EU Toy Safety Regulation (EU) 2025/2509
The shift from a directive to a regulation means the rules apply directly and uniformly across all EU member states without requiring national transposition. This closes inconsistencies in how the previous directive was implemented across different markets.
Until August 1, 2030, toys that comply with Directive 2009/48/EC may continue to be placed on the EU market under the transitional provisions. Both frameworks are in effect during this period.
CE Marking, EN 71 testing and REACH compliance all carry forward under the new Regulation. The primary operational changes are the expanded chemical prohibitions, the Digital Product Passport and the new online marketplace obligations detailed below.
Expanded Chemical Requirements
Regulation (EU) 2025/2509 expands the categories of prohibited substances.
- Prohibited: Intentional use of PFAS in toys
- Broadened the generic ban on hazardous chemicals to prohibit CMR substances, endocrine disruptors, specific target organ toxicity substances, respiratory sensitizers and skin sensitizers
- Expanded age range: Chemical restrictions that previously applied only to toys intended for children under 36 months now cover all toys, regardless of intended age group
Digital Product Passports
- Digital Product Passports replace the EU Declaration of Conformity
- A digital carrier (e.g. QR code) on the toy or packaging provides access to conformity documentation, chemical test reports and production information
- This significant operational change requires supply chain data infrastructure that many companies have not yet built
Online Marketplace Obligations
- The platforms must be designed to display certain information before purchase (CE marking, safety warnings, Digital Product Passport link)
- Platforms are responsible for identifying and removing any non-compliant toys
- Sellers on the marketplace must supply the platform with a digital copy of the required data - with a unique identifier
- Fulfillment services (warehousing, packaging, addressing, dispatch) must maintain the toy's conformity with the safety requirements
