EU Toy Safety Regulation 2025/2509: New Labelling Requirements

The European Union has adopted Regulation (EU) 2025/2509 on the safety of toys, replacing the previous Toy Safety Directive 2009/48/EC. The new regulation strengthens toy safety requirements across the EU and introduces stricter obligations for manufacturers, importers, distributors, online sellers, fulfilment service providers, and other economic operators placing toys on the EU market.

The new framework introduces expanded chemical restrictions, clearer warning and labelling rules, mandatory Digital Product Passports, stronger online marketplace controls, and improved traceability requirements. While most obligations will apply from 1 August 2030, businesses should begin preparing now, especially where toy portfolios include many SKUs, multiple suppliers, private-label products, or online sales channels.

 

What Is Changing Under the New EU Toy Safety Regulation?

The new Toy Safety Regulation is designed to address risks that have become more visible in recent years, especially unsafe toys sold online, imported toys with incomplete documentation, inconsistent labelling, and insufficient control of hazardous substances.

Unlike the previous directive, the new regulation applies directly across all EU Member States. This should make enforcement more consistent and reduce differences in national implementation.

Main Changes for Toy Businesses

The most important changes include stricter chemical safety requirements, updated labelling rules, mandatory Digital Product Passports, stronger online sales obligations, and clearer responsibilities for economic operators.

For manufacturers, importers, and private-label brands, this means that compliance can no longer rely only on basic EN 71 test reports or supplier declarations. A complete and well-structured technical file will become even more important.

 

Mandatory Toy Labelling Requirements

Toys placed on the EU market must carry clear, visible, and legible safety and traceability information. The label must allow consumers, authorities, and supply chain partners to identify the product, the responsible economic operators, and the relevant safety warnings.

Information Typically Required on Toy Labels

Depending on the product type and supply chain setup, toy labelling should include the following information:

  • Product name, model number, type, batch, serial number, or another traceability element
  • CE marking
  • Manufacturer name, registered trade name or trademark, and postal address
  • Importer name and postal address, where applicable
  • EU Responsible Person or relevant economic operator details, where required
  • Age grading and age-related warnings, where applicable
  • Specific safety warnings based on the toy’s intended use and foreseeable misuse
  • Digital Product Passport access method, such as a QR code or other data carrier

Warnings Must Be Visible Before Purchase

Warnings must be visible to consumers before purchase. This is especially important for online sales. If a toy is sold through an online store or marketplace, the required warnings must be shown clearly in the product listing before the consumer completes the purchase.

Practical Impact for Online Sellers

Online sellers should review their product pages and ensure that age warnings, safety warnings, CE information, and relevant compliance details are not hidden in images, PDFs, or post-purchase documents only. The buyer must be able to see the required safety information before ordering.

 

Warning Statements and Pictograms

The new regulation strengthens the way warnings must be presented. Warnings must be clear, understandable, and easy to read. They must also be appropriate for the toy’s intended user group and risk profile.

Use of the Word “Warning”

Where required, warning statements should begin with the word “Warning” and should not be presented in a way that minimizes or hides the safety message.

Small Parts and Children Under 36 Months

The familiar warning for toys that are not suitable for children under 36 months remains important. Where a toy presents a choking hazard or other risk to young children, the warning must be used correctly and supported by the product’s age grading and safety assessment.

Important Note on Age Grading

Age grading must be based on the toy’s function, design, marketing, expected user group, and foreseeable use. It should not be used only as a way to avoid stricter safety requirements. For example, a product that clearly appeals to young children may still be treated as a toy for that age group, even if the label attempts to state a higher age range.

 

Digital Product Passport for Toys

One of the most important changes is the introduction of a Digital Product Passport for toys. The Digital Product Passport will provide electronic access to key compliance and traceability information.

What the Digital Product Passport May Include

The Digital Product Passport is expected to include important information such as:

  • Product identification
  • Manufacturer details
  • Importer or responsible economic operator details, where applicable
  • Declaration of Conformity information
  • Applicable EU legislation
  • Harmonised standards used
  • Safety warnings
  • Relevant chemical safety information
  • Notified body information, where applicable

Access Through a Data Carrier

The Digital Product Passport will normally be accessed through a data carrier, such as a QR code. This data carrier must be linked to the specific toy model and remain accessible for the required retention period.

Why This Matters for Importers

Importers and private-label brands will need reliable systems to connect each toy model with its compliance documentation. This is especially important where a company sells many product variants, imports from multiple factories, or changes suppliers over time.

 

Stronger Chemical Safety Requirements

The new Toy Safety Regulation expands restrictions on hazardous substances in toys. This is one of the most important areas of change, especially for toys made from plastics, coatings, inks, textiles, foams, metals, adhesives, paints, or electronic components.

Substances of Concern

The regulation strengthens controls on several categories of substances, including substances that may be carcinogenic, mutagenic, toxic to reproduction, endocrine disrupting, persistent, bioaccumulative, toxic, or otherwise harmful to children.

Additional Focus on Young Children

Toys intended for children under 36 months and toys intended to be placed in the mouth will remain subject to particularly strict safety expectations. These products often require stronger chemical evidence and more detailed risk assessment.

Practical Documentation Needed

Businesses should collect and maintain material-level documentation, including bills of materials, EN 71 test reports, REACH declarations, supplier declarations, substance declarations, and where relevant, Safety Data Sheets (SDS) for materials, coatings, inks, adhesives, and finishes.

 

Online Marketplace and Distance Sales Obligations

The new regulation places strong emphasis on online sales. This reflects the growing number of toys sold directly to EU consumers through online marketplaces, cross-border e-commerce platforms, and direct-to-consumer websites.

Required Information in Online Listings

Online toy listings should clearly show required safety information before purchase. This includes warnings, CE marking information, Digital Product Passport access, and relevant economic operator details where required.

Marketplace Scrutiny Will Increase

Online marketplaces are expected to apply stronger checks to toy listings. Sellers may increasingly be asked to provide technical files, test reports, Declarations of Conformity, product images, labelling artwork, traceability details, and Digital Product Passport data.

Risk of Delisting

Incomplete compliance documentation may lead to product delisting, customs detention, market surveillance inquiries, recall requests, or Safety Gate notifications. Sellers should not wait until a marketplace requests documents. The documentation should already be prepared before the toy is offered for sale.

 

Technical Documentation Requirements

Technical documentation is the foundation of toy compliance. It must demonstrate that the toy has been properly assessed, tested, labelled, and documented before being placed on the EU market.

Typical Technical File Contents

A toy technical file should normally include:

Declaration of Conformity

The Declaration of Conformity confirms that the toy complies with the applicable EU requirements. It should be signed by the responsible manufacturer or importer, depending on the supply chain setup.

Important Compliance Point

A test report alone is not the same as full compliance. A toy may pass selected EN 71 tests but still have incomplete labelling, missing traceability, insufficient chemical documentation, or an incomplete technical file.

 

Impact on Importers and Private-Label Brands

Importers and private-label brands often carry significant legal responsibility under EU product safety law. If a company places toys on the EU market under its own name or trademark, or imports toys from outside the EU, it must ensure that the product is compliant before sale.

Supplier Documents Must Be Verified

Importers should not rely only on supplier statements. They should verify that test reports match the actual product, materials, supplier, factory, model numbers, and intended EU market.

Product Grouping Must Be Controlled

Where multiple SKUs are grouped under one compliance file, the grouping must be justified. Products should only be grouped where they share the same function, material composition, construction, supplier documentation, and risk profile.

When Separate Certification May Be Needed

Separate certification or documentation may be required where products use different materials, different suppliers, different factories, different age grades, different functions, different electronics, or different safety-relevant components.

 

Transition Timeline

The new Toy Safety Regulation entered into force in January 2026. Most obligations will apply from 1 August 2030.

Why Businesses Should Prepare Early

Although the main application date is still several years away, toy businesses should begin preparing now. Digital Product Passport systems, updated labelling, revised technical file structures, and stronger chemical documentation may require significant internal preparation.

Recommended Preparation Steps

Businesses should begin by reviewing existing toy labels, EN 71 reports, Declarations of Conformity, supplier documentation, product grouping logic, online listings, and traceability systems. Any gaps should be addressed before the new rules fully apply.

 

How EaseCert Supports Toy Compliance

EaseCert supports toy manufacturers, importers, brand owners, and online sellers with structured GPSR and toy safety compliance documentation. This includes technical file preparation, risk assessment, labelling review, Declaration of Conformity drafting, product grouping review, and EU Responsible Person support where applicable.

Our Compliance Support May Include

  • Review of product grouping and SKU structure
  • Review of supplier documentation and test reports
  • Preparation of GPSR risk assessments
  • Preparation of technical documentation files
  • Review of labels, warnings, and traceability information
  • Drafting of Declarations of Conformity for signature
  • EU Responsible Person support
  • Guidance on online listing compliance

Frequently Asked Questions

When does the new EU Toy Safety Regulation apply?

The new Toy Safety Regulation entered into force in January 2026. Most obligations will become fully applicable from 1 August 2030. However, manufacturers, importers, and online sellers should begin preparing well before that date, especially for Digital Product Passport implementation, technical documentation updates, and revised labelling requirements.

Does the new regulation replace the Toy Safety Directive?

Yes. Regulation (EU) 2025/2509 replaces Directive 2009/48/EC on toy safety. Unlike a directive, an EU regulation applies directly across all Member States without separate national implementation legislation.

What is a Digital Product Passport for toys?

A Digital Product Passport (DPP) is a digital compliance and traceability record linked to a toy product. It will normally be accessed through a QR code or similar data carrier and may include manufacturer details, safety warnings, conformity information, applicable standards, and other compliance documentation.

Will all toys require a Digital Product Passport?

Yes, the new regulation introduces Digital Product Passport requirements for toys placed on the EU market. Businesses selling toys online or through marketplaces should begin preparing systems to manage this information now.

Do online marketplaces need to display toy warnings?

Yes. Mandatory warnings and safety information must generally be visible before purchase, including in online product listings. This includes age warnings, safety restrictions, and other required compliance information.

What happens if toy labels are not compliant?

Non-compliant toy labels may lead to customs detention, online marketplace delisting, enforcement action, product recalls, or Safety Gate notifications. Authorities may also request updated technical documentation and corrective action.

Do importers have legal responsibility under the new regulation?

Yes. Importers placing toys on the EU market are responsible for ensuring that products comply with applicable EU legislation. This includes verifying technical documentation, test reports, labelling, traceability information, and conformity assessment requirements.

Can one EN 71 test report cover multiple toy SKUs?

Potentially yes, but only where the products share the same material composition, function, construction, supplier documentation, and risk profile. Different materials, suppliers, factories, or safety-relevant components may require separate documentation or testing.

Will chemical requirements become stricter?

Yes. The regulation introduces stronger restrictions on hazardous substances, including certain endocrine disruptors, PFAS substances, allergenic fragrances, and other chemicals considered harmful to children.

Do Amazon and other online sellers need to comply?

Yes. The regulation applies to toys sold through online marketplaces, direct-to-consumer websites, and cross-border e-commerce platforms. Sellers remain responsible for ensuring that products placed on the EU market comply with the applicable requirements.

What documents should toy businesses prepare?

Toy businesses should prepare a complete technical file including product descriptions, bills of materials, risk assessments, EN 71 test reports, chemical safety documentation, labelling artwork, Declarations of Conformity, and traceability records.

Does GPSR still apply to toys?

Toys primarily fall under toy-specific legislation. However, the General Product Safety Regulation (GPSR) may still apply in parallel regarding product safety obligations, recalls, online marketplace responsibilities, and market surveillance cooperation.

Can EaseCert help with toy compliance?

Yes. EaseCert supports manufacturers, importers, and online sellers with toy compliance documentation, GPSR risk assessments, technical files, label reviews, Declaration of Conformity drafting, and EU Responsible Person support.


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Conclusion

The new EU Toy Safety Regulation marks a major shift in toy compliance. It strengthens chemical safety, improves warning visibility, introduces Digital Product Passports, and places greater responsibility on online sellers and importers.

For toy businesses, the main message is clear: compliance must be documented, traceable, and ready before the product is placed on the EU market. Companies that prepare early will be in a stronger position when the new rules fully apply from 1 August 2030.

Official EU References