Toys placed on the European Union market must be designed and manufactured so that children can use them without unacceptable risks to their health or safety, taking account of their intended use and reasonably foreseeable use.
As of 2026, European toy manufacturers are operating during an important regulatory transition. Directive 2009/48/EC remains the principal product safety framework for toys placed on the EU market until 31 July 2030, while the new Toy Safety Regulation (EU) 2025/2509 has entered into force and will become generally applicable from 1 August 2030.
Toy conformity can involve mechanical and physical hazards, flammability, chemical exposure, electrical safety, hygiene, radioactivity, warnings, age suitability, traceability and manufacturing controls. Manufacturers must evaluate these risks before CE marking their products.
The new Regulation also represents a significant evolution of the system. It strengthens chemical restrictions and introduces a Digital Product Passport that will become an important part of toy conformity and market-surveillance controls.
This GAR Insight explains the current CE marking route under Directive 2009/48/EC and helps manufacturers understand how to prepare for the incoming Regulation (EU) 2025/2509.
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Explore toy scope, safety assessment, mechanical, chemical, electrical and flammability requirements, harmonised standards, conformity assessment, technical documentation, CE marking and the transition to Regulation (EU) 2025/2509.
Understanding the EU Toy Safety Framework
The European toy safety framework is currently in a transition period. Directive 2009/48/EC continues to govern toys placed on the EU market until the new Toy Safety Regulation becomes generally applicable.
What Is Considered a Toy?
The EU toy safety framework generally concerns products designed or intended, whether exclusively or not, for use in play by children under 14 years of age.
Determining whether a product is a toy is therefore not always as simple as reading its commercial description. Design, function, presentation, intended users and reasonably foreseeable use can all influence classification.
Traditional Toys
Dolls, figures, construction toys, puzzles, vehicles and similar products intended for children’s play.
Activity Toys
Products intended for recreational activity that may involve climbing, jumping, swinging or other physical play.
Electronic Toys
Toys incorporating electronic circuits, batteries, motors, lights, sound functions or interactive features.
Connected Toys
Toys incorporating wireless, connected or digital functionality may also trigger other applicable EU legislation.
Toy Safety Assessment
Before placing a toy on the EU market, the manufacturer must analyse the hazards that the toy may present and assess potential exposure to those hazards.
Chemical
Substances and materials capable of creating harmful exposure.
Physical & Mechanical
Choking, cutting, crushing, entrapment and structural hazards.
Electrical
Electrical shock, heating, battery and related electrical risks.
Flammability
Ignition behaviour and the spread or persistence of flame.
Hygiene
Risks associated with cleanliness, contamination and hygienic design.
Radioactivity
Potential hazards associated with radioactive materials where relevant.
Mechanical & Physical Requirements
Mechanical and physical safety is one of the most visible areas of toy compliance because children interact directly with the product through touching, pulling, pushing, dropping, climbing, throwing or mouthing it.
Small Parts
Components capable of creating choking hazards require particular attention, especially for toys intended for young children.
Sharp Edges & Points
Accessible edges and points should not create unacceptable cutting or puncture hazards.
Strength & Durability
Toys should withstand relevant foreseeable mechanical stresses without creating dangerous failures.
Entrapment
Openings, mechanisms and moving components should be assessed for finger, head, limb and other entrapment hazards.
Projectiles
Toys capable of launching projectiles require assessment of impact energy and foreseeable misuse.
Cords & Straps
Cords, loops and similar features can create strangulation or entanglement hazards.
Flammability Requirements
Toys should not present unacceptable fire hazards in the child’s environment. Materials, construction and intended use can all influence flammability requirements.
Ignition
Materials should be selected and used with appropriate consideration of their tendency to ignite.
Flame Spread
Where ignition occurs, applicable requirements can limit the speed at which flame propagates.
Costumes & Disguises
Toy costumes and materials worn by children can require particular attention because of proximity to the body.
Soft-Filled Toys
Textile and filling materials can require appropriate flammability assessment.
Chemical Safety Requirements
Chemical safety is one of the most technically demanding parts of toy conformity because children can be exposed through skin contact, inhalation, ingestion and mouthing behaviour.
The current Directive already establishes significant restrictions concerning hazardous chemicals, including controls relating to CMR substances, migration of certain elements and allergenic fragrances.
Materials & Coatings
Plastics, paints, inks, metals, adhesives and coatings should be evaluated for relevant chemical hazards.
Migration of Elements
Applicable toy materials must satisfy relevant migration limits for specified elements.
CMR Substances
Carcinogenic, mutagenic and reprotoxic substances are subject to strict restrictions and defined exceptions.
Allergenic Fragrances
Certain fragrances are prohibited or subject to labelling and other conditions.
Electrical, Hygiene & Other Safety Requirements
Modern toys increasingly combine mechanical, electronic and digital functions. The safety assessment must therefore address all relevant hazards created by the complete product.
Electrical Safety
Electrical toys require appropriate protection against shock, excessive temperatures and electrical hazards.
Batteries
Battery accessibility, compartments, charging arrangements and foreseeable misuse should be considered.
Hygiene
Toys should be designed and manufactured so that hygiene and cleanliness risks are appropriately controlled.
Radioactivity
Applicable requirements also address hazards associated with radioactivity.
Harmonised Toy Safety Standards
Harmonised European standards provide recognised technical methods manufacturers can use to demonstrate conformity with relevant toy safety requirements.
EN 71 Series
The EN 71 family addresses major areas of toy safety, with individual parts covering different hazards and test methods.
Electrical Toys
Electrical toys may require relevant electrical toy safety standards in addition to applicable EN 71 requirements.
Product-Specific Standards
Certain toy categories may be covered by additional or specialised standards.
OJEU Citation
The manufacturer should verify the current harmonised status and cited edition before relying on presumption of conformity.
Self-Verification or Notified Body Assessment?
Under the current Toy Safety Directive, two principal conformity assessment routes are available.
Internal Production Control
Where harmonised standards covering all relevant safety requirements are correctly applied, the manufacturer can use the applicable internal production control route.
EC-Type Examination
Where the conditions for the harmonised-standard route are not met, a Notified Body may be required to perform EC-type examination.
Classify
Confirm that the product falls within toy legislation.
Assess Hazards
Complete the required toy safety assessment.
Select Standards
Identify applicable harmonised standards.
Select Route
Determine internal control or third-party assessment.
Test
Complete applicable laboratory and product verification.
Document
Compile the technical documentation.
Declare
Prepare the required Declaration of Conformity.
CE Mark
Apply CE marking before EU market placement.
Toy Safety Technical Documentation
The technical documentation is the manufacturer’s evidence that the toy placed on the market corresponds to the product that was assessed and satisfies the applicable safety requirements.
Warnings, Instructions & Product Traceability
Toy safety does not end with laboratory testing. Information supplied with the product can be essential to ensuring safe use.
Age Warnings
Applicable age limitations and associated hazards should be communicated in accordance with the relevant requirements.
Safety Instructions
Where safe use depends on particular precautions, appropriate instructions should accompany the toy.
Product Identification
Type, batch, serial or other identifying information should allow the product to be traced.
Economic Operator Details
Required manufacturer and importer information should be provided in accordance with applicable legislation.
Declaration of Conformity & CE Marking
Toys placed on the EU market must carry CE marking. The CE mark represents the manufacturer’s declaration that the toy satisfies the applicable EU safety requirements.
Complete Assessment
Confirm that all applicable toy safety requirements have been addressed.
Technical Evidence
Ensure the technical documentation supports the marketed configuration.
Declaration
Prepare and maintain the applicable Declaration of Conformity.
CE Marking
Apply CE marking in accordance with the applicable visibility, legibility and permanence requirements.
Preparing for Regulation (EU) 2025/2509
The new Toy Safety Regulation strengthens the European framework and introduces changes that manufacturers should begin considering well before its general application date of 1 August 2030.
Digital Product Passport
Toys will require a Digital Product Passport containing prescribed compliance and product information accessible through a data carrier.
Stronger Chemical Controls
The new framework expands restrictions on substances considered particularly harmful to children.
Digital Market Surveillance
Product-passport information will support more effective customs and market-surveillance checks.
Online Sales
The regulatory framework expressly addresses toys supplied through distance and online sales channels.
Common Toy Safety Compliance Failures
| Common Issue | Why It Creates Risk |
|---|---|
| No documented safety assessment | Testing may fail to address hazards specific to the toy and its foreseeable use. |
| Using only a generic EN 71 test package | Applicable hazards or specialised requirements may be omitted. |
| Incorrect age grading | Test requirements, warnings and foreseeable behaviour may be assessed against the wrong user group. |
| Material changes after testing | New plastics, coatings, paints or suppliers can invalidate chemical evidence. |
| Component changes after mechanical testing | Fasteners, cords, wheels, magnets or small components can change physical safety performance. |
| Warnings used instead of safer design | Foreseeable hazards should be reduced through design where reasonably possible. |
| Incomplete traceability | Authorities may be unable to connect the marketed toy with its conformity evidence and production batch. |
| No planning for Regulation (EU) 2025/2509 | Products intended to remain on the market after the transition may require significant documentation, material or digital-system changes. |
From Toy Design to Demonstrable European Conformity
Effective toy compliance begins before laboratory testing. It starts with defining the intended users, understanding foreseeable play behaviour, identifying hazards and selecting materials and design solutions capable of satisfying the applicable safety requirements.
Testing then verifies the relevant characteristics, while technical documentation connects the tested product to its design, materials, manufacturing process, warnings and production configuration.
During the present transition period, manufacturers should also consider whether products being developed today will remain on the EU market after Regulation (EU) 2025/2509 becomes generally applicable in 2030.
The Safety Question
Have the hazards associated with the toy, its intended users and reasonably foreseeable use been systematically identified and controlled?
The Evidence Question
Can the manufacturer demonstrate through traceable assessment, testing and production records that the marketed toy corresponds with the product declared compliant?