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Poland: Scientific paper says laser toy is misclassified, 4x legally required power

A paper published online March 24 2021 describes a laser aiming device on a plastic toy rifle intended for children. It had a red laser and a blue LED. The paper does not state whether there is any type of required laser labeling on the device. However, no laser warning label or classification label is seen in the paper's only photo of the device:

Laser aimer sight toy rifle classification squashed

The paper examined the red laser's output and found it was 1.7 milliwatts. This is four times the Class 1 limit of <0.39 mW, and is 1.7 times the Class 2 limit of <1 mW. The laser should have been classified as Class 3R (<5 mW limit).

The author notes that according to the European standard EN 62115:2020, and guidance from Public Health England, laser toys should be Class 1. At four times the Class 1 limit, this toy's "radiation may be hazardous, especially when looking into the beam for long periods."

From Mlynczak, Jaroslaw. "Laser toys fail to comply with safety standards – case study based on laser product classification" Advanced Optical Technologies , no. (2021). https://doi.org/10.1515/aot-2020-0072


We do not dispute Mlynczak's technical findings. However, there are some misleading or false statements in the paper that we would like to address.

  • An erroneous title; it should be "Laser toy fails to comply…" The case study is not about "toys" plural. It covers only one sample of one toy rifle which had a laser aiming device that was found to be misclassified.
  • Stating that the toy laser's output power (1.7 mW) is illegal, when it may have been legal or close to legal (within 0.7 mW) at time of sale.
  • Calling the laser's light output "radiation" 14 times and never using the more precise term "light," thus giving a misleading impression the hazard might be similar to that of X-radiation or nuclear radiation.
  • Stating without any proof or reference that children "will usually try to look directly into the laser beam."
  • Stating without any proof or reference that children "could have temporary disturbances of vision… lead[ing] to a tragedy."
  • Stating without any proof or reference that there is such a thing as "hypersensitivity to laser radiation."
  • Stating without any proof or reference that "the described laser toy… [is] easily available and [is] still sold as toys in many European states."
  • Listing in the References studies claiming laser "toy" injuries, which actually were from standard, non-toy laser pointers.

Details are below:

Title of the paper is wrong

The title of the paper begins "Laser toys fail to comply with safety standards…" when in fact just one sample of one toy failed to comply. Mlynczak did not list any other papers or references indicating laser toys are failing to comply — much less that laser toys are being sold.

Two papers listed in the Reference, both by Raoof et. al. titled "'Toy' laser macular burns in children", may seem to be about toys with lasers. But these papers are in fact about injuries from standard laser pointers/laser pens. The fact that a child plays with a laser pointer/pen does not make it a "toy," just as if a child cuts himself with a steak knife, the knife does not become a "toy".

Assertion about toys being sold is unverified and appears wrong

Early in the paper, Mlynczak writes: "Due to the unknown origin of the toy and the lack of any markings, its manufacturer was not identified." To try to find the toy, LaserPointerSafety.com did an internet search using terms such as "laser rifle gun toy children red laser blue LED." We were unable to find any such toys emitting laser light. (We did find a photo of a "Cool BB Toy Gun With Red Laser / Blue Flashlight / Safety Glasses / Black" first indexed nine years ago from Deal Extreme. Clicking on the link went to a different rifle shooting soft Nerf-like bullets that has no laser device.)

In the paper's conclusion, Mlynczak contradicts his earlier statement. He writes that "the described laser toy … [is] easily available and [is] still sold as toys [sic] in many European states." However, there is no reference or other proof of the statement about availability. In addition, Mlynczak previously noted he does not know anything about the toy's origin or manufacturer. If he did know it was being sold, he would be able to provide the manufacturer, origin, sales channel or similar information.

Is the toy illegal?

The toy may have been legal or near-legal when it was originally sold. The EN 62115:2020 standard is dated 2020. The Public Health England safety advice document is from 2017 and appears to be guidance — not legally restricting a sale.

If at the time of sale, it was legal to sell a Class 2 laser product, then the red gun laser was 0.7 mW over the <1 mW Class 2 limit. This would be illegal, but would not be a significant eye hazard increase. If it was legal to sell a Class 3R laser product, then the red gun laser was well within the limit (<5 mW).

The paper does not indicate how old the gun might be.

Misleading "radiation" hazard

Fourteen times the paper refers to the gun device output as "laser radiation." The output is never called "laser light."

However, the lay reader is not made aware that this "radiation" is simply visible light, in the same wavelength range as the sun, lightbulbs, flashlights, etc. While technically light is "radiation," it does not cause cellular changes or mutations in the same way as what the layperson would ordinarily consider "radiation": high-energy X-rays or nuclear radiation.

Referring to laser light as laser "radiation" makes it appear more hazardous to a layperson.

Correct classification

Mlynczak is correct that a red gun laser with 1.7 mW output would be four times the Class 1 limit. He is correct that the European standard and Public Health England say or imply that lasers for children should be Class 1. This is because Class 1 is so weak (<0.39 mW) that it is not expected to harm a person's eye even if they stare into the laser light.

Mlynczak is correct that the red gun laser is 0.7 mW over the Class 2 limit which is <1 mW. He is correct that the classification should be Class 3R.

Note that laser pointers in the EU and U.K are permitted up to and including Class 2. In the U.S., laser pointers are permitted up to and including Class 3R. So the red gun laser is 0.7 mW over the laser pointer limit in the EU and U.K., and would be a legal pointer in the U.S.

Is it unsafe?

Leaving aside the illegality of the laser power and classification, is it unsafe?

Mlynczak does point out, correctly, that "the risk of eye injury is relatively low" from the red gun laser. He also mentions studies showing that the red gun laser's power of 1.7 mW "can be scientifically characterized as 'negligible risk' also for intentional exposure over many seconds" (e.g., deliberate staring into the beam)."

But Mlynczak then goes on to claim without any proof or references that children "will usually try to look directly into the laser beam," that they could have temporary disturbances of vision… lead[ing] to a tragedy" and that there is such a thing as "hypersensitivity to laser radiation." Here is more information about these three unverified claims:

  • Will children usually look directly into the laser? This might be true for some children, but how many (what percentage)? And how many will go on to stare multiple times, for multiple seconds? There are certainly cases in the literature of children — often teens — staring into laser beams for visual effects. But what proportion of all children with access to laser pointers does this represent? No one knows. So Mlynczak's statement is really just his opinion.

  • Will laser vision disturbance lead to tragedy? What type of activity would a child be doing that could lead to a tragedy if their vision was disturbed? And have these occurred? At LaserPointerSafety.com we have been compiling hundreds of stories of laser misuse in aviation, non-aviation, and elsewhere since 2008. Over that 13-year time span we can recall just one case where a laser caused "temporary disturbances of vision" leading to an accident. (A driver aimed at laser at another a car in traffic, that caused an accident with no injuries.) And this did not involve a child's laser misuse.

  • Is there such a thing as "hypersensitivity to laser radiation?" We have never heard of such a condition. (A brief internet search did turn up information from the Australian government on "Electromagnetic Hypersensitivity" which is related to electromagnetic fields (not laser light as far as we can tell). The authors note that Electromagnetic Hypersensitivity "is not part of any medically recognized syndrome.")

Potential for injury

Because a child could overcome their aversion reflex and deliberately stare into a laser pointer, they should never be given pointers (or this red gun laser) to play with. That is why only Class 1 lasers (safe under all conditions) lasers are allowed for children's toys.

The parents of this child should be concerned about potential misuse. They should of course take the laser device away from the child.

But the parents should not be unduly worried about eye injuries. They should actually be more worried about the gun itself causing an injury.

In the ten years from 2011 to 2020, it is estimated that there were nearly 18,000 visits to emergency rooms in the U.S. involving toy guns or toy weapons, according to the U.S. Consumer Product Safety Commission's "NEISS" survey.

In comparison, during the ten year period from 2008 to 2017, there were 20 emergency room visits caused by eye complaints from laser pointers, and as far as we can tell, no emergency room visits due to toy lasers (data here).

That makes a toy gun about 900 times more hazardous than a laser pointer.


As a whole this paper is severely misleading and flawed. We believe it should be withdrawn and the errors, starting with the first word of the title, should be corrected.

Finally, we have not been able to find many unsafe toys containing lasers, or any reports of an unsafe toy laser causing injury to a person. (There are some stories and papers claiming "toy" laser injuries but as of May 2021, these turn out to be caused by standard general-purpose laser pointers or handheld lasers.)

Laser safety experts and children's toy safety officials should remain vigilant regarding laser-containing toys. But as of May 2021 there appears to be no crisis requiring action.