EU Releases New Toy Safety Regulation, Upgrading Controls on Multiple Chemicals

On December 12, 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 August 1, 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, and educational scientific apparatus.

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 Carcinogenic, Mutagenic or toxic to Reproduction (CMRs), 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

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 ten 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 August 1, 2026.
• Products already placed on the market in accordance with the old Directive can continue to be sold until August 1, 2030.
• Old EC-type examination certificates remain valid until February 1, 2031.

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Further Information

OJ