We are at the initial stages of product design for a sleep aid for infants i.e. intended for use with newborn age upwards. The project product name is called 'Jezza' and comprises a soft-toy that in turn houses the electronics in a 'pod'. The pod can be removed from the soft-toy to allow machine-washing of 'Jezza'.
We are working through the necessary compliance for toy safety and have a query about the use of an internal rechargeable lithium-ion battery pack within the 'pod' and how we are interpreting the requirements of EN62115. I thought I would seek the opinions from the list here please just to see if we are OK in regards our thinking, which I will explain below. 'Jezza' will need to comply with EN 62115:2005+A2+A11+A12, electrical safety for toys. To provide power for 'Jezza' it is intended that a lithium-ion type battery 'pack' is contained within the pod. This battery pack is not user accessible. The choice of this type of battery technology is to meet the client's design requirements in terms of 'usable battery life' between charging. The first query is that we have not seen any specific compliance restrictions regarding the use of lithium-ion type batteries in toys and especially toys intended for use from birth age upwards. Is anyone, however aware of any restrictions, other than of course meeting all the safety requirements with the battery pack? Are there none regarding toys? The second is regarding the appropriate charging method for this battery. In the EN 62115 standard is a clause 14.4, "Transformer toys and dual supply toys shall not be intended for use by children under 3 years old." Just to interpret that, in standards "shall" indicates a requirement. In the ISO/IEC Directives, Part 2, Seventh edition, 2016, 3.3.3, a requirement is defined as an "expression in the content of a document conveying objectively verifiable criteria to be fulfilled and from which no deviation is permitted if compliance with the document is to be claimed." The definition of 'transformer toy' and 'dual supply toy' is given in an earlier clause 3.1.3 within EN62115. 3.1.3 transformer toy toy that is connected to the supply mains through a transformer for toys and using the supply mains as the only source of electrical energy 3.1.4 dual-supply toy toy that can be operated as a battery toy and either simultaneously or alternatively as a transformer toy 3.1.8 transformer for toys safety isolating transformer specially designed to supply toys operating at safety extra-low voltage not exceeding 24V (Note the transformer may supply a.c. or d.c. or both). Just a note - 'transformer' in this standard appears to be being used in a colloquial sense as nowadays most power supplies (probably due to ErP directive as well as cost) are a switched mode design rather than a basic 'step down' transformer type, although the switched mode type may still contain a transformer element. Given the constraints above about re 'Transformer toys and dual supply toys shall not be intended for use by children under 3 years old' we are considering the design so that the pod has to be taken out of 'Jezza' by a responsible person (adult) and then placed on or in (depending on industrial design) a 'docking station' base to recharge. The docking station would have a physical interface using pogo pins and lands, or maybe a knife connector plug/receptacle, between it and the pod to charge the device. The pod would not function as a sleep-aid when charging. The dock would be connected to an external mains-DC power supply e.g. 5 or 12V output from the power supply to a connector on the dock. This docking station would charge the pod. The arrangement is intended to be very much like a cordless DECT telephone or similar. Separate chargers are not considered to be a toy even if they are supplied with it as per Note 3 in section 1 (scope) of EN62115. We wanted to gather opinion on whether this interpretation, that we can put a rechargeable pack within the sealed pod and charge it with a separate dock, is correct with regards complying that a 'transformer toy and dual supply toy shall not be intended for use by children under 3 years old'. We take that to mean it would not be acceptable to have e.g. a USB socket on the pod for connection to a 'charger' via a cable. Thank you all for reading and any info regarding all that. 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