EU published the Regulation on the Safety of Toys

Vol. 1504 | 16 Dec 2025

Regulation (EU) 2025/2509 modernizes EU toy law with tighter chemical limits, cybersecurity rules for connected/AI toys, strengthened warnings, online marketplace obligations, and the Digital Product Passport, replacing Directive 2009/48/EC from August 2030.

On 12 December 2025, the European Commission published a Regulation on the safety of toys (Regulation (EU) 2025/2509).

This Regulation will replace the Toy Safety Directive (Directive 2009/48/EC), which would avoid divergent national transposition/interpretation and make rules uniformly applicable across the EU. The new regulations also adds things like Digital Product Passport and updated online-marketplace/ operator obligations which were not in the Toy Safety Directive.  

Scope

This Regulation applies to toys that are intended for use in play by children under 14 years of age.

Essential safety requirements

Toys shall be placed on the market only if they comply with the essential safety requirements (in Annex II), which include:

• Physical and mechanical properties
• Flammability
• Chemical properties
• Electrical properties
• Hygiene
• Radioactivity

There are some updates for the above requirements when compared to the Toys Safety Directive:

• Digital element (Data connection to a device or network)/Radio toys must comply with essential requirements for the protection of privacy and internet-connected toys must have cybersecurity safeguards. Toys with Al functions must comply with applicable EU regulations and Acts.
• Toys containing magnet shall not present a risk of intestinal perforation or blockage.
• The intentional use in toys of PFAS is prohibited.
• The presence in toys of the bisphenols is prohibited.
• Toys with the following categories are prohibited:
  • carcinogenicity, germ cell mutagenicity or reproductive toxicity (CMR) category 1A, 1B or 2;
  • endocrine disruption for human health category 1 or 2;
  • specific target organ toxicity category 1, either in single exposure or in repeated exposure;
  • respiratory sensitisation category 1;
  • skin sensitisation category 1A.
• New requirements for N-nitrosamines and N-nitrosatable substances are added:

	N-nitrosamines (mg/kg)	N-nitrosatable substances (mg/kg)
toys intended for use by children under 36 months and intended or likely to be placed into the mouth	0.01	0.1
toys intended for use by children under 36 months not covered by the above	0.05	1
toys intended for use by children of 36 months and over and intended to be placed into the mouth	0.05	1
balloon	0.05	1
Finger paints, slimes and putties	0.02	1

• The limits of the following substances shall not exceed:

Substance	Limit
TCEP	5 mg/kg
TCPP	5 mg/kg
TDCP	5 mg/kg
Formamide	20 μg/m3
1,2-benzisothiazol-3(2H)-one	0.75 mg/kg
5-Chloro-2-methyl-isothiazolin-3(2H)-one	0.75 mg/kg
Phenol	5 mg/l
Formaldehyde	1.5  mg/l (migration limit) in polymeric toy material 0.062  mg/m3 (emission limit) in wood toy material 30 mg/kg (content limit) in textile toy material 30 mg/kg (content limit) in leather toy material 30 mg/kg (content limit) in paper toy material 10 mg/kg (content limit) in water-based toy material
Anline	30 mg/kg (content limit) after reductive cleavage in textile toy material and leather toy material 10 mg/kg (content limit) as free aniline in finger paints 30 mg/kg (content limit) after reductive cleavage in finger paints
Styrene	0.77 mg/l
Bisphenol A	0.005 mg/l
Acrylonitrile	0.01 mg/l
Butadiene	0.07 mg/l
Vinyl chloride	0.01 mg/l

• The lists and the requirements of fragrance allergens are updated.
• Cobalt is classified as “Carc 1B, Muta 2, Repr 1B” with the following permitted presence:
  • In toys and toy components made of stainless steel, as an impurity in the nickel contained in the stainless steel.
  • In toy components which are intended to conduct an electric current.
  • In neodymium-based magnets used in toys if those magnets cannot be swallowed or inhaled.
• Preservative may be used in toy leave-on cosmetic products.

Warning requirements

Toys shall bear warnings specifying appropriate user limitations including:

• Appropriate age grading for the user
• Maximum and minimum weight of the user (when appropriate)
• The need to ensure the toy is used only under adult supervision

All warnings shall be preceded by the word "Warning" but now this word can be replaced by the Triangle mark (black triangle, yellow background and black exclamation mark). The height of this pictogram shall be at least 10 mm.

Certain toys are required to bear warnings in accordance with Annex III of this Regulation.

Obligations of manufacturers and importers

Manufacturers shall draw up the technical documentation and carry out conformity assessment. In addition, manufacturers shall also

• create a digital product passport for the toys
• affix the data carrier
• affix the CE Marking
• upload the unique product identifier and the unique operator

The technical documentation shall be up to date. The technical documentation and the digital product passport shall be kept for a period of 10 years after the toy has been placed on the market. Importers shall ensure the compliances.

The following information shall be found:

• a type, batch, serial or model number for the product identification;
• manufacturer’s, importer’s name, postal and electronic address on the toy, its packaging, accompanied document or in the digital product passport;
• instruction for use and safety information.

Providers of online marketplaces

Providers of online marketplaces shall comply with the requirements of the related provisions of Regulation (EU) 2022/2065 and Regulation (EU) 2023/988. The following information shall be provided in the online interface by the providers of online marketplaces:

• The CE marking
• Warnings
• The data carriers or weblink through which the digital product passport is assessable

Conformity assessment

Manufacturers shall carry out a safety assessment before placing a toy on the market. Manufacturers can apply harmonised standards or use the EU-type examination procedure for the conformity assessment procedures.

Digital product passport

The digital product passport is newly introduced under this Regulation. The digital product passport shall contain the following information:

• Unique product identifier of the toy
• Name and address of the manufacturer
• Name and address of the economic operator
• a statement indicating that the digital product passport is issued under the sole responsibility of the manufacturer
• Object of the passport
• The commodity code
• References to all Union legislation that the toy complies with
• The mention that the digital product passport replaces the EU Declaration of conformity
• References to the relevant harmonised standards used, or references to common specifications in relation to which conformity is declared
• The notified body’s name and number
• CE marking
• A list of allergenic fragrances that are present in the toy and that are subject to specific labelling requirements 
• The communication channel
• Reference of the digital product service provider hosting the back-up copy of the digital product passport

The digital product passport may also contain the following information:

• Safety information and warnings
• Instructions of use

Effective date

• This Regulation shall apply from 1 August 2030. However, Articles 28 to 44 and Articles 49 to 55 shall apply from 1 January 2026.
• Toys that comply with the Toy Safety Directive are able to be placed on the market before 1 August 2030. EC type-examination certificates issued in accordance with the Toy Safety Directive shall remain valid until 1 February 2031.
• The Toy Safety Directive shall be repealed from 1 August 2030.

 

If you have any questions, please contact: