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

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.

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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.

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Further Information

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