On 12 December 2025, the Official Journal of the European Union published the new EU Toy Safety Regulation (Regulation (EU) 2025/2509). This Regulation will replace Directive 2009/48/EC and will apply from 1 August 2026. Below is a summary of its core content:
Scope of Application
- Applies to all products designed or intended for use in play by children under 14 years of age, regardless of whether playing is the primary function.
- Exempted products: Public playground equipment, toy internal combustion engines, pedal cycles, collectibles for adults, educational scientific apparatus, etc.
Main Revisions
- Legal Form Upgrade: Directive 2009/48/EC is upgraded to a "directly applicable" Regulation, requiring no transposition into national laws.
- Safety Requirements Upgrade:
- Chemical: Prohibition of CMRs (Carcinogenic, Mutagenic or toxic to Reproduction), endocrine disruptors, respiratory sensitisers, PFAS, and 34 bisphenol compounds; migration limits for heavy metals generally halved; addition of combined exposure assessment.
- Digital: Toys connected to the internet must comply with the Cyber Resilience Act, the Artificial Intelligence Act, and data protection requirements.
- Physical: New provisions on sound pressure level limits, risks associated with swallowing magnets, and battery compartment security to prevent access.
Core Safety Requirements
|
Category |
Summary of Requirements |
|
Physical & Mechanical |
Prevention of risks like suffocation, cuts, pinching, falls; stricter size requirements for toys intended for children under 36 months. |
|
Chemical Safety |
Prohibition or restriction of hazardous substances including CMRs, endocrine disruptors, PFAS, bisphenols, etc.; setting of migration limits (e.g., Lead ≤ 2mg/kg). |
|
Electrical Safety |
Voltage ≤ 24V; prevention of electric shock, overheating, battery ingestion; compliance with EMC and AI-related regulations. |
|
Acoustics & Radiation |
Limits on sound intensity from toys to prevent hearing damage; lasers/LEDs must comply with safety standards. |
|
Hygiene & Cleanliness |
Must be washable and present no microbial risks; toys for under-36-months must be cleanable. |
Digital Product Passport (DPP) System
- Each toy must have a DPP containing:
- Unique product identifier;
- Manufacturer information;
- Declaration of Conformity, CE marking;
- Information on hazardous substances, allergens;
- Safety warnings and instructions for use.
- Attached to the toy via QR code or data carrier, accessible to consumers, customs, and market surveillance authorities by scanning.
- Must be maintained for 10 years, even if the company ceases to exist.
Conformity Assessment Procedures
- Internal Production Control: Applicable to products manufactured in conformity with harmonised EU standards.
- EU-Type Examination: Applicable to products without standards, partially using standards, or considered high-risk, requiring certification by a third-party notified body.
Transitional Arrangements
- Full implementation begins 1 August 2026.
- Products already placed on the market in accordance with the old Directive can continue to be sold until 1 August 2030.
- Old EC-type examination certificates remain valid until 1 February 2031.
Further Information
