Compliance testing for toys is a complex area and it is the final product (the painted, decorated, assembled product) that needs to be CE marked to show it is compliant. I’m afraid I can’t advise on it but here are some pointers.
Little Brown Dog Workshop sells unpainted wooden peg dolls and shapes as craft parts and not as toys.
As lots of customers want to use wooden parts to make toys, we are adding extra information to help you choose the product that is right for you. We are starting to have testing done on some of our products according to EN71 toy safety standards.
You can be sure our parts that are EN71 compliant are suitable for making toys, but that doesn't automatically make them a finished toy or mean they are eligible for CE marking. For the shapes to become toys they need to be decorated and finished, and it is this completed toy that needs to demonstrate compliance and be CE marked. What they are decorated, dressed, painted and sealed with is just as important and the maker of the finished toy needs to demonstrate that all these elements comply. There's a detailed process of testing, reporting, demonstrating conformity and marking to be dealt with before that completed item can be called a toy.
EN71 compliance testing is expensive, and so we're not testing all our parts. If there's no test, it doesn't mean the part is not suitable for toy makers, it just means we haven't done the first stage of testing for you.
A bit more detail and some websites to help you:
CE marking is a declaration of conformity with all the legal requirements to achieve CE marking https://www.gov.uk/guidance/ce-marking
Obviously to have a product that conforms, you need to have parts that are suitable and to assemble, decorate, finish, label and package in an appropriate way. You need to be able to demonstrate your compliance.
Part of demonstrating compliance is keeping records to show what you have used, how you have put it together, and how you have tested it. You need to keep batch records as well, as you continue to make repeats of your items.
Part of testing is to show your product is compliant with the EU Toy Safety Directive. In the UK this is mainly done using tests under British Standard EN71 parts 1, 2 and 3 but other standards may apply depending on your product.
Although testing needs to be done on the final product, three of our shapes - the 9cm man, 8.9cm woman and 6.5cm rounded body figure have been EN71 tested to help toymakers who are selecting parts and putting together their compliance records. Although the final product needs to be shown to be compliant, I have had the shapes tested so that people can see that these will be suitable parts to use for toy making. It is not a requirement for us to test our shapes as they are sold as craft parts not toys. The other craft parts are also fine for making toys but many are not suitable for children under 36 months as they are small parts and could be a choking hazard. There's more info about this here
With careful sourcing of compliant parts and compliant paints and finishes, some toy makers complete the remaining tests themselves and self-certify their compliance. People making large quantities and selling to retailers usually move from self-certification to getting their own laboratory testing done on the final product. Either way, products then need to be marked as compliant.
After doing some preliminary research it would probably be helpful to talk to your local Trading Standards office for advice.
Government website for toy manufacturers https://www.gov.uk/guidance/toy-manufacturers-and-their-responsibilities
You might like to join this group: https://www.facebook.com/groups/cemarkingcommunitylvl/
There is also a sub group specifically for people involved with wooden toys https://www.facebook.com/groups/125356137672409/
Where you can pay to download an information pack that has further information on how to begin putting together compliance information.