EU Toy Safety Regulation 2025/2509

If you import into the EU any product designed or intended for use in play by a child under 14 years of age, the new EU Toy Safety Regulation, Regulation (EU) 2025/2509, applies to you from 1 August 2030. It was adopted on 26 November 2025 and published in the Official Journal on 12 December 2025. It repeals the previous Toy Safety Directive 2009/48/EC and, unlike a directive, applies directly in all 27 Member States without national transposition. Its institutional provisions, Articles 28 to 44 and 49 to 55, covering notified bodies and Commission procedures, already entered into force on 1 January 2026, but the substantive obligations on toys, chemistry expansion, Digital Product Passport, warning pictograms, economic operator duties, apply from 1 August 2030. Until then, Directive 2009/48/EC remains the applicable framework, and toys placed on the market before that date under the old Directive can continue to be made available afterwards.

This guide is written from the factory floor rather than a regulatory office. It covers the timeline through 1 February 2031, the scope updates, the Article 5 chemistry expansion, the Article 22 Digital Product Passport, the four economic operator roles, how EN 71 sits under the new regime, the two conformity assessment routes, a phased factory-side prep workflow, and how AQF collects chemistry samples, DPP data fields and data carrier verification at the factory before your container leaves the port.

1. What Is Regulation (EU) 2025/2509? (Published 12 December 2025, Applies to Toys from 1 August 2030)

Regulation (EU) 2025/2509 of the European Parliament and of the Council of 26 November 2025 on the safety of toys is the new EU-wide law that governs how toys placed on the EU market must be designed, tested, labelled and documented. It replaces the previous Toy Safety Directive 2009/48/EC and, unlike a directive, applies directly in all 27 Member States without national transposition.

• Regulation number: (EU) 2025/2509.
• Adopted: 26 November 2025.
• Published in the Official Journal: 12 December 2025.
• Institutional provisions in force: 1 January 2026 (Articles 28 to 44 and 49 to 55).
• General application to toys: 1 August 2030.
• Scope: toys designed or intended for use in play by children under 14 years of age.
• Retention: 10 years for technical documentation and the Digital Product Passport.

A regulation applies uniformly from day one, with no national interpretation variance, unlike the directive it replaces. UK exporters should note that the UK is now a third country relative to the EU: any toy shipped from the UK into an EU Member State must comply with 2025/2509 from 1 August 2030, the same as a shipment from China or Vietnam.

2. The Transition Timeline: Entry into Force, Application Date and the Repeal of Directive 2009/48/EC

Regulation (EU) 2025/2509 was published in the Official Journal on 12 December 2025 and entered into force on 1 January 2026 for its institutional provisions. It applies to toys placed on the EU market from 1 August 2030. Until then, Directive 2009/48/EC remains the applicable framework.

Date	What Applies	Reference
26 November 2025	Regulation adopted by Parliament and Council	Regulation (EU) 2025/2509
12 December 2025	Published in the Official Journal	OJ L, 2025/2509
1 January 2026	Institutional provisions in force: designation of notified bodies, Commission procedures	Articles 28 to 44, 49 to 55
2026 to 2030	Commission adopts delegated and implementing acts: DPP technical design, EU registry specifications, harmonised standards	Various
1 August 2030	General application to toys; Directive 2009/48/EC repealed; Digital Product Passport mandatory	Full Regulation
1 February 2031	EC type-examination certificates issued under Directive 2009/48/EC expire	Transitional provisions
Ongoing after 1 August 2030	Toys placed on the market before that date under Directive 2009/48/EC can continue to be made available	Transitional provisions

The four-year runway is longer than it looks. Building a Digital Product Passport infrastructure typically takes 12 to 18 months on the importer's side. Reformulating chemistry with suppliers to remove PFAS and restricted bisphenols can take 12 to 24 months. Importers who start planning in 2029 will be working against the clock; those who start in 2026 to 2028 have room to sequence the work properly.

3. Scope of the Regulation: Which Products Count as Toys, and Which Do Not

The Regulation applies to any product designed or intended, whether or not exclusively, for use in play by children under 14 years of age. The scope test is not what the product is technically, but what a parent or supervisor can reasonably assume it is meant for.

Catapults and slings are newly included in scope; they were excluded under the old Directive. Paintball equipment is newly excluded, and reading or educational books intended for children over 36 months without play value are clarified as out of scope. Public playground equipment, combustion-engine toy vehicles, properly labelled collectors' items and certain sports equipment remain excluded, unchanged from the previous Directive.

Grey zones are frequent in Asia sourcing: plush figurines marketed as collectible, bath items marketed as novelty, promotional items styled as toys but marketed to adults. When in doubt, treat the product as a toy. Children's furniture, such as cots and high chairs, follows a separate regime under standards including EN 716, EN 1273, EN 14988 and EN 1130, not this Regulation; see our furniture safety testing guide for that regime.

4. Chemistry Expansion (Article 5 and Annex II): PFAS, Bisphenols, Endocrine Disruptors, N-Nitrosamines

Article 5 of the Regulation, backed by Annex II, sets the chemical requirements for toys. Compared to Directive 2009/48/EC, the Regulation prohibits intentional PFAS use, restricts several bisphenols including BPA, adds endocrine disruptors to the generic ban, tightens N-nitrosamine limits across five toy categories, and lowers the allergenic fragrance threshold from 100 mg/kg to 10 mg/kg.

PFAS

PFAS covers any substance with at least one fully fluorinated methyl (CF3-) or methylene (-CF2-) carbon atom. Intentional use in toys and components is prohibited; trace unintentional presence is tolerated only where technically unavoidable. Request a supplier declaration of no intentional PFAS use in resins, coatings and inks, cross-checked with LC-MS/MS screening through a chemistry screening service.

Bisphenols

Several bisphenols, including BPA and structural analogues named in Annex II, are prohibited, with the BPA migration limit tightened to 0.005 mg/L. Check polycarbonate parts, thermal paper and epoxy coatings on food-contact components.

Endocrine disruptors and sensitisers

Category 1 and 2 endocrine disruptors, Category 1 target organ toxicants, Category 1 respiratory sensitisers and Category 1A skin sensitisers are added to the prohibited list.

N-nitrosamines

Toy category	N-nitrosamines (mg/kg)	N-nitrosatable substances (mg/kg)
Under 36 months, mouthed	0.01	0.1
Under 36 months, other	0.05	1
36 months and over, mouthed	0.05	1
Balloons	0.05	1
Finger paints, slimes, putties	0.02	1

Previous Appendix C substances, now extended to all ages

Substances such as TCEP, TCPP, TDCP, formamide, BIT, CIT, phenol, formaldehyde and aniline previously applied only to toys under 36 months or mouthed. Under 2025/2509 they apply to all ages. New migration limits (polymeric materials): acrylonitrile 0.01 mg/L, styrene 0.77 mg/L, butadiene 0.07 mg/L, vinyl chloride 0.01 mg/L. Formaldehyde: 1.5 mg/L polymeric, 0.062 mg/m3 wood emission, 30 mg/kg textile/leather/paper, 10 mg/kg water-based. Aniline: 10 mg/kg free in finger paints, 30 mg/kg after reductive cleavage.

Allergenic fragrances

The prohibited fragrance list grows to 59 substances, tolerated only under good manufacturing practice and below 10 mg/kg. A further 65 substances require specific labelling above 10 mg/kg, listed in the DPP.

REACH Regulation (EC) 1907/2006 applies in parallel: 2025/2509 Article 5 is toy-specific, REACH is horizontal. See our REACH compliance guide and PPWR EU packaging regulation guide for toy packaging. For importers selling into the EU and US, see our CPSIA compliance guide. Toys with cosmetic components also trigger cosmetics regulation; see our MoCRA cosmetics guide.

5. Digital Product Passport (Article 22): The 14 Fields and the Data Carrier on Every Toy

The Digital Product Passport, or DPP, is a machine-readable digital record of a toy's compliance information, mandatory for all toys placed on the EU market from 1 August 2030 under Article 22. It replaces the paper EU Declaration of Conformity and is accessible via a data carrier, such as a QR code, physically affixed to the toy or its label.

The 14 mandatory DPP fields are:

1. Unique product identifier of the toy.
2. Name and address of the manufacturer.
3. Name and address of the importer.
4. Statement that the DPP is issued under the manufacturer's sole responsibility.
5. Object of the passport (product identification).
6. Customs commodity code.
7. References to all Union legislation the toy complies with.
8. Mention that the DPP replaces the EU Declaration of Conformity.
9. References to the harmonised standards used.
10. Notified body name and number, if applicable.
11. CE marking.
12. List of allergenic fragrances subject to specific labelling.
13. Communication channel for complaints, safety concerns and accidents.
14. Reference of the service provider hosting the DPP back-up copy.

Optional fields include safety information, warnings and instructions of use. The data carrier must sit physically on the toy or on an affixed label; only where the size or nature of the toy makes this impossible may it move to the packaging or accompanying documentation. It must be publicly accessible free of charge for at least 10 years. Before placing a toy on the market, the manufacturer must upload the DPP information to an EU digital registry, which issues a unique registration identifier; customs authorities may release a toy for free circulation only after verifying that the data carrier and commodity code match the registry entry.

The Digital Product Passport under 2025/2509 covers safety compliance, not sustainability. A separate framework, the Ecodesign for Sustainable Products Regulation, may extend DPP requirements to sustainability information for toys in the medium term. Factory-side, expect a 12 to 18 month IT project to develop or contract DPP infrastructure, a distinct DPP per toy variant, and verification at pre-shipment inspection that the data carrier is present and readable on every unit.

Screen your toys for PFAS, bisphenols and endocrine disruptors before 2030

Get a Toy Compliance Quote

6. Economic Operators: Manufacturers, Importers, Distributors and Online Marketplaces (Articles 4 to 8)

The Regulation defines four economic operator roles with distinct duties: manufacturer, importer, distributor, and provider of online marketplace. The most misunderstood point in Asia sourcing is that the Chinese factory is not the manufacturer under EU law: the EU-established brand or importer that places the toy on the EU market usually is.

• Manufacturer (Article 4): design, safety and conformity assessments, DPP creation, CE marking, data carrier affixed, technical documentation kept for 10 years, and acting on non-compliance.
• Importer (Article 6): verify the manufacturer completed conformity steps including the DPP and CE marking, add its own contact details, and act on risks.
• Distributor (Article 7): check the CE marking, warnings and data carrier before making toys available, and act with due care.
• Provider of online marketplace (Article 8): comply with the Digital Services Act and the General Product Safety Regulation, and provide the data carrier or a weblink to the DPP in the online interface.

A critical rule: anyone placing a toy under their own name or trademark, or substantially modifying a toy already on the market in a way that affects compliance, becomes the manufacturer with full obligations. This is the trap for private label brands and Amazon EU sellers who assume the Chinese factory carries the duty.

Several adjacent regulations sit alongside 2025/2509 for specific toy types: the General Product Safety Regulation, Regulation (EU) 2023/988, in force since 13 December 2024, applies to all consumer products including online sales and recalls; the AI Act, Regulation (EU) 2024/1689, applies to AI toys; the Cyber Resilience Act, Regulation (EU) 2024/2847, applies to connected toys; the Radio Equipment Directive, Directive 2014/53/EU, applies to radio-connected toys; the food-contact materials Regulation (EC) 1935/2004 applies to teethers and feeding toys; and the cosmetics Regulation (EC) 1223/2009 applies to play makeup and face paints. For CE compliance and lab testing services covering this wider EU stack, AQF coordinates with an ISO 17025-accredited partner laboratory network.

7. Harmonised Standards: How EN 71 Sits Under the New Regulation

The EN 71 series is the reference set of harmonised standards for meeting the essential safety requirements of Annex II. A toy that fully complies with the applicable harmonised standards published in the Official Journal is presumed to conform to the corresponding requirements of the Regulation.

• EN 71-1: mechanical and physical properties, including small parts, sharp edges, projectile toys and cord length.
• EN 71-2: flammability, covering ignition tests on hair, textile, plush and disguise costumes.
• EN 71-3: migration of elements including antimony, arsenic, barium, cadmium, chromium, lead, mercury, selenium, aluminium, boron, cobalt, copper, manganese, nickel, strontium, tin and zinc.
• EN 71-8: activity toys for domestic use.
• EN 71-9, 71-10, 71-11: organic chemical compounds, covering requirements, sample preparation and methods of analysis.
• EN 71-12: N-nitrosamines and N-nitrosatable substances.
• EN 71-13: olfactory board games, cosmetic kits and gustative games.
• EN 71-14: trampolines for domestic use.
• EN 62115 (IEC 62115): safety of electric toys.

If your toy fully follows the harmonised standards listed for 2025/2509, you can self-declare conformity via internal production control; if not, EU-type examination via a notified body is required, covered in section 8. The toy supplier's technical file must reference which EN 71 parts and revisions were used, with test reports; this is one of the 14 DPP fields. For testing methodology, see our toy safety testing guide, and for lab testing services generally, AQF coordinates with an ISO 17025-accredited partner laboratory network.

8. Conformity Assessment: Internal Production Control or EU-Type Examination via a Notified Body

Before placing a toy on the EU market, the manufacturer must complete a conformity assessment. The Regulation allows two procedures: internal production control (Module A) if harmonised standards fully cover the toy, or EU-type examination (Module B) plus internal production control if they do not.

Module A: internal production control

The manufacturer applies all applicable harmonised standards, prepares technical documentation, performs internal checks, and issues the DPP and CE marking without notified body involvement, for standard toy categories fully covered by EN 71.

Module B: EU-type examination plus internal production control

The manufacturer submits a representative sample and technical documentation to a notified body, which issues an EU-type examination certificate; the manufacturer then applies internal production control to serial production. This route is required when harmonised standards do not fully cover the toy. Notified bodies are designated by Member States under Articles 28 to 44, in force since 1 January 2026. Connected toys with a high-risk classification under the Cyber Resilience Act and AI toys under the AI Act may trigger additional third-party assessments.

The rebrand rule from section 6 applies here too: if you rebrand a Chinese toy under your own name, you become the manufacturer and bear the conformity assessment burden yourself. For CE compliance and lab testing services, AQF coordinates test work with an ISO 17025-accredited partner laboratory network.

Collect your Digital Product Passport data at the factory, on every unit

Get a Toy Compliance Quote

9. Factory-Side Prep Workflow: What to Do at Your Chinese or Vietnamese Toy Supplier Between Now and 2030

The four-year runway to 1 August 2030 sounds long, but the factory-side prep work is substantial. This is a phased workflow for importers sourcing in China, Vietnam and other Asian toy hubs.

1. Phase 1, 2026: chemistry reformulation and supplier readiness. Send a structured questionnaire covering PFAS in raw materials, bisphenol content, endocrine disruptor presence, N-nitrosamine sources and allergenic fragrances. Prioritise bath toys, plush and wooden toys with formaldehyde-based glues. See our factory audit service.
2. Phase 2, 2026 to 2027: DPP infrastructure decision. Decide whether to develop DPP hosting internally or contract an external service provider, integrate with existing PIM and QMS systems, and map which of the 14 fields comes from R&D, QA, sourcing, regulatory or IT.
3. Phase 3, 2027 to 2028: artwork update and first article inspection. Update packaging and label artwork for the data carrier, warning pictogram and communication channel. Run a first article inspection guide style inspection to verify prototype packaging with the data carrier in place.
4. Phase 4, 2028 to 2029: notified body engagement where needed, for toys not fully covered by harmonised standards, plus technical documentation aligned with the new article structure.
5. Phase 5, 2029 to 2030: production ramp-up. New runs after 1 August 2030 must comply fully. Run a pre-shipment inspection guide style check, or book AQF's pre-shipment inspection service, to verify data carrier presence and readability on every unit.
6. Phase 6, after 1 August 2030: transition management. Existing stock placed on the market before that date under Directive 2009/48/EC can continue to be sold through; manage inventory FIFO. EC type-examination certificates expire 1 February 2031, so schedule re-certification for products still in production.

For the wider cross-jurisdiction picture, US CPSIA and ASTM F963 alongside EU EN 71, see our toy safety testing guide.

10. AQF's 2025/2509 Workflow: Chemistry Sampling, DPP Data Collection, Data Carrier Verification

AQF is not a testing lab. AQF is the QC firm inside the toy factory in China, Vietnam or India that collects the chemistry samples, gathers the DPP data fields, and verifies that the data carrier is correctly affixed to every toy before your container ships.

1. Supplier 2025/2509 readiness audit: a structured questionnaire covering the 14 DPP fields, the chemistry supply chain, harmonised standards traceability, and warnings artwork readiness, run by an AQF inspector on-site at the toy supplier's factory.
2. Chemistry sampling: the inspector collects samples across component types, plastic, textile, coatings and printed labels, sent to an ISO 17025-accredited partner laboratory network for PFAS, bisphenol and N-nitrosamine screening, formaldehyde and aniline testing, and migration limits per EN 71-3.
3. DPP data collection: compiling the 14 fields from supplier deliverables into a structured file that supports your DPP creation.
4. Data carrier verification at pre-shipment inspection: confirming the data carrier is physically present, correctly placed and readable on every unit, on the toy or its label rather than only the packaging. See AQF's pre-shipment inspection service and our pre-shipment inspection guide for the buyer-side workflow behind this check.
5. Warning label and artwork verification: confirming the warning pictogram is present and legible, warnings text is correctly translated, and the communication channel is printed on the toy or packaging.

AQF sits between your Chinese or Vietnamese toy supplier and your EU import operation, collecting the data an EU importer needs for a valid Digital Product Passport by 1 August 2030.

Frequently Asked Questions

What is the EU Toy Safety Regulation 2025/2509?

Regulation (EU) 2025/2509 of the European Parliament and of the Council of 26 November 2025 is the new EU-wide law on the safety of toys. It was published in the Official Journal on 12 December 2025 and repeals the previous Toy Safety Directive 2009/48/EC. Unlike a directive, it applies directly in all 27 Member States without national transposition, and introduces the Digital Product Passport, an expanded chemistry regime and cybersecurity requirements for connected toys.

When does the EU Toy Safety Regulation 2025/2509 apply?

The Regulation applies to toys placed on the EU market from 1 August 2030, when Directive 2009/48/EC is repealed. Articles 28 to 44 and Articles 49 to 55, which cover institutional provisions such as designation of notified bodies and Commission procedures, apply from 1 January 2026. Until 1 August 2030, importers may continue to place toys on the market under the old Directive 2009/48/EC framework.

What is the Digital Product Passport for toys?

The Digital Product Passport, or DPP, is a machine-readable digital record of a toy's compliance information, mandatory for all toys placed on the EU market from 1 August 2030 under Article 22. It replaces the paper EU Declaration of Conformity, is accessible via a data carrier such as a QR code physically affixed to the toy or its label, must be available for at least 10 years, and is stored by an EU registry that customs authorities can verify at import.

Does the EU Toy Safety Regulation ban PFAS?

Yes. The Regulation prohibits the intentional use of per- and polyfluoroalkyl substances (PFAS) in toys, their components and micro-parts. PFAS covers any substance containing at least one fully fluorinated methyl (CF3-) or methylene (-CF2-) carbon atom. Trace unintentional presence is tolerated only where technically unavoidable under good manufacturing practice and the toy remains safe. Bisphenols including BPA and several structural analogues are similarly prohibited.

What chemicals are newly restricted under 2025/2509 vs Directive 2009/48/EC?

The Regulation broadens the generic ban beyond CMR substances to include endocrine disruptors (Categories 1 and 2), specific target organ toxicants (Category 1), respiratory sensitisers (Category 1) and skin sensitisers (Category 1A). It adds PFAS, bisphenols and N-nitrosamines with tighter limits, extends previous Appendix C substance restrictions to toys for all ages (not just under 3), and tightens allergenic fragrance limits from 100 mg/kg to 10 mg/kg.

Does the Regulation apply to me if I import toys from China into the EU?

Yes. Any economic operator placing a toy on the EU market carries duties under 2025/2509. From 1 August 2030, as an EU-established importer, you must verify the manufacturer has completed a valid conformity assessment, ensure a Digital Product Passport is created and its data carrier physically affixed to each toy or its label, keep technical documentation and the DPP for 10 years, and act on any non-compliance discovered before or after placing the toy on the market.

Which EN 71 standards apply under the new Regulation?

The EN 71 series remains the reference set of harmonised standards for meeting the essential safety requirements of Annex II. Key parts include EN 71-1 (mechanical and physical properties), EN 71-2 (flammability), EN 71-3 (migration of certain elements, including antimony, arsenic, barium, cadmium, chromium, lead, mercury, selenium), and EN 71-9, 71-10, 71-11 (organic chemical compounds). Additional revisions are expected as harmonised standards are updated to align with the Regulation.

Do I need a notified body to place a toy on the EU market?

Not always. If your toy fully complies with harmonised standards published under 2025/2509, you can use internal production control (Module A) and self-declare conformity. If the toy does not fully follow those standards, or if a harmonised standard does not exist for a specific property, you must use EU-type examination (Module B) plus internal production control, which requires assessment by a notified body designated under the Regulation. Connected and AI toys may trigger additional third-party assessments.

What about my toys currently on the market under Directive 2009/48/EC?

Toys placed on the EU market in conformity with Directive 2009/48/EC before 1 August 2030 can continue to be made available after that date, providing breathing room for existing inventory in EU warehouses and stores. EC type-examination certificates issued under the Directive remain valid until 1 February 2031. New production runs after 1 August 2030 must comply fully with Regulation 2025/2509, including the Digital Product Passport.

What happens if my toys do not meet the new requirements at import?

Customs authorities can verify the data carrier and commodity code against the EU registry entry and refuse release for free circulation if data is missing or does not match. National market surveillance authorities can require corrective action, restrict or prohibit market access, order recall or withdrawal, and impose penalties defined by each Member State. Repeat non-compliance can trigger blockage across the single market via information-sharing between authorities.

EU 2025/2509 applies from 1 August 2030. Is your toy supply chain ready?

Get a Toy Compliance Quote