New EU Toy Safety Regulation: what will change and when?

The European Union has adopted a new Toy Safety Regulation, which will gradually replace Directive 2009/48/EC. Regulation (EU) 2025/2509 of the European Parliament and of the Council entered into force on 1 January 2026, while most of its substantive requirements will apply from 1 August 2030.

Until 31 July 2030, Directive 2009/48/EC therefore remains the principal legislation governing the placing of toys on the EU market. Manufacturers have a transition period of more than four years to prepare their technical documentation, production processes and information systems for the new requirements.

Why was new legislation adopted?

The existing Toy Safety Directive already establishes strict requirements concerning mechanical, physical, chemical, electrical, hygiene and other risks. However, the European Commission identified a need to strengthen restrictions on hazardous chemicals and improve enforcement, particularly for toys sold online or imported from outside the European Union.

Unlike a directive, the new Regulation will apply directly in all EU Member States without requiring transposition into national legislation.

Stricter requirements for hazardous chemicals

One of the most significant changes is the extension of restrictions on hazardous chemical substances. The new rules strengthen the existing prohibition of carcinogenic, mutagenic and reprotoxic substances and extend restrictions to additional groups of chemicals.

Toys will be subject to stronger restrictions concerning substances that:

• disrupt the endocrine system,
• damage the respiratory system,
• cause skin sensitisation,
• cause damage to specific organs,
• belong to the PFAS group,
• are classified as hazardous bisphenols.

The objective is to reduce children’s exposure to substances that may cause long-term health effects.

The stricter requirements may affect plastics, paints, coatings, textiles, adhesives, softened materials and other toy components. Manufacturers will therefore need to exercise greater control over material composition and supplier documentation.

A digital product passport for every toy

Every toy placed on the EU market will be required to have a digital product passport containing information about the product, its manufacturer and compliance with applicable safety requirements.

The passport will be accessible through a QR code or another data carrier placed on the toy, its label or packaging. The information will be available to market surveillance authorities, customs authorities and, to an appropriate extent, consumers.

The digital product passport is intended to improve the control of toys imported into the European Union and products sold through online shops and marketplaces.

It will not replace the conformity assessment, technical documentation or laboratory test reports.

Will CE marking and the EU declaration of conformity remain mandatory?

Yes. Toys will continue to require conformity assessment and CE marking. Before placing a toy on the market, the manufacturer will generally need to:

• carry out a risk analysis and safety assessment,
• arrange testing under the relevant harmonised standards,
• prepare technical documentation,
• issue an EU declaration of conformity,
• provide the manufacturer’s and, where applicable, importer’s details,
• include the required warnings and instructions,
• affix the CE marking.

The manufacturer will remain responsible for the safety and conformity of the toy. The digital product passport will provide a new method of making compliance information available and facilitating its verification.

What happens to toys placed on the market before August 2030?

Toys that comply with Directive 2009/48/EC and are placed on the market before 1 August 2030 may continue to be made available after the new Regulation begins to apply.

EC type-examination certificates issued under the existing Directive will remain valid until 1 February 2031 unless they expire earlier.

The relevant factor will be the date on which the individual toy was first placed on the EU market, rather than only its date of manufacture or subsequent distribution.

What should toy manufacturers begin preparing?

Manufacturers and importers should gradually review:

1. the chemical composition of materials and components,
2. supplier documentation and declarations,
3. the scope of existing test reports,
4. the identification of models and production batches,
5. the availability of information required for the digital product passport,
6. the accuracy of technical documentation and EU declarations of conformity.

Early preparation will be particularly important for products with long development cycles, large product ranges and toys sourced from several manufacturers outside the European Union.

Toy conformity assessment and certification

PRVÁ CERTIFIKAČNÁ provides professional services concerning the conformity assessment of toys. We review technical documentation, determine the necessary scope of testing, provide product certification, review instructions and labelling and prepare EU declarations of conformity.

Our assessment considers the materials used, the intended age group, the foreseeable use of the toy and relevant mechanical, physical, chemical, electrical and other risks.

Products developed in the coming years may remain on the market for a long period. Manufacturers should therefore begin considering the new requirements during product design and material selection rather than waiting until 2030.