Childrenswear Safety Manual 2009 - Clothing

Introduction
Welcome to the Marks & Spencer Childrenswear Safety Manual.
Safety is extremely important to us and our customers have high expectations of our ability to trade safely and responsibly. It
underpins our core business values (Quality, Value, Service, Innovation & Trust) and we take great pride in selling safe product that
meets the highest standards of our business.
Marks & Spencer has a large exposure to the consumer and so we must minimise the possible safety risk by minimising the hazard
(Hazard X Exposure = Risk). It is therefore essential that all possible steps are taken to eliminate hazards and it is for this purpose
that the Childrenswear Safety Manual exists.
Understanding and adhering to its content will support the process of producing a safe product and assure continued confidence
and trust in the M&S brand.
This manual has been designed to give the reader guidance when designing and manufacturing Childrens clothing for Marks &
Spencer and is arranged in alphabetical order for convenience.
This manual is a living document and will be continually updated to remain relevant to the changing needs and expectations of our
customer as well as changes or updates in legislation. Please ensure you are always referring to the latest version available on the
Quality Standards website.
Technologists in our UK Head Office and Regional Offices, are available to support you in interpreting the topics covered in this
manual.
There will be occasions when product is outside the guidelines of the manual. In this instance advice must be sought, from the
M&S Departmental technologist. The technologist will assess the risk using available research, data and services of our independent
safety consultant.

Product Safety Manager

It is a condition of supplying Marks & Spencer Childrenswear that our Suppliers designate a senior level person as Product Safety
Manager to co-ordinate all aspects of product safety. This person will be the key point of contact for Marks & Spencer for safety
related matters.
A Product Safety Officer must be employed on each factory site and this person must report directly to the Product Safety Manager.
All workers involved in the manufacturing process from development to delivery must have access to adequate training so that
they can successfully play their part in delivering safe product. It is the responsibility of the Product Safety Manager to ensure that
this is delivered.

Product Safety Audit (PSA)

The Marks & Spencer Product Safety Audit exists to ensure that procedures operating in each factory can consistently produce the
safe product our customer expects and that the Marks & Spencer brand and reputation demands.
Before any factory can produce Childrenswear product, the Regional Product Safety Auditor must carry out a PSA and the factory
must achieve a grading no less than minimum standard. Where applicable Corrective Action Plans will be issued and followed
up with a visit(s).
QMS Childrenswear Product Safety audit report is available on the Quality Standard Website, the path to the document is:
Document Library/Quality Systems Standards
Factories will be re-audited by Regional Product Safety Auditor, the frequency of which will be determined by the grade awarded.
It is a Marks and Spenser requirement that internal audits are carried out by the factory Product Safety Officer, monthly.
A copy of the safety audit form can be found on the Marks & Spencer Quality Standards Website.
Ferrous Free Policy In order that product may be effectively metal detected, it is a requirement that suppliers keep to the M&S
policy of using ferrous free metal components so they pass through the metal detector and ensuring the sewing needles are of
ferrous content so they are detected for all production.

Non Adherence to Safety Manual Our Policy

The safety of our Childrenswear is a core requirement for Garment Makers to conform to. Specifically, all products presented to
Childrenswear must be risk and safety assessed, and suitably specified, to avoid any foreseeable risk of danger to the customer.
The Childrenswear Safety Manual details the minimum standards of safety that are our Marks and Spencer requirement. These
standards to be adhered to for all our products, from first design samples through to production, including those products made for
our Outlet Stores.
Suppliers who deliver product that fails to perform to the clearly specified guidelines and requirements in this manual risk having
non-conforming product rejected: at source, warehouse, RTMd, or potentially recalled from M&S Stores or customers at their cost.
This Merchandise will be destroyed unless it can be re-processed to a safe standard and at a timely requirement to the
Departmental needs, no unsafe merchandise will be allowed to be disposed of for re-sale elsewhere.
M&S takes the issue of product contamination very seriously specifically where there is contamination of sharp items which have
originated in the factory. In certain instances, these can cause a serious injury or even a fatality to a customer.
Our General Merchandise Terms and Conditions on the Quality Standards Website under Supplier Fines and Recharge Table
(All Suppliers) - clearly states that where there is sharp contamination found in product, a fine of 10000 GBP may be applied to
the supplier by M&S. We also reserve the right to Bulk RTM the product. In cases where there has been, or potentially could be,
serious customer injury which may lead to a fatality, the product may be subject to a nationwide Product Recall. This procedure
includes a full recharge of advertising costs in the national papers, as well as charges for the Bulk RTM

Category

Contents

Non-adherence to our Safety Policy

Risk Assessment
Legal Documentation
Marks and Spencer Internal Standards
Test Methods
Battery Operated Components
Beads
Belts
Bibs
Braces (Separate Braces)
Buttons
Decorative Feathers
Diamantes
Direct Embroidery / Fusible Motifs and Badges
Dressing up & disguise costumes
Elastics
Faux Fur pile fabrics & trims.
Flammability All Garments excluding nightwear and Dress up
Flammability Nightwear
Flash Flame
Float Lengths - Includes socks / tights / gloves / and garments with integral feet.
Hoods and Headwear
Hooks and Eyes and Hooks and Bars
Lace Crochet - open constructions
LED Lights (Light Emitting Diode)
Liquid Filled Products (e.g. Badges/ Teethers
Magnets
Metal components - Press fasteners, Stud buttons, Rivets, Eyelets, Strap adjusters
Migration of Toxic Elements
Natural Materials for Accessories & componentry
Necklaces
Neck Stretch
Neck Ties
Plastic bags e.g. over bags intended for sale with the products in M&S stores
Pom-Poms / Bobbles / Tassels and Fringing
Prints (transfers, panel prints, all over continuous prints includes backing materials)
Rouleau Loops
Safe in the Sun Garments and Hats
Scarves
Sequins
Silica Gel
Sleeping Bags
Sound Nodules/ Noise Levels
Swim Short Mesh Liner Fabric for Boys
Toys
Waddings and Quilted Waddings including Feather & Down
Washed Garments - that use Stones or Sand.
Zips
APPENDIX
Cords and Drawstrings
Risk Assessment & Design Hazard Assessment documentation
Test to Failure (TTF) and Pull Tests
Test to Failure (TTF) - The Maths and graphical illustrations

In Line Testing

No

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
I
II
III
IV

Risk Assessment
Safety, like quality, must be designed, planned and built in to the product. It is sometimes difficult to foresee all the possible modes of failure
allowing for all the conditions of use and unforeseeable use. Without a systematic approach to design and manufacture it is likely that some
element will be missed resulting in a failure and possible injury to the wearer.

First the Hazards need to be identified

Burn
An injury caused by heat, friction, cold, electricity, chemicals or radiation (sun)

First-degree burns (superficial thickness) are usually limited to redness, minor pain and a white plaque at the site of injury. These burns usually
extend only into the epidermis
Second-degree burns (partial thickness superficial and deep) additionally fill with clear fluid, and have superficial blistering of the skin, and can
involve more or less pain depending on level of nerve involvement. Second-degree burns involve the superficial papillary dermis and may also
involve the deep (reticular) dermis layer.
Third-degree burns (full thickness) additionally have charring of the skin, and produce hard, leather-like scabs. Frequently, there is also purple fluid.
Nerve endings will have been destroyed in the involved areas.

Choking
Choking is the mechanical obstruction of the flow of air into the lungs. This can be caused by a foreign object lodged in the mouth or throat thus blocking
the airways
Hazard Example - release of a component such a button or stud
Note:
Mouthing is an important learning strategy used by all children; infants start mouthing as soon as they can place their hand in their mouth this strategy
continues with varied intensity until a child approaches 36 months after this it reduces considerably. This is well understood by child behavioral
experts and all safety standards for childrens products contain specific criteria for children in this younger age group.
Childrens garments contain many small parts such as buttons and poppers, if detached any one of these could become a serious choking hazard.
In an effort to ensure that all products sold to this age group are as safe as possible a specific testing regime has been introduced for this age group
to ensure that all products sold are safe. Testing to Failure or destruction is a statistical process designed to identify component defects and provide
a consistently safe product

Entrapment
A situation where a child is unexpectedly caught up on a garment or part of a garment.
Hazard example - chain attached to the belt loops of jeans
Eye Impaction
Injury to the eye cased by projectile
Hazard example - projectile toy such as bow and arrow
Ingestion
The process of taking something into the body by swallowing,
Hazard Example - button cell battery / magnets that could become an ingestion hazard
Inhalation (or Aspiration)
The action of drawing in air, other gases or objects into the airway, as in breathing. This could lead to items getting in to the lungs or choking if the item
lodges in the airway.
Hazard example - A small button or part of a fastener could become an aspiration or inhalation hazard should it detach
Insertion (object into body)
Injury caused by child placing small object into their nose or mouth
Hazard example - Detached bead
Over heating
Very young children are not capable of regulating their temperature efficiently, which can lead to overheating
Overheating may play a role in causing SIDS (Sudden Infant Death Syndrome),
Hazard Example Sleep bags being too high a Tog Rating
Laceration
Cut, scratch or graze
Hazard example - Poorly attached fastener with exposed prong / flash on zip fastener
Penile entrapment
There are two likely types of penile entrapment:
The foreskin can become caught up in the net fabric that lines boys swimming trunks
The foreskin or the skin on the penis can become caught up in the teeth of a zipper on trousers

Pinching
Painfully squeezing skin or flesh
Hazard Example caught in a push closure clip or caught in a hinged mechanism
Projection
A protruding part that extends out from the garment, or accessory with the ability to cause an injury should the child fall on it.
Hazard Example - Some buttons shaped like sharks teeth could become a projection hazard if placed in the neck area of a garment with no fabric /
padding beneath when fastened.
Restriction of hearing
Any product that can constrain hearing
Hazard Example - iPod earphones can make wearer oblivious of approaching traffic
Restriction of sight
Any product that impedes clear vision
Hazard Example a mask that could limit peripheral vision
Skin Irritation
A skin allergy is caused by a substance that comes into contact with the skin
Hazard Example Formaldehyde Resin finishes
Strangulation
Injury caused by constriction of the throat that restricts breathing
Hazard example - necklace without a break point,
Suffocation
Injury caused by the stoppage of breathing or asphyxia resulting from it.
External suffocation (not choking or aspiration)
Hazard example - flexible impermeable fabric such as hood
Rigid hemispherical shape - container
Tourniquet
Injury to most likely a toe or finger that has caught in a float or loose end causing restriction to the flow of blood, causing potential loss of toe or finger
Hazard example - Float on babies sock

Toxicity Chemical
A toxic substance is one that can cause harm from through inhalation (by breathing), absorption (by touch) or ingestion (by mouth)
Hazard Example Lead paint
Toxicity - Microbiological
The absence (or low colony count) of microbial growth would indicate a product was microbiologically clean.
Hazard example - There should be no bacteria present a liquid filled badge
Toxicity - Pathogen
Any agent capable of causing disease. The term pathogen is usually restricted to living agents, which include bacteria, fungi, viruses, yeasts and certain
insect larvae.
Hazard example - Feathers must be treated in order that they are free from pathogens
Tripping
Falling by catching the foot on something
Hazard Example - overly long dressing gown tie belt

Marks & Spencer Technologist will then complete the Tech Pack (see appendix) with safety grading for the product (Tech Pack See
Appendix)
FSV must assess their designs for Safety using the Hazard criteria
Suppliers must complete the Supplier Safety Risk Assessment document (See Appendix) for each product and use as a working document
from initial development through to contract seal. The final version must be uploaded onto contracts.com at contract seal stage.
Should a Product Review Document PRD form be required (see Appendix) this should be completed and submitted on contracts.com
at contract seal stage

It is essential to ensure that every aspect of the product is adequately covered by the analysis.

Legal Documentation
Childrenswear safety standards are governed by law, legal guidelines and retail best practices.
This section sets a list of standards and statutory regulations that apply directly to or which Marks & Spencer has adopted for
application to childrens products and any associated accessories or components.
Each supplier must ensure that they have a copy of and are familiar with the documents that relate to their product of supply.
British and European Standards are available at http://www.bsi-global.com/en/Standards-and-Publications/
Please ensure you keep up to date with the latest versions.
BPA (Baby Products Association)
BS (British Standard)
BSEN (A British Standard adopted by European Standards)
EN (European Standard) (European Norm)
ISO (International Organisation for Standardisation)
SI (Standard International)
General
The Consumer Protection Act 1987.
General Product Safety Regulations SI 1803.
BS7907 The Design and Manufacture of Childrens Clothing to promote Mechanical Safety.
Directive 2005/84/EC of The European Parliament and of the council. The Dangerous Substances and Preparations
(Safety) Regulations 2006.
BSEN14682 Safety of Childrens clothing Cords and Drawstrings.
Phthalate Directive 2005/84/EC
Azo dyes 2002/61/EEC
The Food Imitation (Safety) Regulations 1989 SI 1291.
Buttons
BS4162 British Standard Method of test for buttons.

Feather & Down

BSEN12935 Feather and Down, Hygiene and Cleanliness Requirements
Hoods

BSEN ISO 9237 Textiles, Determination of the permeability of fabrics to air.

The Childrens Clothing (Hood Cords) Regulations 1976 No 2

Metal Components
BSEN12472 Method for the simulation of wear and corrosion for the detection of nickel release from coated items.
EN1811 Reference test method for release of nickel from products intended to come into direct and prolonged contact
with the skin.
BSEN71 Part 3 (Migration of elements)
Nightwear
The Nightwear Safety Regulations 1987.
BS5722 Flammability Performance for fabrics and fabric assemblies used in sleepwear and dressing gowns.
EN14878 Burning behaviour of childrens nightwear specification.
Sleep Bags
BS8510 Child use and care articles - Safety of childrens sleep bags Safety requirements and test methods.
BS 5335-1 1991 D.2 and BS 5335-2 2006 with modification laid out in BS 8510:2009 method for determination of
thermal resistance.

Sunsuits / Sun Hats

BSEN13758 Parts 1&2 Textiles Solar UV protective properties
Part 1: Method of test for apparel fabrics
Part 2: Classification and marking of apparel.
BS8466 Hats: protection against solar UVR Method of test and performance requirements / specifications.
Toys / Add -Ons
(Including electronic parts in day wear and dress up, dress up accessories, key rings, soft toys)

BSEN71 Part 1(Mechanical),Part 2 (Flammability), Part 3 (Migration of elements) Safety of Toys, Part 9 (Safety of Toys
Organic chemical compounds)

Toys (Safety) Regulations 1995 SI 204.

BSEN62115 Electric Toys Safety.

Draft Waste Management (Battery and Accumulator) Regulations 2008.

Waste Management (Battery and Accumulator) Directive 2006/66/EC

WEEE Disposal of Waste Electrical and Electronic Equipment.

RoHS Directive on the Restriction of certain Hazardous Substances.

EMC Electromagnetic Compatibility Regulations.

BSEN60825-1 Safety of Laser Products

The Violent Crime Reduction Act 2006 Regulations 2007

Materials and Articles in contact with food (England) regulations 2005 S.I 898

BS7272 (Part 1 & 2) Writing and Marking Instruments

Zips

BS3084 Specification for slide fasteners.

BS7907 Clause 4 4.2 & 4.3 Ischemic Injuries

Marks & Spencer Internal Standards

This section lists Marks & Spencer internal standards that have been drafted to support the delivery of safe product to our customer.
These documents are updated regularly and are available on the Marks & Spencer Quality Standards Web Site.
Animal Welfare Policy.
C99: Environmental, Chemical and Factory Minimum Standards for Dyeing, Printing, Finishing, Leather tanneries, Spinners &
Laundries of Clothing and Textiles.
Clothing and Home Textiles Test Methods (Colour).
Clothing performance Standards CS1- CS14.
Clothing Test Methods (Physical).
Critical Tolerance Chart Ref 014
Due Diligence Code of Practice.
Infestation Policy.
Latex Guidelines.
Migration of Toxic Elements
Nickel Guidelines
QMS Factory requirements
QMS factory guidelines
PVC Guidelines.
Suffocation Hazard Assessment Intertek RAM - see Dept Tech

Test Methods specifically referred to in this manual

C61 Determination of Phthalates

C64 Determination of PVC
C65 Determination of Alkyl Phenols
FP55 Determination of strength of lace hole eyelet attachments
P5 Durability wash for garments and components
P53 Fibre Retention
P116 Nightwear Flammability
P117 Surface Flash Flame
P122 Strength of Buttons
P131 Pile Retention
P115 Security of Attachment of Accessories to garments (Age 4 years and above)
P115 A Security of attachment of poppers to garments (Age 4 years and above)
P115 B Test to Failure of Attachments of Accessories to garments (bows or other stitched on garment accessory)
(Age Under 4 Years)
P115 C Test to Failure of Attachments of Poppers to garments (Age Under 4 Years)

No

Category

Battery Operated
Components

Potential Hazard

Aspiration
Burn Chemical
Choking
Ingestion
Inhalation
Insertion
Over heating /Fire
Toxicity - chemical

Specification

Age: All Ages

Must comply with BS EN 62115 (2005) Electric Toys Safety.

(BS EN 50088 was withdrawn 01/01/2008 and will no longer be
accepted).
Certification of compliance to EN71 pt1where applicable
For use in Toys - Refer to the M&S Electronic Toys Standard on the
Quality Standards Website.
Certification of compliance to EMC requirements.
For use in Toys - Comply with the WEEE Directive.
For use in Toys - Components to be RoHS compliant.
Comply with New Directive 2006/66/EC for Batteries &
Accumulators and waste batteries & accumulators.
For Clothing - P5 Durability wash to be submitted at technical
evaluation stage in garment or panel form.

Tech Notes

Electrical components (including button cell batteries) shall not

be easily accessible (refer to BS EN 62115 for full details).
Battery operated components must be enclosed in a sealed unit
prior to attachment to the garment footwear or accessory
Directive 2006/66/EC for batteries & accumulators (including
button cells) all batteries shall be marked with the Standard
Battery logo (the crossed out wheelie bin) and where appropriate
with the chemical symbol for the heavy metal concerned below
it; if it contains more than 0.0005% Mercury (Hg), 0.002%
Cadmium (Cd) or 0.004% Lead (Pb) by weight (Note: due to size
restrictions button cell markings may be applied to the product
label or packaging).

Battery logo

Heavy metals Battery logos

Age: Under 4 Years

Allowed in this age group provided they are inaccessible

Refer to Battery Directive 2006-66-EC Marking Requirements

and Warnings on the M&S Quality Standards Website for full
marking requirements and standard battery warnings (located
under the Home folder).
Standard disposal statement DISPOSAL - This product
contains batteries and electronics that may be harmful to the
environment; they should not be discarded with normal
household waste but taken to your local collection centre for
recycling.

No.

Category

Beads

Potential Hazard

Choking hazard
Ingestion
Inhalation
Insertion
Laceration
Toxicity-chemical

Specification

Age: All Ages

Beads must not have sharp, rough edges, burrs or flash from the
molding process.
Shaped beads such as flower or star shapes must have smooth edges
and no sharp points
Coatings on beads must conform to Migration of Toxic Elements
section
P5 - Durability wash is required.

Age: Under 4 years

Size/Type of bead must be agreed with the relevant technologist

Beads must be enclosed with a suitable fabric e.g. mesh so the beads
can not come out should they become loose.

Or

Beads are permitted if they are not accessible e.g. threaded onto a
non open ended strap. In this case the strap should pass TTF to ensure
it remains in place and the beads do not become loose. (Please refer
to TTF/Pull test appendix)

Tech Notes

Hand applied Beads:

Thread:

Monofilament thread may not be used because of potential

laceration.

How to Attach:

The needle must pass through the bead a minimum of three

times.
If beads are applied singly, double knot off after each bead.
If beads are attached in a group knot off every third bead.

At Start:

Double knot two strands of thread together, stitch through fabric

to form a small stitch before applying bead.

To finish:

Stitch through and double stitch, finish and knot.

Thread length - start and finish to be 3mm to 5mm.

For Quality :

Float length maximum of 1cm

Thread end - after cutting 0.5cm to 1cm.

If applied to neck area ensure neck stretch is checked. Please refer

to Neck Stretch section.

No.
3

Category
Belts

Potential Hazard

Choking
Entrapment
Laceration
Skin Irritation
Toxicity-chemical
Tripping

Specification
Age: All Ages

Method of attachment
Prong should
not extend past
buckle edge

Figure 1

Please refer to TTF/Pull test appendix

Metal Components:
Must be non ferrous
To avoid rusting, metal components must be made of brass, or stainless
steel specification reference 316L (a common type of surgical quality
stainless steel), or Zamac ( zinc, aluminum, magnesium and copper
alloy)
Refer to Migration of Toxic Elements section

Buckles, Keepers, Prongs, D Rings & Clasps

Must be free from rough or sharp edges.
Prongs must be compatible to buckle size. ( see Figure 1)

Figure 2

Eyelets
Only rolled finish eyelets are permitted. Ensure that the eyelet is
correct depth suitable to the material to which it is applied.
Ensure the eyelet rolls at the back of the material.
Star clench back not permitted due to sharp edges.
Eyelets are not permitted on elastic belts.

Studs
Star clench back not permitted due to sharp edges.
Studs are not permitted on elastic belts.

Age: Under 4 Years

Metal D rings / buckles must be fully welded into one piece. (see
Figure 2)
TTF (P115b) must be carried out on all small parts, e.g. prongs, studs
Where belt keepers are used they must be permanently attached by
stitching. Staples are not acceptable.

Age: Over 4 Years

P115 must be carried out on all small parts, e.g. prongs, studs

PLEASE REFER to TTF / Pull Test Appendix

Eyelets

Where pull test / TTF cannot be carried out , use Eyelet

attachment strength test, reference: M&S FP55, BS 5131:515D

No.

Category

Bibs

Potential Hazard

Laceration
Strangulation
Suffocation

Specification
Age: All ages

No side or back neck ties permitted.

Closing method must not be a continuous loop.
Closing method - To be joined either by press fastener, or touch and
close fastening e.g. Velcro.
Plastic backed bibs must be tested to ensure they are not a Conforming
material* Suffocation Hazard assessment- Intertek RAM may be
specified by the technologist.
P5 to be carried out on any plastic backed bibs to ensure they do not
become brittle and break up, or disintegrate in wash /wear

Tech Notes

The construction of the closure must avoid irritation to the skin.

*Conforming material a material that seals round the mouth /
nose and inhibits or prevents breathing
Suffocation Hazard assessment - Intertek RAM may be required.
This can only be carried at ITS Chicago USA. In this case please,
refer to department technologist for advice.

No.

Category

Braces

(Separate Braces)

Potential Hazard

Entrapment
Laceration
Strangulation
Toxicity - chemical

Specification

Age: All Ages

Webbing must be woven to desired width.

Elastic must be latex free
Must be free of rough edges.
For metal component of braces please refer to Migration of Toxic
Elements
Please refer to TTF / Pull Test Appendix

Age: Under 4 Years

Braces are not allowed under 4 years

Any D rings must be fully welded into one piece (see figure 2 Belts
section)

Tech Notes

Webbing must be securely stitched over D rings

Rabbit ears must be bar tacked.
Must carry swing ticket warning Not suitable for under 36
months For all label references please refer to the CLA website

No
6

Category
Buttons
( relating to any
buttons that can be
sewn onto a garment
/ product using
thread)

Potential Hazard

Choking
Ingestion
Inhalation
Insertion
Laceration
Projection
Toxicity-chemical

Specification
Age: All Ages

Buttons must withstand P122

Machine Lockstitch only CHAIN STITCHING IS
NOT PERMITTED.
Must be free of injection mould flash or rough
edges.
Buttons must not resemble food.
Do not attach spare buttons on Childrenswear.
Glass buttons not permitted.
PLEASE REFER to TTF / Pull Test Appendix

Tech Notes

Please remember if you are applying the same button over

different levels of thickness on the same garment, a TTF / Pull test will need to be
submitted for each thickness. ( for example, a four layer placket and a two layer pocket)
Fig. 1

Fig. 2

Age: Under 4 Years

No Buttons to be attached to uneven surfaces.

No two part / *composite buttons permitted. (see
Figure 1)
Pig nose covered buttons are acceptable provided
they are fabric covered and have metal casings as
holes, or where stitching secures all parts of the
button to the garment (example, fig. 2)
Toggle buttons (see figure 3) must be risk assessed
for shape, catchments, and attachment hazard at
design briefing stage.
Hand stitch buttons NOT PERMITTED

Age: 4 Years and Above

If used composite buttons must be clamped or glued

with epoxy resin adhesive, and withstand P5
Durability and P122 test requirements.
Hand stitched buttons are permitted if they pass
P115

Fig. 3

*Composite: A button made up from more than one part.

To aid in security of attachment, whipping and heat sealing can be used on all
heavyweight fabrics / garments e.g. coats.

Any buttons/ toggles attached using cord or tape must be secured using bar
tacking.

Cut cords must be covered with a triangular piece of fabric (Sprat head) that are
sewn over the cord and stitched to the product.

Sprat Head Diagram (these can also be fabric patches)

Buttons made from polyester are preferred

It is recommended to avoid materials such as Acrylic, Polycarbonate and
polypropylene which are relatively weak and do not usually pass P122 test
requirements.

No.

Category

Decorative Feathers

Potential Hazard

Choking
Ingestion
Inhalation
Insertion
Laceration
Projection
Skin irritation
Toxicity Pathogen

Specification

See Kidswear Dress-up performance standard

Technical Notes

Feathers

Age: Under 4 Years

Decorative feathers are not allowed under 4 years

Feathers must be thoroughly washed and suitably processed to

the British hygiene and cleanliness requirements
E.g. steam cleaned.
Please refer to the Animal welfare policy on quality standard
website

No.

Category

Diamantes

Potential Hazard

Choking
Inhalation
Ingestion
Insertion
Laceration
Toxicity -chemical

Specification
Age: All Ages

Diamante attachment to fabric type to be assessed at product

development stage.
Assess security using the P5 durability wash.
Diamantes are to be inspected for cracks, chips & blackened
edges prior to application
Diamantes must not have sharp, rough edges or burrs
Shaped diamantes such as stars must have smooth edges
Both ultra sonic & heat transfer methods of attachment are
acceptable
Big diamantes i.e. larger than 5mm must be sewn on (see
sequin/ bead section for sewing attachment guidelines) and
meet P115 requirements.
Acrylic stones should not be used as they do not react well to
heat application.

Age: Under 4 Years

Diamantes can be used in this age group. Minimum size to be

used 2mm maximum size 3mm.
Diamantes attached to woven fabric, to be discussed with the
department technologist.

Tech Notes

Diamantes should not be attached directly over prints as this affects

the bonding of the diamante to the fabric.

Diamantes must not be attached on uneven surfaces, such as seams.

Nail head Diamantes can also be called Rhinestones or Rhinestuds

these can be made of metal and can be used

Coloured Diamantes are not as durable due to the films and backing
used. Please ensure they are tested independently of the clear
diamantes if you are using both on the same garment.

Diamantes need to be attached after industrial garment washing.

No spare diamantes to be supplied with the garment

Labeling

All Ages

Additional Care codes required

wash inside out

iron on reverse
Age 4 Years and above

if the diamantes used are not as allowed for under 4 years category
then an additional disclaimer Label: K8A 483G stitched into the side
seam adjacent to the care label.

No.

Category

Direct Embroidery /
Fusible Motifs and
Badges

Potential Hazard

Choking
Ingestion
Irritation in wear.
Laceration
Tourniquet
Toxicity
Toxicity - chemical

Specification
Age: All Ages

Soft interlining to be used on all embroideries which are in direct

contact with the skin to avoid irritation in wear. ( this depends on the
location of the embroidery and should be discussed at development
stage with department technologist )
Thread ends can potentially become a tourniquet risk if over 2.5cm.
For quality we specify thread ends/ loops on embroidery should not
exceed 1cm.

Flocked, PU Printed or Welded Motifs applied by a high frequency

welding
The welded edges must be continuous, all contours to be as
round as possible, and edge lines as wide as possible- to
increase adhesion. These motif types are not dry-cleanable

Motifs/ Badges

Must not be applied by adhesive alone, and must be stitched all

round to ensure security of attachment.

Badges

All edges must be sealed to prevent fraying.

Soft plastic badges must have groove line to allow for stitching.

Nightwear

Kids nightwear containing embroideries, fusible motifs, and badges

must comply with relevant nightwear regulations.

Direct embroidery motifs, embroidered fabrics, and fusible motifs

and backing fabric must all comply with the relevant flammability
requirements

Synthetic fibre threads must be used.

Backing fabric on direct embroidery must apply to the relevant

nightwear regulations e.g.100% polyester.

Age: Under 4 years

Fusible motifs or badges should not be hand sewn on for this age
group as this could pose a choking hazard.
Welded motifs can be used must pass P5 Durability test

Tech Notes

Consider irritation e.g. knees, elbows etc.

Special attention must be paid to flocking to ensure that safety
standards are met, formaldehyde free etc.
Design motifs on stretch fabric must be designed with breaks
in the pattern. This will avoid the breaking of thread when
worn by the customer.
Ensure any adhesives comply with C99.
To reduce sharpness of motif edges it is recommended to laser
cut or fold.
Novelty motives / badges please refer to section on Liquid
Filled Products

No.
10

Category
Dressing up &
disguise costumes

Potential Hazard
ALL RISKS

Specification
Age: All Ages

Refer to the Dress Up Performance standard KDU standard

Refer to the Home safety manual where relevant for toys accessories
& add-ons
All product must be compliant to relevant parts of EN71 & must be
CE labeled
DHA must be carried out for all dress-up products by department /
qualified supplier technologist
Please refer to TTF / Pull Test Appendix

Age: 3 Years and Under

Any potential detachable items must meet TTF P115B requirements.

Tech Notes

Trousers with integral feet must include a slip resistant soletest method FP06.

Formaldehyde finishes are not permitted PU COATED

FABRICS should be durability tested to ensure they do not
deteriorate or peel.

No.

11

Category

Elastics

Potential Hazard

Entrapment
Pinching
Skin Irritation
Tourniquet

Specification

Age: All Ages

Must be latex free

Where used in nightwear, must conform with relevant flammability
legislation

Tech Notes

Elastics can reduce blood flow if designed too tight. Ensure

conformance to relaxed and extended garment
measurements stated on the size chart
Where elastic is used in garment necklines it must meet
minimum neck stretch measurements refer to 014 Critical
Tolerances Chart to be found in appendix.
Must be compliant with formaldehyde restricted levels
specified in C99.

No.

12

Category

Faux Fur pile fabrics

& trims.

Potential Hazard

Perceived choking
and aspiration
Inhalation

Specification
Age: All Ages

Real animal fur is not permitted.

Printed furs (e.g. discharge tips) - solvent-free printing systems should

be used wherever possible and the finished product must comply
with C99 requirements.

Where cellulosic and cellulosic rich faux furs are used these should
be tested to surface Flash Flame P117

Age: Under 12 Months

Toys - Pile length to be maximum 3mm

Garments - Pile length maximum 18mm.

Age: 12 months to 4 Years

Trims Pile length 25mm

Garments - Pile length maximum 20mm.

Technical Notes

Under 4 years - Boa construction must be used as it is more

secure
4 Years and above - Sliver knit constructions are permitted
where agreed with the Departmental Technologist and must
be polished to remove loose fibre.
Loose pile can also be improved by back coating or heat
bonding the fabric the coating used must meet C99
requirements and be latex free

Development

Pile retention to be discussed & agreed with Department

Technologist. P5 durability wash to be submitted in garment
or panel form or 5 x label wash with negligible loss of pile
Note: Methods P131 Pile Retention, & P53 Fibre Shedding
may be used as guides if required
Repeated label washes can be carried out in house

Age: 4 Years and Above

No restrictions on pile length.

Labeling

Our animal welfare policy for clothing states that- For

clothing - Synthetic materials made to look like animal
products should be clearly labeled as such to avoid
unnecessary offence or confusion.
To comply with this any product containing faux fur must
be labeled as such on the care label using Z 305 Code

No.

13

Category

Flammability All
Garments excluding
nightwear and Dress
up

Potential Hazard

Burns

Specification
Age: All Ages
Labeling
All Kids Daywear Clothing must have a Fire Warning (FW) label as
part of the front of the permanent sewn in care label please note
product exceptions in the appendix

The FW wording to read, KEEP AWAY FROM FIRE (Upper

Case 10 point red lettering).

Flash flame testing may be required on certain products please refer

to flash flame section

Tech Notes

Please refer to the Childrenswear label position on the Quality

Standards Website
Please also refer to Kids clothing Flammability Labeling Policy
for products and exceptions.
Pram shoes, bootees & slippers must carry the FW wording.

No.

Category

14

Flammability Nightwear

Potential Hazard

Burns

Specification
Age: Age 3 months and Above:

PYJAMAS, ALL IN ONES AND WALK-IN SLEEPERS must meet the

requirements of EN14878 minimum Class B

NIGHTDRESSES must meet the requirements of BS5722, as

specified in clauses 3.1.1 and 3.2.1.

DRESSING GOWNS AND BATHROBES (except those made of

100% cotton terry toweling) - must meet the requirements of
BS5722, as specified in clauses 3.1.1 and 3.2.1.

Bathrobes Made of 100% Cotton Terry Towelling must meet the

requirements of EN14878 Minimum Class A

Refer to the requirements for Flash Flame M&S test method P117

Tech Notes

Flammability performance relates to both the individual base

fabric and as assembled as a complete garment. Please refer
to Nightwear Flammability Appendix VI doc. for specific
testing details
Please also refer to Appendix for specific labeling
requirements by product type including fire warnings
Where stricter flammability requirements exist for
nightdresses, dressing gowns etc, all components including
threads, trimmings labels etc will be required to meet the
flammability performance.
Specific design restrictions are also detailed in the nightwear
appendix. BS5722 and EN14878
Flame retardant finishes are not permitted unless they comply
with C99, Toxicology of flame retardant as specified in
EN14878 and will perform for the life of the garment.
100% Cotton terry toweling bathrobes can not be sold as
nightwear

No.

15

Category

Flash Flame

Potential Hazard

Burns

Specification
Age: All Ages

FABRICS WHERE FLASH FLAME TEST APPLIES

Products made from 100% cellulosic or cellulosic rich fabric / yarns

(over 55% content) with a raised hairy surface should be assessed
using test method M&S reference P117.

Tech Notes

Refer to Garment Safety standards S4

Refer also to specific nightwear flammability requirements
Where cellulosic and cellulosic rich faux furs are used as
trims, these should also be tested

No

16

Category

Potential Hazard

Float Lengths
Includes socks /
tights / gloves /
and garments
with integral feet.

Laceration
Ripping off
finger and toe
nails
Tourniquet &
restriction of
blood circulation

Specification

Tech Notes

Age: Babywear

Baby bootees and garments with integral feet, all over-runs of seams must be at
the back of the foot

Age: Under 3 years

Floats Leg
1.0cm
Nil

Float Foot
1.0cm
Nil

Floats
1.0cm
Nil

Long Ends
2.5cm
Nil

Long Ends
2.5cm
Nil

Toe Seam
1.0cm
Nil

An untrimmed thread end, attached at one side.

Products must be examined inside and out to ensure no

threads or floats are left inside.
Coverage of floats where technically possible for
example in mittens, it is recommended to line the side of
the product where the floats are exposed, to minimise the
risk of catchment in wear
In knitwear & specifically jacquard designs, floats above
the specified tolerance must be discussed with the
departmental technologist to eliminate risk.
Refer to beads, direct motifs and sequins for sewing float
guidelines.

Gloves Babies 0 to Age 3

Floats and Long Ends
Design Standards
Manufacturing tolerance

Knitwear Babies 0 to Age 3

Floats and Long Ends
Design Standards
Manufacturing tolerance

Floats Main
Body
2.0cm
Nil

Floats - Sleeves
& Legs
1.0cm
Nil

Knitwear

Age: 3 years and Above

Hosiery Children Age 3 Upwards
Floats and Long Ends
Design Standards
Manufacturing tolerance

Floats Leg

Float Foot

Long Ends

Toe Seam

2.5cm
1.5cm

2.5cm
Nil

3.0cm
1.0cm

1.0cm
Nil

Gloves Children Age 3 Upwards

Floats and Long Ends
Design Standards
Manufacturing tolerance

Floats
2.5cm
Nil

Long Ends
3.0cm
1.0cml

Knitwear Children Age 3 Upwards

Floats and Long Ends
Design Standards
Manufacturing tolerance

A thread, which is attached at both ends & lies on the

surface of a fabric, forming a loop

Long End:

Hosiery Babies 0 to Age 3

Floats and Long Ends
Design Standards
Manufacturing tolerance

Float:

Floats Main
Body
2.5cm
1.5cm

Floats - Sleeves
& Legs
2.5cm
Nil

Colour changes on stripe panel may result in vertical loops

at the panels edge. If these are longer than the specified
float length, they must be trimmed in line with Marks and
Spencers quality requirements.

No.

17

Category

Hoods and
Headwear

Potential Hazard

Burns
Entrapment
Strangulation
Suffocation
Restriction of hearing
Restriction of sight

Specification
Age: All Ages
Hoods & Headwear

Please refer to Cords & Drawstrings section and Appendix

Wadded hoods must be assessed for flammability P142.
Hoods should be designed to minimise the risk of entrapment.
Headwear should be designed to minimise any restriction of hearing
or vision by the wearer.

Hat / Cap Functional Ties

A quick release mechanism such as a press fastening or touch and

close fastening such as Velcro is required for under-chin closures.

Hat / Cap Decorative Ties

Strings from hat area need to be individually Risk Assessed as a

potential strangulation hazard if long enough to tie.

Dress Up Headwear:

Refer to Dress Up section for flammability requirements EN 71 part 2

Age: 12 Months and Under

Daywear Hoods

Rain coats for infants with hoods must be assessed on a case by case
basis for suffocation.
Hoods must be assessed for Air Permeability Either (1) Air
permeability BSEN IS0 9327 and achieve result of greater than 10
litres of air, submitted at technical evaluation stage.
Or (2) Suffocation Hazard Assessment Intertek RAM Test Method

Age: 3 years and Under

Nightwear Hoods:

Hoods are not permitted on garments designed for sleeping.

Tech Notes

Construction of any closures must avoid irritation to the skin.

When designing Baby Headwear ensure consideration is
taken of softness of babies heads
Increasing the thickness and bending stiffness of the hood
material can reduce the suffocation hazard.
Linings can help reduce the risk of the fabric conforming to
the face and therefore resulting suffocation
Plastic inserts to stiffen the peak, should have round corners
for comfort.
Suffocation Hazard Assessment test may be required. This
can only be carried at ITS Chicago USA. In this case please,
refer to department technologist for advice.

No.

Category

18

Hooks and Eyes and

Hooks and Bars

Potential Hazard

Specification
Age: All Ages

Choking
Ingestion
Inhalation
Insertion
Laceration
Toxicity - chemical

Please refer to TTF / Pull Test Appendix

Age: Under 4 years

Hooks and Eyes and Hooks and Bars are not permitted.

Tech Notes

No.

Category

19

Lace crochet
open
constructions

Specification

Potential Hazard

Entrapment
Laceration
Tourniquet
Toxicity -chemical

Age: All Ages

All Laces & Crochet

Lace on any nightwear must comply with relevant Nightwear

(Safety) Regulations. See Flammability Nightwear section of
this document.

(Note: Cellulosics generally do not meet the regulations.)

Age: 12 Months and Under

Monofilament yarns not permitted

Nightwear

Tech Notes

Due to the size of Babies fingers Crochet and lace stitch

knitwear hole size to be
Under 7.0mm
or over 12mm in diameter

Lace containing metalised fibres e.g. lurex can be an irritant when in

direct contact with the skin ensure a soft version is used and it is
checked through wearer trial
Free and released Formaldehyde must meet C99 standards C18 B & C
Rigid Laces can affect stretch when applied to knitted fabrics - Ensure
Neck stretch is checked and cuff movement is assessed

No.

Category

20

LED Lights (Light

Emitting Diode)

Potential Hazard
Damage to eyesight

Specification

Age: All Ages

Obtain specification from supplier to confirm the class of LED; this

determines the strength of the beam to prevent any potential damage
to eyes (Only Class 1 LEDs are permitted in childrens clothes, shoes
or toys.

Test to BS EN 60825 pt1. Safety of Laser Products.

Refer to the front section of this manual for generic standard

requirements.

Tech Notes

Valid Certification required verifying Class 1.

It is good practice to ensure that LEDs are tested in position
within the product to take account of any lenses, covers or
filters which may affect the strength of light emitted.
Warning text in respect of LEDs is not required for Class 1.

No.

Category

21

Liquid Filled
Products (e.g.
Badges/ Teethers)

Specification

Potential Hazard
Choking
Laceration
Toxicity Microbiological

Age: All Ages

New reports required if composition of contents change.

Toxicological assessment on liquid formulation required. The

assessment must not show any Hazard.

Water treatment plant to be audited to ensure microbiologically

safe by a qualified microbiologist.

Audit process and controls documentation to be recorded and

retained by the factory i.e. checks on purification.

Batch microbiological testing required frequency to be agreed with

M&S department technologist and is dependant on batch size/
quantities.

CAS/ EINECIS number/ listing to be recorded in technical file.

All liquid filled products must be traceable to batch production

records.

Factory cleanliness is key to prevent cross contamination of the

liquid and must be demonstrated to M&S Regional Office
Technology team.

Age: Under 4 Years

Acceptable if passes:

Bite and tear test ASTM F963 -03.

If smaller than the 1.5 gauge, must pass TTF P115B.

Tech Notes

Please refer to TTF / Pull Test Appendix

Safety data sheet must be completed and submitted prior to
contract seal.
MSDS (Material Safety Data Sheet) to be uploaded onto
Contracts.COM (CMS) and retained in product technical file.
Random checks on each process batch required.
Checks on purification system to be performed and recorded
daily.
Min 3yrs planned maintenance to be in place for purification
system.
Toxicity test on liquid to be completed on an annual basis.
The security of enclosure to which liquid is contained should be
designed to prevent possible leakage and avoid potential
customer complaints over perceived hazard of ingestion (consider
seam strength/ edge sharpness/ product integrity).

No.

22

Category

Magnets

Potential Hazard

Aspiration/ Inhalation
Choking
Ingestion
Insertion

Specification

Tech Notes

CLOTHING FOOTWEAR & ACCESSORIES

Magnets are NOT permitted
TOYS / NON CLOTHING ADD ONS
Age: All Ages

No loose Neodymium or similar strong magnets are to be used which

can fit entirely within the small parts cylinder as specified under EN71
pt1.

Magnets must be completely enclosed or embedded within the toy or

garment.

Must be designed to avoid the heart/ chest area when worn.

Suitable in-line production checks should be agreed to check security

of attachment. Records to be recorded and made available upon
request.

Magnets retained by glue or ultra-sonic welding are not allowed unless

retained by a secondary method.

Torque and tension, drop and impact tests required as per EN71 pt1.
Please note: amendments to EN71 due 2009 will include requirements
for magnets which will need to be adhered to.

TTF testing required.

Age: Under 4 Years

Magnets not permitted.

Childrens Shoes containing magnets are excluded from the above rule
provided an appropriate risk assessment has been completed by a
qualified person.

Magnets have become increasingly powerful and now pose a

higher risk of serious accidents than in the past. When more than
one magnet is swallowed, the magnets can attract each other
and may cause intestinal perforation, infection or blockage,
which can be fatal. Inhalation of magnets can also cause serious
injuries, and aspiration into the lungs requires immediate
surgery.
A strong magnet can affect the performance of a pacemaker or a
defibrillator, so strength must be determined as the minimum
required for functionality and agreed with department
technologist at development stage.
Determine the strength, or Gauss (G), of the magnet, and ensure
it is kept to a minimum.
Note that the strength of a magnetic field is measured in units of
Gauss (G).
Ensure warning placed on garment giving caregivers awareness
of potential hazard to consumers with pacemakers or
defibrillators.
Enclosed magnet warning Warning: Magnets have been safely
enclosed within this product. In the event of the product
becoming damaged and the magnets being released, ensure that
the product and magnets are disposed of safely to avoid
potential serious injury.

No.

Category

23

Metal components Press fasteners

Stud buttons,
Rivets,
Eyelets,
Strap adjusters.

Potential Hazard

Specification

Choking
Ingestion
Inhalation
Insertion
Laceration
Projection
Toxicity - chemical

Age: All Ages

PRODUCT REQUIREMENTS:

For metal fasteners and eyelets the gauge of the brass strip must be
minimum 0.37mm on the drawn barrel.

Prong fasteners rings must be made from brass, and a minimum strip
thickness of 0.5mm. This reduces the risk of the prongs cracking.

Steel must not be used as it can rust.

Refer to Migration of Toxic Elements section

Must be free of rough edges.

Roll setting eyelets (as opposed to split setting eyelets) must be used on
all products.

When sourcing components refer to approved component list.

APPLICATION:

For stud buttons, woven fabrics should be pre-punched, and knitted

fabrics should be bodge (this avoids the separation of yarns) pierced
to ensure successful application.
Must not be applied to uneven surfaces. E.g. half on half off the seam

allowance.

Knitted fabrics; use prong fasteners to prevent laddering. Post fasteners

must not be used on knitted fabrics.
In Line checking:

Check the machine has set up in accordance with the pinch testing and
this should be done every two hours

Pull Tests to be carried out every two hours

A manual check must be carried out on every garment to confirm that

the popper prongs have all been pierced into the base fabric and
none are left protruding (See Figure 1)

All garments with feet / pockets or other areas where poppers could be
found need to be turned inside out to check that no loose objects are
trapped inside.

Technical notes
PLEASE REFER to TTF / Pull Test Appendix
REFER TO INLINE TESTING PROCEDURES
Figure 1:
FRONT

BACK

9
X
Prongs bent back can be
sharp. Not acceptable

MACHINERY:
Machine operators must be trained and certified by the
component supplier.

Manufacturers compatible dies must be used.

Pinch settings and machine sign off must be obtained from the
component supplier.

TTF/ P115a must be passed before production starts.

Where possible Fully Automatic Machinery is preferred

Manually operated machinery which solely is reliant on the

operators foot or hand pressure is not acceptable.

Semi automatic manually foot or hand operated machinery

allowed provided that it incorporates a non return ratchet
mechanism. This ensures the required level of pressure is
applied. It must be regulated to ensure machine stops if
pressure falls below required level for operation.

Fully automatic machinery is allowed provided that it is

regulated to ensure machine stops if pressure falls below
required level for operation.

No.

Category

23

(Cont)
Metal components Press fasteners
Stud buttons,
Rivets,
Eyelets,
Strap adjusters

Potential Hazard
(Cont)
Choking
Ingestion
Inhalation
Insertion
Laceration
Projection
Toxicity - chemical

Specification
Age: Under 4 Years

Rhinestones only permitted if fully encased in component (See Figure

2)

Rivets must be chosen that can be tested for TFF P115C. Any
exceptions to this must be agreed by the department Technologist prior
to purchase.

Brace clips and strap adjusters for straps must be one piece welded
(See figure 3)

Technical notes
Figure 2:

Rhinestone is enclosed in
metal and held by metal
ridge

Figure 3:

Fully welded, one piece metal.

Application notes:
Some fabrics may need reinforcing to attach metal components
securely. For example, knitted fabrics require woven bias cut
interlining to stabilise the base.

No.

Category

24

Migration of Toxic
Elements

Potential Hazard
Toxicity - Chemical

Specification

Tech Notes

Age: All Ages

< Less than

Migration of Toxic Elements:

Metal componentry - Test as EN71 and apply our standards

Fabrics ,Tanneries, Print Houses and Laundries

Must comply to M&S C99 requirements

Chrome in all Leather products

Chrome is present in most tanned leathers
Chrome vi is banned
Chrome iii is permitted

Silica Gel has been shown to occasionally contain DMF. Silica

Gel sachets are prohibited in any kidswear products.

Toys

Must comply to EN71 part 3 & 9

Metal componentry

Must comply to the following levels:

Antimony ( Sb)
Arsenic
(AS)
Barium
(Ba)
Cadmium (Cd)
Chromium (Cr)
Lead
(Pb)
Mercury (Hg)
Selenium (Se)

< 60ppm
< 25ppm
< 500ppm
< 50ppm
< 25ppm
< 10ppm
< 40ppm
< 400ppm

Nickel Free

All our metal componentry, regardless of contact with the skin, must
be specified Nickel Free and must pass EN 1811 Nickel requirements
Leather

Must comply to C99

Dimethyl Fumarate (DMF)

This is a fungicide used to prevent mold forming in leather

DMF is banned from use in all Kidswear products

No.
25

Category
Natural Materials
for Accessories &
componentry

Potential Hazard
Laceration

Specification
Age: Under 4 years
Natural products can vary in strength and can split.
Due to the nature of these products the following raw materials Must
Not be used:
Wood
Coconut
Mother of Pearl
Shells
Age: 4 years and above
Discuss material with Dept Technologist prior to purchase.

Tech Notes

No.
26

Category
Necklaces

Potential Hazard
Laceration

Specification
Age: Under 3 years
Not permitted

Tech Notes

Oval jump rings are preferred with split at the top

Diag:

Age: 3 years and above

Necklaces must have loose jump rings (split rings).
Break Strength max 2.5N

For quality purposes break strength should be higher than

2.0N

No.
27

Category
Neck Stretch

Potential Hazard
General Distress
Laceration

Specification
The following requirements are to be adhered to:
Age
Minimum neck
stretch
0- 24months
56cm
14m -10years
58cm
10yrs - 14yrs
60cm
over 14 years
62cm

Tech Notes

Perspex templates are available to test samples and end of line

contact RO

No.
28

Category
Neck Ties

Potential Hazard
Strangulation

Specification
Age: 5 Years and Under

Conventional neck ties are not suitable for children under the age of
5 years.

Clip on, or touch and close fastenings, e.g. Velcro, to be used for
neckties for children 5 years or under. (as Figure 1b)

Touch and close fastenings should be quick release to aid this the
hook side should be cut shorter than the loop side.

A low strength touch and close fastening is recommended.

Touch and close fastening edges should be rounded off to eliminate

sharp edges and corners.
Age: Over 5 Years
Traditional neck ties permitted (as Figure 1a)
Garments should be labeled Not suitable for under 5 years

Method of attachment
Figure 1:
a)

b)

One piece tie

Touch and close

fastener required at
centre back neck

No.

Category

29

Plastic bags e.g.

over bags intended
for sale with the
product in M&S
Stores

Potential Hazard
Suffocation

Specification

Thickness of permanent polyester bags to be greater than 38.0

microns.
Bags made of flexible plastic with an opening perimeter of greater
than 350mm must not have a drawstring or cord as a means of
closing
New products which require plastic bag packaging when in store
should be developed in consultation with the departmental
technologist & packaging developer.

Tech Notes

Appropriate warnings to be applied depending on end use.

Please refer to GM Terms & Conditions for transit packaging
including overbags.

No.
30

Category
Pom-Poms /
Bobbles / Tassels
and Fringing

Potential Hazard

Choking
Entrapment
Ingestion
Inhalation
Insertion
Strangulation
Tourniquet

Specification

Please refer to Cords & Drawstring appendix

Please refer to TTF / Pull Test Appendix
All types of Pom Poms must be risk assessed for entrapment and
strangulation

Tech Notes

PLEASE REFER to TTF / Pull Test Appendix

Figure 1

Figure.2

Traditional Pom Poms (see figure 1)

Age: Over 4 Years
Traditional Pom Poms are allowed
Age: Under 4 Years
No Traditional Pom Poms
Other Pom Poms -Stuffed (figure 2) / Fabric Strips
Age: All Ages
Fringing length to be agreed with Departmental Technologist to
individually Risk Assess but Note length should never exceed 14cm.
Age: Under 4 Years
Small soft decorative pom-poms (as Figure 2 not traditional type as
figure1) directly attached, are allowed, provided P115B requirements are
met.
Large Stuffed Pom Poms / bobbles on a string must:
(1) If soft and squashable meet 50cc plush criteria, or
(2) If round and hard meet the 44.0mm gauge.

And therefore not require TTF Testing for Safety

Tassels and Fringing
Age: Under 4 Years

Like Pom-Poms, threads can be removed if pulled. These products are

only suitable for use if it is possible to produce them with threads that
are not removable and they meet the requirements of P115B.

When used, pom-poms must be attached by means of a 4

hole lockstitch button sew attach, and thread ends must not
be able to be pulled out.
Pom Poms can be lock stitched at the centre position during
construction for extra security
The attachment of Pom Poms, tassels etc must not cause a
potential entrapment hazard, for example when attached as
an embellishment to a decorative or functional cord. Please
refer to BS EN14682

No.
31

Category
Prints (transfers,
panel prints, all
over continuous
prints includes
backing materials)

Potential Hazard

Choking hazard
prints peeling off
Toxicity - Chemical

Specification
Age: All Ages

All inks and backing materials should be PVC free where

technically and commercially viable any exceptions to be
discussed with Departmental Technologist at development
stage.

Phthalates & APEOs are not permitted according to C99.

Print house and all printing inks and binders used need to
conform to M&S C99 requirements

Some printing methods can leave a residue of formaldehyde on

the fabric. Ultra-low formaldehyde binders should always be
used.

No Formaldehyde is permitted in Babywear or Intimate apparel

Solvent-free printing systems should be used wherever possible

and no residual solvent must remain on the garment

Plastisol prints covering a large area of the garment can cause

issues with flammability - refer to Flammability of nightwear
section for more details

Transfer prints should be applied according to the manufacturers

recommendations and transfer press calibrated and checked
regularly to ensure optimum fusing conditions

Technical Notes

Test for Qualitative determination of PVC - C64

QUALITATIVE (BELSTEIN TEST) then/or FTIR for confirmation
(Fourier Transform Infa-Red Spectroscopy)
Test for determination of Phthalates - C61 Solvent Extraction
and GCMS (Gas Chromatography/Mass Spectrometry)
Durability test on transfer prints should be carried out during
production to ensure there is no peeling or cracking on the
surface.
Transfer prints applied to pile fabrics i.e. Velour should be
assessed to P5 at product development stage

No.

Category

32

Rouleau Loops

Potential Hazard

Entrapment
Tourniquet

Specification

Age: All Ages

Rouleau Loops
To avoid entrapment, the loop should have an opening length
measured as circumference. Maximum 7cm.

Tech Notes

No.

Product category

33

Safe in the Sun

Garments and Hats

Potential Hazard
Burn

Specification
Age: All Ages
Garment styling: Garments for the top half of the body must fit from
the nape of the neck down to at least the hip level, and the arms
covered to 3/4 of the upper arm below the elbow. Bottoms must
cover from waist to sit below knee bone.
Testing

Fabrics and garments needs to comply with BS EN 13758 parts 1&2.

Hats need to comply with BS 8466 (2006).

At development stage all prints and colour ways need to be tested to

BSEN13758 part 1 and comply with BSEN13758 part 2. I.e. to pass
the fabric results must show UVPF values larger than 40, and the
average UV-A transmission to be less than 5%.

At bulk garment stage every stroke number must be tested

independently to ensure compliance with BSEN 13758:2.

Tech Notes
Labeling

All safe in the sun product must have permanent wording on

the care label for the garment AND hat, even if sold together.

Suit care labels need to have the reference; 'conforms to

EN13758-2 2003 UPF40+' in addition to 'KEEP AWAY FROM
FIRE' and care code ref TC16 B.

Hat care labels must have the reference; 'this hat conforms to
BS8466' in addition to 'KEEP AWAY FROM FIRE' and care
code ref TC16 B.

No.

34

Category

Scarves

Potential Hazard

Entrapment
Strangulation

Specification

Under 18 Months

No traditional Scarves Permitted

A Safe Scarf that can not be tied around the neck and is fastened
with Velcro is permitted at the following lengths:
6-12 Months
A Safe Scarf construction permitted with max length 45cm
12 18 Months
A Safe Scarf construction permitted with max length 50cm
Touch and close fastening edges should be rounded off to eliminate
sharp edges and corners.

Over 18 Months

The following Maximum Length requirements are to be adhered to:

18 Months 4 Years
60cm
4-6 Years
90cm
6-8 Years
100cm
8-10 Years
125cm
10-12 Years
140cm
12-14 Years
155cm

Tech Notes

The maximum lengths must include any tassels or

attachments at the end of the scarf.
Tassels should not exceed 14cm
Pockets are allowed on scarves as long as a risk assessment
has been carried out. Only patch pockets should be applied
reduce the entrapment risk.

No.
35

Category
Sequins

Potential Hazard

Aspiration
Choking,
Ingestion
Inhalation
Insertion
Laceration
Skin Irritation.
Toxicity - Chemical

Specification
Age: All Ages
Sequins must not have sharp, rough edges or burrs.
Must be free of mould flash
Sequins must be Phthalate and APEO free e.g. made of Polyester
Age: Under 4 years
Machine attach only
Maximum Diameter 5mm
Sequins must be round, flat and with smooth edges, and have a
centre punched hole.
Strip sequins on a string not allowed
Age: 4 years and Above
Hand applied sequins are permissible if application guidelines are
followed.
Shaped sequins such as stars, must have smooth edges
Strips of sequins to be attached by lockstitch machine bar tack start
and finish.

Tech Notes

P5 Durability wash must be carried out before contract seal.

No Spare sequins to be supplied with the garment

Machine attach Sequins:

Thread: Monofilament of a minimum of 80denier may be used
to keep lustre of the sequin, but if used must be used in
combination with a fusing backing to avoid direct contact with
skin.
Stitching must be secure to ensure that none of the
monofilament comes unraveled by carrying out a D wash at
first production and carried out weekly during production.
These records must be kept.
Stitch Type: Lockstitch
Attachment:
Age: Under 4 Years - 4 double stitch formation passing through
the centre of the sequin
Age: 4 Years and Above Any stitch formation permitted
Hand Attach Sequins Age 4 years and Above
Thread: Embroidery/General sewing thread ticket 120.
If applied singly, double knot off after each sequin
If attached in a group - knot off every third sequin
Knot off knot thread and cut off
At Start:
Double knot 2 strands of thread together, stitch through fabric
to form a small stitch prior to applying bead.
To finish:
Stitch through and double stitch finish and knot
Thread length start and finish to be 3mm to 5mm.
Float length maximum of 1cm, length after cutting 0.5cm to
1cm.
Strips of Sequins:
The stitch run where possible, must start and finish in a seam
True Knitwear
Must be attached with Embroidery / general sewing thread.
(as monofilament will cut the yarn)
If applied to neck area neck stretch must be unaffected.

No.
36

Category
Silica Gel

Potential Risk

Choking
Toxicity - Chemical

Specification
Silica Gel is banned in Kidswear

Tech Notes

Silica Gel is primarily used in moisture re-movement in transit

No.
37

Category
Sleep Bags - for
use in a cot

Potential Risk

Entrapment
Flammability
Over Heating

Specification

Flammability must conform to BS EN 14878

M&S max Tog requirement Tog 3.5 tested to BS 5335 as defined in
BS 8510
To ensure no Entrapment of body into the bag
Up to 6 months - neck opening must be between 280 320mm
6 months upwards - neck opening must be 355 395mm
Dimensional Stability Length and width change must not exceed +/5% when tested to care label instructions
Label requirements - compliance to BS 8510:2009 must be displayed
on the permanent care label

Tech Notes

Specific Instruction need to be displayed on the Swing Ticket

this must be signed off by the Departmental Technologist

No.
38

Category
Sound Nodules/
Noise Levels

Potential Hazard
Damage to hearing

Specification
Age: All Ages

Must comply with acoustic requirements in EN71 part 1.

Must comply with Electro Magnetic Compatibility (EMC) regs.

Refer also to Battery Operated Components section in this

document for compatibility & labeling
Age: Under 4 years

Allowed in this age group provided they are permanently attached

and are inaccessible

Tech Notes

Certification of compliance to EN71 part 1 (clause 4.20

Acoustics).
Use an appropriate warning: Do not place close to the ear,
misuse may damage hearing.
D wash to be submitted at contract seals stage
Product to be CE marked for EMC

No.
39

Category
Swim Short Mesh
Liner Fabric for
Boys

Potential Hazard
Entrapment
Laceration

Specification

Technical Notes

Age: All Ages

Holes in mesh need to be smaller than 1.5mm in diameter to avoid

entrapment of skin.

Mesh fabric to be soft handle. Agreement of handle should be gained

from the M+S Departmental Fabric Technologist.

Avoiding skin entrapment is a new requirement into BS 7907

No.
40

Category
Toys

Potential Hazard

ALL

Specification
Age: All Ages

Must comply with EN 71 parts 1 to 11 as required.

Must comply with all other relevant standards see this document.

Refer to relevant Toy Standards in Home Safety Manual on Quality

Standards website.

Tech Notes

Consult with relevant M&S Technologist for any add on

products, give-always, soft toys, key rings or other child
appealing items.
Please refer to TTF / Pull Test Appendix

Pens Writing and Marking Instruments

Sufficient ventilation must be allowed in pen tops ,closures
and caps to avoid asphyxiation refer to BS 7272 part 1&2

Ensure appropriate warnings as specified in EN71 parts 1,2,3

inc. age specific warnings.
Refer to M&S approved standard warnings for toys
Note: EN71 testing requirements are different for under 3s
and over 3s age group. Ensure testing is performed
appropriate to the intended age group. If the item is intended
for over 3s but you feel it may appeal to under 3s then test
to under 3s as a precaution and consult with relevant toy
technologist.
Note: M&S small parts criteria differs from those specified in
EN71, refer to Toy standards in the Homeware Safety Manual.
Small parts must meet M&S gauge criteria unless agreed with
M&S toy Technologist in exceptional circumstances.

Labeling

All Toys must be tested to the relevant sections of EN71

and CE labelled in accordance with EN71 part 6

Those Toys not suitable for Under 3 Years must carry an

additional warning to state this

No.
41

Category
Waddings and
Quilted Waddings
Inc Feather & Down

Potential Hazard

Laceration
Projection
Suffocation
Toxicity Chemical
Toxicity - Pathogen.
(Refer to animal
infestation policy.

Specification
Age: All Ages

Synthetic Wadding must be made from 100% low melt polyester.

This includes silicon finished polyester balls.

Resin treated waddings not permitted.

Nightwear garments must comply with Nightwear (Safety)

Regulations. 1985.
Age: 12 months and under

Feather and Down are not to be used in this age group due to
potential over heating
Wadded Hoods

Garments with wadded hoods for infants must be assessed on a case

by case basis for suffocation.

Hoods must be assessed for Air Permeability Either (1) Air

permeability BSENISO 9327 and achieve result of greater than 10
litres of air, submitted at technical evaluation stage.
Or (2) Suffocation Hazard Assessment Intertek RAM Test Method
Age: Under 4 years

No quill to be used in any Feather and Down

Tech Notes
Testing

Waddings in Nightwear to be assessed and evaluated for tog

rating BS 4745 at development stage.

Baby sleep bags see section 37

C18 B & C: Determination of free and released

Formaldehyde, submitted at technical evaluation stage.
Migration of fibre from wadding must pass P5 test.

To prevent fibre migration; wadding can be heat bonded,

outer fabrics can be chintzed on the inner surface or a scrim
can be used on the wadding.

Seams must have sufficient bite in order to reduce seam

failure and the exposure of fillings.

We recommend that Silicon finished Polyester Balls are

double bagged to prevent migration.

Suffocation Hazard Assessment test may be required. This

can only be carried at ITS Chicago USA. In this case please,
refer to department technologist for advice.
Feathers and Down

Feather and down must be thoroughly washed and suitably

processed to the British hygiene and cleanliness requirements
E.g. steam cleaned.
Also to be double bagged to prevent migration.

Please refer to the Animal welfare policy for down wadding

on quality standard website

No.
42

Potential Hazard

Category
Washed Garments that use Stones or
Sand.

Choking hazard
Ingestion
Inhalation
Insertion

Specification

Tech Notes

Age: All Ages

Sand must be free from aluminum chips to ensure that metal

detection is possible.

Where there are attached components TTF must be tested after

garment washing

If mock ups are used to test componentry , they must be washed

All ages

Apply all componentry after washing.

Adequate rinse cycles must be used to remove/neutralise

residual chemicals including wash chemicals and enzymes.

Ensure for all chemicals used C99 is adhered to. Ensure Safety
data sheets are available.

Age: Under 4 Years

Sand or Stones not permitted on garments with any pockets or areas

where stones/Sand can be entrapped.

4 Years and Above

Where stones and sand are used all pockets must be tacked
closed before washing, and all garments 100% inspected for
loose stones and/or sand.

No

Category

43

Zips

Potential Hazard

Choking
Inhalation
Injection
Insertion
Laceration
Penile entrapment
Toxicity - chemical

Specification
Age: All Ages
Zip supplier must be informed that it is an M&S Kidswear order

Must be free of rough edges.

Decorative pullers should be risk assessed, and where appropriate a design hazard assessment
conducted.

Polyester zip tapes should be used for greater strength.

Zip puller length refer to Cords and Drawstring appendix

Zips must be manufactured to set lengths. Continuous rolls of nylon coil zips not acceptable.

Please refer to TTF / Pull Test Appendix

Top and bottom stops

Must not be claw type. Fig 2 (see technical notes)

D Stops, and injection molded or welded top stops, must be used.

Cut coil ends must not protrude above the top stop.

Open end zips must have a top stop to retain the slider.
Age: Under 4 years

Metal Zips not allowed.

No metal top stops

Bottom stop can be metal provided they are H type

Sliders and pullers can be metal, provided they meet the criteria in ALL section above.

Plastic molded zips preferred.

Coil zips only allowed when zip will not be in direct contact with the body.

Zip guards to be used to avoid entrapment when zipper is directly in contact with skin
especially in the neck area

Ideally Zip puller should be Direct Attachment (one-piece) Pullers. Any Indirect Attachment
(two-piece) Pullers MUST be TTF tested and Zip supplier to confirm suitability for M&S
Kidswear production before order placed

TTF (P115b) on zip puller submitted at contract seal stages - this test is carried out by the zip
manufacturer.

Material or add-on pullers TTF (P115b) required, this is to be carried out by the garment
manufacturer. This is in addition to the zip puller TTF above.

Wadded fabric zip pullers need to be double bagged and assessed by the departmental
technologist at development stage.
BOYS FLY OPENINGS
Age: 5 Years and Under

Functioning zips on boys fly openings are not allowed.

Mock openings with an elasticated waistband, press stud, or button flys should be used as
alternatives. (Code of practice requirement BS7907)
Age: 6 Years and Above

When allowed, zips can be made of metal however zips with plastic elements reduce the risk of
entrapment.

Where metal zips are used for ages 6 years and above, they must be designed with an inner flap
at least 2.0cm wide, and secured by stitching across the base of the fly opening.

Technical notes
Figure 1

Claw type top and bottom stops.

Claw stop must be replaced by an H block bottom stop.

Figure 2

Testing:
Zip manufacturer to carry out CS13 test on each type of
zip supplied. (BS 3804:2006)
Figure 2

Metal

Coil

Plastic
molded