methods; there are also difficulties on how to interpret test results (see CEN/TR 1641112).
This has led to uncertainties for all actors in the past years. However, the basic rule is: Soother holders which are also classified as toys have to fulfil the requirements of the Toy Safety Directive. Soother holders/dummy clips are not classed as a toy, however every dummy clip design needs to be tested on a case-by-case basis, whether it falls within the scope of application of the Toy Safety Directive 2009/48/EC or within the scope of application of other sectoral legislation.

How to distinguish between soother holders that are toys and those that are not:
The definition of ‘toy’ in Article 2 (1), first subparagraph of the Toy Safety Directive 2009/48/EC provides the following criteria: Any product designed or intended whether or not exclusively for use in play by children under 14 years of age.

Where the soother holders/dummy clip have play value, it has to be classed as a toy, and tested/CE marked as a toy as well as passing the soother holder standards.

Soother holders/dummy clips have a similar testing regime to toys, e.g., all the parts need chemical/migration of elements testing, including things like phthalates and BPA, and this depends on the material types e.g., wood different to plastics etc.The lengths/widths of cords have to be under a certain measurement, the parts need ventilation holes. They need impact tests, tension tests, finger trap tests and more depending on the design.
*All untested dummy clips or soother holders beaded or un-beaded are illegal and could potentially cause harm.

-BS EN 71-3:2019
- BS EN 12586 2007 + A1 2011 Child use and care articles –Soother holder
- BS EN ISO 105-E01 2013
- BS EN ISO 14184-1 2011
- BS EN 14372 2004
- BS EN 14362-1 -2
- BS EN 71-11, BS EN 71-9
- Toy Safety Directive 2009/48/EC.
*The ‘Muncher’ dummy clip range comply with all the relevant UK & EU regulations.


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If you have any specific questions or concerns please contact us at

Team Tobbie and Co