“Digitization aspects and consumer requirements in relation to “smart” toys – implementation in standardization. Study by the DIN Consumer Council, Germany

Standards, such as EN 71-1 (safety of toys) and EN 62115 (safety of electric toys), provide manufacturers with instructions for the construction of toys and how certain aspects can be met. Standards also provide consumers with confidence that a toy will be safe if it complies with their requirements. In order to guarantee the safety of new types of toy coming on to the market, it is necessary to consumer requirements in the light of digitisation and the link to standards.

The advancing digitization means that classic, analog toys – such as Dolls – increasingly contain digital components and can also be networked with other devices (or directly with the Internet). As a result, these “smart” toys can be used in addition to the “classic” product core – eg the doll answers specific questions. This development means that new consumer requirements (such as adequate data protection or the security of data connections) arise for “smart” toys. To ensure the safety of toys in the future, an analysis is required.

With this is mind, the Institute for Consumer Policy was commissioned by the DIN Consumer Council to consider a) the new consumer requirements that arise from the digitisation and networking of toys; b) the extent to which these requirements are covered by existing toy standards; c) the possible application of standards from other areas to smart toys; d) the options available to implement these new consumer requirements in standards.

The aim of the study was to categorize “smart” toys and to determine consumer requirements for “smart” toys based on various documents (e.g. position papers from consumer organizations, specifications, standards, guidelines, laws). The next step was to investigate whether and which of these requirements apply specifically to “smart” toys and which generally apply to IoT products. Building on this, the requirements in the relevant standards were compared with the determined consumer requirements for “smart” toys. The study shows that the consumer requirements for “smart” toys are only insufficiently taken into account in the existing standards and therefore makes specific suggestions for necessary additions and or changes to standards.

The results show three overarching findings for the standardisation of smart toys from the consumer’s point of view.

The first is 28 new consumer requirements due to the digitisation of toys. Most of these relate to data protection and the data security of smart toys.

The second is that, in addition to toy standards such as EN 71-1 and EN 62115, standards and specifications for connected devices may also be relevant to smart toys. As part of the study, the specifications ETSI TS 103 645 (Cyber Security for Consumer Internet of Things), DIN SPEC 27072 (IoT devices – Minimum requirements for information security) as the draft ISO 31700 (Consumer Protection – Privacy by Design for Consumer Goods and Services) were identified and examined.

The third is that the comparison of consumer requirements and relevant standards shows a heterogeneous picture regarding the implementation of these requirements in standards.

The three findings result in three recommendations for action.

1. General consumer requirements for connected devices – also relevant to smart toys – should be included in standards for IoT devices. Regarding data security, cooperation within the framework of the new European standard ETSI EN 103 645 is advised;
2. Regarding data protection in standards, it is advisable to participate in the development of ISO 31700 in the ISO/PC 317 committee, focusing on privacy-by-design for connected consumer devices and related services.
3. Specific consumer requirements for smart toys should be reflected in toy standardisation or content introduced in the relevant committees. Another entry point is the IEC 62115 standard on the safety of electrical toys and similar work from IEC/TC 61. Here the scope of the committee and the standard would need to be extended to include electronic and connected toys.

The final report from DIN’s study “Digitization aspects and consumer requirements with regard to smart toys – Implementation in standardization” is now available.

The study can be requested as a PDF file free of charge from the DIN Consumer Council. If you are interested, please send an email to  verbraucherrat@din.de .