EU Toy Safety Regulation: What Changed and When It Applies

The EU Toy Safety Regulation (EU) 2025/2509 (TSR) is the new legal framework for toys sold in the European Union. Adopted on 26 November 2025 and in force since 1 January 2026, it replaces the Toy Safety Directive 2009/48/EC, which has governed toy safety in the EU since 2011. The new rules apply in full from 1 August 2030, and they change three things fundamentally: which chemicals are allowed in toys, how compliance is documented (a Digital Product Passport replaces the familiar paper trail), and how digital and connected toys are assessed.

If you manufacture, import, or sell toys in the EU, the transition window is already running. Four and a half years sounds generous. For companies managing hundreds of SKUs across multiple suppliers, it is not: every toy in your range needs to be reassessed against stricter chemical rules and equipped with a machine-readable product passport before the deadline.

The shift from a directive to a regulation is not a technicality. A directive must be transposed into 27 national laws, which produced years of divergence in how member states interpreted and enforced toy safety rules. A regulation applies directly and identically across the entire EU, the same mechanism the EU used when it replaced the General Product Safety Directive with the General Product Safety Regulation (EU) 2023/988 (GPSR) in 2024.

For toy companies, this means one set of rules, one enforcement logic, and far less room for market-by-market interpretation. It also means the compliance bar is set centrally, and it has been set noticeably higher.

Why did the EU replace the Toy Safety Directive?

The European Commission's evaluation of Directive 2009/48/EC found two persistent weaknesses: the directive could not keep pace with new scientific evidence on harmful chemicals, and enforcement struggled with the volume of non-compliant toys entering the EU through online sales. Toys were the second most-notified product category in the EU's Safety Gate rapid alert system in 2025, accounting for 16% of a record 4,671 alerts, according to the European Commission's Safety Gate annual report. The TSR addresses both weaknesses directly: a dynamic mechanism for banning hazardous substances, and a digital enforcement infrastructure built around the product passport.

Stricter chemical rules, applied dynamically

The most significant substantive change is chemical. According to the European Commission, the TSR bans substances from toys as soon as they are classified as hazardous, including chemicals that disrupt hormones, harm the respiratory system, cause skin allergies, or damage specific organs. The regulation also strengthens the existing prohibition on carcinogenic, mutagenic, and reprotoxic (CMR) substances.

Two bans stand out for their supply chain impact:

• PFAS: the intentional use of per- and polyfluoroalkyl substances ("forever chemicals") in toys is prohibited.
• Bisphenols: the presence of bisphenols in toys is prohibited, extending well beyond the previous restrictions on bisphenol A.

The regulation also tightens rules on fragrance allergens. The Appendix to Annex II prohibits 59 listed fragrance allergens unless their presence is technically unavoidable under good manufacturing practice and does not exceed 10 mg/kg, and requires 65 further allergens to be labelled, including in the digital product passport, when present above that threshold. Preservatives may only be used where they are allowed in leave-on cosmetics under the EU Cosmetics Regulation (Annex II, Part III, point 14 of the TSR).

The word "dynamically" matters here. Under the old directive, adding a substance restriction was slow. Under the TSR, hazard classification triggers the ban. For quality teams, this means chemical compliance for toys stops being a static checklist and becomes a moving target that must be monitored continuously.

A Digital Product Passport for every toy

Under the TSR, all toys placed on the EU market will be required to carry a Digital Product Passport (DPP) containing safety and compliance information, accessible online via a QR code or other data carrier. The toy DPP is the first mandatory product passport applied to an entire consumer product category, arriving ahead of most categories planned under the Ecodesign for Sustainable Products Regulation (EU) 2024/1781 (ESPR).

Article 19 of the TSR requires the manufacturer to create a digital product passport for each toy, and the passport replaces the EU declaration of conformity that toys carried under the old directive. Where the passport contains all required information, it can also serve as the declaration of conformity under other EU legislation applying to the toy, such as RoHS, the Radio Equipment Directive, or the Cyber Resilience Act (Article 19(5)). Customs authorities will be able to check the passport for toys sold online and imported into the EU, which closes the enforcement gap that has let non-compliant toys flow into the market through e-commerce channels.

For a deeper look at how product passports work across categories, see our Digital Product Passport guide.

Digital, connected, and app-enabled toys

The TSR extends safety assessment beyond physical and chemical hazards. For toys in scope of the AI Act, the Cyber Resilience Act, or the Radio Equipment Directive, Article 25(2)(c) requires the safety assessment to take account of children's particular vulnerabilities, and the regulation's recitals state that assessments should, where appropriate, cover risks that digitally connected toys pose to mental health. Cybersecurity itself is not regulated by the TSR: connected toys must instead comply with the Cyber Resilience Act (EU) 2024/2847, which the TSR cross-references, and internet-connected toys that speak, film, or track location fall into the CRA's "important products" class with stricter conformity assessment. If your range includes anything with a chip, a microphone, an app, or a connection, your technical documentation now spans two regulations, not one.

Obligations across the supply chain

Like GPSR, the TSR assigns explicit obligations to every economic operator: manufacturers, importers, distributors, and online marketplaces. Marketplaces and customs gain new tools to verify compliance through the DPP, which means retailers and platforms will increasingly push documentation requirements upstream to brands and manufacturers. Companies selling through Amazon, Zalando, or similar channels should expect passport data to become a listing requirement, not just a legal one.

Is the Toy Safety Regulation already in force?

Yes, the TSR entered into force on 1 January 2026, but its substantive requirements do not apply to products until 1 August 2030. Under Article 59, Articles 28 to 44 and Articles 49 to 55 apply from 1 January 2026; these cover the institutional machinery (notification of conformity assessment bodies, delegated powers, committee procedure, and penalties) rather than product requirements. Until 1 August 2030, toys must continue to comply with Directive 2009/48/EC.

Can I still sell toys that comply with the old directive after 2030?

Yes. Under Article 57(1) of the TSR, member states may not impede the making available of toys placed on the market in conformity with Directive 2009/48/EC before 1 August 2030, and the regulation sets no sell-off end date for that stock. EC type-examination certificates issued under the directive remain valid until 1 February 2031 unless they expire earlier (Article 57(3)). "Placed on the market" refers to each individual unit's first making available in the EU, so production runs after the deadline must comply with the TSR regardless of when the model was designed.

Does the new regulation apply in the UK?

No. The TSR applies to the EU and EEA market. Great Britain retains its own Toys (Safety) Regulations 2011, and toys sold there follow UKCA or recognized CE rules; Northern Ireland follows EU rules under the Windsor Framework. Companies selling in both markets will need to manage diverging toy safety requirements, a divergence that will grow as the TSR's chemical rules take effect. See our UKCA marking guide for the GB side of the picture.

Four and a half years is enough time if the work starts from structured product data. It is not enough time to do this manually across a large catalogue. Konges Sløjd, the Danish children's brand selling in 90 countries, is a useful reference point for the scale problem: children's product portfolios routinely require risk assessments by the hundreds, and the TSR effectively re-opens every one of them.

This portfolio-wide reassessment is exactly the kind of work that breaks manual compliance processes, and it is why we built Complir to run classification, risk assessment, and supplier document retrieval from a single structured record per product.

The EU Toy Safety Regulation (EU) 2025/2509 replaces the Toy Safety Directive 2009/48/EC and applies in full from 1 August 2030. Chemical compliance becomes dynamic: hazard classification now triggers bans automatically, including prohibitions on PFAS and bisphenols. Every toy on the EU market will need a Digital Product Passport accessible by QR code, checkable by customs and marketplaces. Digital and connected toys face new cybersecurity and mental-health assessment duties. And because the passport requires structured product data, the companies that win the transition will be the ones that treat this as a data project starting now, not a documentation sprint in 2029.

If reassessing an entire toy portfolio against the TSR while keeping up with GPSR and the incoming ESPR passports sounds like more than your team can absorb, see how Complir automates product classification, chemical risk mapping, and supplier documentation collection across your full catalogue.

Sources & References

• Regulation (EU) 2025/2509 of the European Parliament and of the Council of 26 November 2025 on the safety of toys and repealing Directive 2009/48/EC: EUR-Lex
• European Commission, "Stronger toy safety rules enter into force," 23 December 2025: European Commission
• Directive 2009/48/EC on the safety of toys: EUR-Lex
• General Product Safety Regulation (EU) 2023/988: EUR-Lex
• Ecodesign for Sustainable Products Regulation (EU) 2024/1781: EUR-Lex
• Cyber Resilience Act (EU) 2024/2847: EUR-Lex
• European Commission, Safety Gate Annual Report 2025: Publications Office

This article is for informational purposes only and does not constitute legal advice. Regulatory requirements may vary by product category, market, and specific circumstances. Consult with a qualified legal professional for compliance guidance specific to your situation.