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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:

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