Welcome to my blog. I am 'The Bunny Maker' - aka Anna, confuzzled mother of three boys, maker of sock bunnies for Widget and Friends, owner of The Warren Bunny Boarding and artist behind Half an Acre. Come on in and join the madness!

Wednesday, 23 June 2010

CE Testing and the 'The Sock Problem': PART TWO

So, continuing the saga - if you haven't read part one click here.

What do I do now?  Its a very good question and it is not good news really either.

I find a sock I like and try and buy as many pairs as I can.  I then have this sock design tested for compliance with the EN71.  I think this is around £80 (please correct me if I am wrong) each for flammability and heavy metals.
If I bought 40 pairs of socks the test would put £2.00 onto the cost of each sock.
When have you ever seen 40 pairs of the same sock in a retail shop anyway?  This means I will have issues with the retailer over why I want these socks and what I am doing with them.
Part of the charm of the bunnies is all the different designs.  The test would have to be done for EACH design of sock costing said amount each time.
I could contact the retailer (I use Top Shop and Next socks alot) and ask them about their socks and get them to provide me with documentation.
Socks do not need to conform to CE testing standards for toys therefore they will not have been tested and there is no documentation.  I know this because I found a sock factory in China to produce the socks and have them made into bunnies for me but they said they could not guarantee that their socks would pass the EN71 test. This is the same with most sock factories because they have nothing to comply too apart from their own self-imposed standards.
Find a factory that does know about their socks and know that they pass the test.

I have the bunnies mass-produced.  This would change the way I sell them and I would be attending trade fairs to take wholesale orders from retailers.  I have looked into this last year and found a factory who would make them and the CE testing would be done by them.  I would be selling them at a wholesale price and the RRP would have to be a much lower price point than they are already because they lose their handmade appeal.  I needed to get the cost down another £1.00 but the factory could not make their price any lower and it is now on the back-burner.  I also needed to buy 3,000 bunnies as a minimum.  Luckily I have a contact who has a good relationship with the factory and they agreed to produce 3 different designs, 1,000 of each.  It is still a whole loada bunnies.
They won't be handmade and there are only three designs.  I don't have the money to pay for 3,000 bunnies.  To make it achievable I would have to have sold a chunk of the bunnies, from working samples, whilst the 3,000 are in production so I know I have money to pay for them.  3,000 bunnies in my garage, unsold, is very, very scary indeed.  I would need to pay around £2500 to attend a trade fair such as Top Drawer.
This ties in with me expanding Widget and Friends too.  I have reached a time when I need to expand 'off the kitchen table' but no retailer will buy my bunnies wholesale because they do not conform with the CE mark and they, themselves, could face a fine for selling them.  Dead end.
The above changes Widget and Friends totally and I am unsure of the appeal of a mass-produced sock bunny - hence the back-burner status.

I have my own socks manufactured that conform to the EN71 tests.
As it stands I am in talks with a UK sock manufacturer (yay uk!) who is looking into the situation for me. Their minimum is 600 pairs in my design.  That's pretty exciting but still a whole lot of socks/money.
They think flammability is a problem as fabrics are usually pretreated and socks aren't.  I still don't have the money for 600 pairs. That's 1200 socks and I use one sock per bunny.  Which design do I choose? I would need THE most appealing design - but which is it?
Even if the socks conform I will still have to have a made up (1200 sewn by me GULP) bunny CE tested and the stitching etc many not stand up to their rhino-pulling techniques.  By nature socks are stretchy and the sewing threads don't stretch as far as the sock fibres - therefore 'riiiiiiip'.

I start a company supplying EN71 conforming socks to everyone who makes toys from them.
Its a great idea but ..... money/knowledge/blahblah and the rest of it.  There are not really enough people out there to buy them to really make much money.

I should not be selling the sock bunnies at all nor anyone else be selling toys made from socks either for that matter - but because I'm selling small numbers (relative to the volume toy market) it is not a 'remove those from the market now' situation.  The Trading Standards officer said that I must state 'Not for anyone under the age of 14' as a temporary statement whilst I sort out what to do for the long term.  I am now a 'reference number' with Trading Standards which means it is documented that I am selling 'non-conformist bunnies'.  I have had to be removed from one website that was selling the bunnies (amicably of course!) - the rest will follow eventually.  Boooo.

Some interesting reading The Laboratory at The Birmingham Assay Office.

For now ........


  1. This is terrible. I always thought you made non-conformist bunnies but I mean that in the best possible way. Can you still sell to customers overseas? Perhaps you could sell all your rabbits from a third party address which has no regulations--like Cameroon or something?

  2. Wowsers, its a case of you can't do right for doing wrong. I attend over 70 craft events a year (I sell traditional toys) and at each event there is someone or other that will be selling non-conformist handmade toys, I am sure most of them either don't know about all this (I have seen loads that have little tags saying not suitable for under 3's) or burying their head in the sand about what it really means.
    I believe we have to have some rules/regs but this to me is taking it way too far.
    Good luck with it all and I sincerely hope you come to some sort of resolution (soon).

    Toniann (Knot Just Jigs)

  3. Just a suggestion from someone else who make sock toys.... Can you not get a couple of sellers together to buy socks to cover solution 3?

    I would certainly talk to you about this....

  4. Depressing reading. Would love to know what you come up with. Agree with Clare Bears that some of us sellers could club together.

  5. It is an idea - to become a company selling EN71 conforming socks - but we're talking 600 pairs of ONE design. You would need to buy at least 100 pairs and then we'd all have the same design - not that that is really a problem though.
    I'm not sure I have the business know-how or the back-funds to do it. I would love to though - how amazing would that be!!

  6. This is a depressing example of bureaucracy designed to protect us actually disadvantaging us. Maybe email David Cameron - he's asking for ideas on how to cut the deficit!

    I don't know if it could work but would organic socks be any use? I can only find info on the material they are made with, not the dye but contacting the companies selling them might produce some answers as they should have more interest in what actually goes into their socks. A quick google brings up a few companies with a range of designs - not huge but maybe a start? Also Fairtrade might have an interest in producing small numbers of socks?

    I love your bunnies, please keep them going - someone must have an anwer....

  7. Organic socks would still need to have a 'piece of paper' stating they pass. No matter what I do I still need that bloomin' document stating the micro-milligrams of dye stuff they contain. Even if you dyed them with crushed blueberries they would still need to be tested to say that they were safe. ARGHHHH
    thing that bugs me is that kids suck socks too! no doubt they are safe but without the 'piece of paper - it means nada.

  8. The Spirit of Nature website claims
    "We are committed to selling high quality products without hidden, harmful chemicals like pesticides, petrochemicals, formaldehyd and other toxic substances. We source products from reputable companies that have been produced from natural, organic or sustainable raw materials. Many of these have also been ethically produced, supporting Fair Trade, and none have been tested on animals."

    So they may have documentation in order to be able to prove that claim. Whether they would share it is a different matter of course. But if they did (in return for sales/promotion) then you might be able to self certify? Or have I completely mis-read this?

  9. No you haven't mis-read - do they do socks? i'm off to investigate!

  10. I know that here in the US, childrens toys and apparel evidently have some of the strictest regulations in the world... I wonder if US made children's socks would be up to the standards?

  11. I'm looking into it and have contacted some people - trouble is in getting people to respond :(
    I wonder if I just sound like a total wierdo! *has confidence crisis*

  12. How about people power to get the regulations to change for handmade people.

    The existing regulations are right and should be in place for mass produced items, but what about us little people.

    Surely if we state not suitable for under 14's then its the parents responsiblity to make sure little ones do not touch it!!!!.

    Lets start a petition and get widget to take it to number 10, would be a great photo for the blog :)

  13. LOL. don't think we'd get very far.
    I've found a company that states their organic sock have no azo dyes etc in them. Trying to get in touch with them.

  14. I have had this same issue with lampshades regarding ridiculous regulations. I have also had an EU directive come down on me about electrical waste because I sell clocks that take 1 battery. I am going to contact my MP about excessive regulation on sole traders/craftspeople and I would recommend that you do the same. Good luck.

  15. Any progress on the socks yet Anna? Or should I look to stocking up on bunnies while I can? :P

  16. Hi just read of your problem ,was talking to my trading standards person about my items and told her about your problem she said she did not see a problem with your sock bunnies at all as long as the socks were fairly inflamable or slow burning and thought that maybe you should talk to somebody else about it,regards Tara

  17. Just a thought that came to mind. Is there a solution or something that you can treat the socks already made that you buy. To make them conform to the fire testing? something to soak the socks in or say have them treated? Just a brain fart that came as I read your article. Best of luck

  18. Anna...THANK YOU! I have just found out recently that I am breaking the law by selling my Solemates TM and trying to get round it has been a nightmare. Reading your blog is like listening to a kindred spirit....all the same problems but no real solution :o/ I make my toys from single 0-6 mth baby socks, all hand stitched, embroidered, no limbs or joints or plastic. Spoke to trading standards today and they basically said I'd need to buy hundreds of 1 pair and pay for that to be tested....just like you have detailed...absolute poo pants. And again, as you have said...who the hell wants to by 600 pairs in one design?! That is the beauty of what we do, uniqueness, bright colours and hand made fun...*sighs* bloody C poxy E mark. Much empathy from one sock cutter/makerer to another!! xx