Toy Safety Regulation (EU) 2025/2509

[Updated May 18, 2026]

What. The Toy Safety Regulation (EU) 2025/2509 establishes stricter safety requirements for toys placed on the EU market, including expanded chemical restrictions and mandatory digital product passports (DPPs) to enhance traceability and compliance. It replaces Directive 2009/48/EC to address modern safety challenges and digitalization, aligning with the EU's broader sustainability and digital product policies.

When. Adopted by the European Parliament in March 2024; entered into force in 2025. Key provisions, including DPP requirements, apply from 1 January 2027, with phased implementation for specific chemical restrictions (e.g., endocrine disruptors from July 2027). Full compliance is required for all toys by 1 January 2028, with stock clearance allowed until 2029.

Products. All toys intended for or likely to be used by children under 14 years, including electrical toys, chemical toys, and toys embedded in food. Excludes products such as sports equipment, decorative objects, and collectibles not designed for children.

Who. Manufacturers, importers, distributors, and authorized representatives placing toys on the EU market. Economic operators must ensure compliance with safety requirements, DPP obligations, and supply chain transparency.

Overview of the Toy Safety Regulation (EU) 2025/2509

The Toy Safety Regulation (EU) 2025/2509 is a comprehensive update to the EU’s toy safety framework, replacing the Toy Safety Directive (2009/48/EC). It introduces stricter safety requirements, particularly for chemical substances, and mandates the use of Digital Product Passports (DPPs) to improve traceability, market surveillance, and consumer transparency. The regulation addresses emerging risks, such as hazardous chemicals in toys, and leverages digital tools to enhance supply chain accountability.

Key objectives include:

• Strengthening chemical safety by expanding the list of prohibited and restricted substances, including CMRs (carcinogenic, mutagenic, or reprotoxic substances), endocrine disruptors, and allergenic fragrances.
• Introducing DPPs to provide detailed product information, including materials, safety certifications, and supply chain data, accessible via a unique digital identifier (e.g., QR code).
• Enhancing market surveillance through digital compliance tools, enabling authorities to verify safety and environmental standards efficiently.
• Aligning with broader EU policies, such as the Ecodesign for Sustainable Products Regulation (ESPR) and the Circular Economy Action Plan, to promote sustainability and digitalization in product design and lifecycle management.

Key Requirements Under the Regulation

Chemical Safety

The regulation significantly expands restrictions on hazardous chemicals in toys to protect children’s health. Key provisions include:

• Ban on CMR substances: Prohibition of carcinogenic, mutagenic, or reprotoxic substances in toys, with limited exemptions for substances deemed safe under specific conditions (e.g., trace amounts).
• Endocrine disruptors: New restrictions on chemicals known to interfere with hormonal systems, particularly in toys intended for children under 36 months. Compliance is required from July 2027.
• Allergenic fragrances: Stricter limits on 71 fragrances that may cause allergic reactions, with mandatory labeling requirements for any fragrance present above 0.01%.
• Heavy metals: Lower limits for heavy metals such as lead (≤ 2.0 mg/kg), cadmium (≤ 1.9 mg/kg), and mercury (≤ 0.5 mg/kg) in toy materials.
• Nitrosamines and nitrosatable substances: Reduced limits for these compounds in toys intended for children under 36 months.

Digital Product Passport (DPP)

The regulation mandates the implementation of DPPs for all toys placed on the EU market. The DPP serves as a digital record containing critical product information, including:

• Unique product identifier: A digital link (e.g., QR code or RFID tag) to access the DPP, affixed to the toy or its packaging.
• Safety certifications: Documentation of compliance with EU safety standards, including test reports, conformity assessments, and CE marking.
• Material composition: Detailed breakdown of materials used in the toy, including chemical substances, their concentrations, and compliance with chemical restrictions.
• Supply chain data: Information on manufacturers, importers, distributors, and the origin of raw materials, ensuring full traceability.
• Instructions and warnings: Digital copies of user instructions, age recommendations, and safety warnings in the official language(s) of the EU member state where the toy is sold.

The DPP must be accessible to consumers, market surveillance authorities, and economic operators via a standardized digital format. This requirement aligns with the broader EU Digital Product Passport framework, which aims to enhance transparency, sustainability, and compliance across product categories.

Compliance Timeline and Phased Implementation

The Toy Safety Regulation (EU) 2025/2509 follows a phased implementation timeline to allow economic operators to adapt to the new requirements: - 2025: Regulation enters into force. - Q1 2026: Publication of harmonized standards and guidelines for DPP implementation and chemical restrictions. - 1 January 2027: DPP requirements become mandatory for all new toys placed on the EU market. - 1 July 2027: Expanded chemical restrictions apply, including bans on additional CMR substances and endocrine disruptors. - 1 January 2028: Full compliance required for all toys, including those already on the market (stock clearance allowed until 2029).

Manufacturers and importers are advised to begin DPP implementation and chemical compliance assessments as early as possible to ensure readiness by the 2027 deadlines.

Affected Parties and Their Obligations

The regulation imposes obligations on all economic operators involved in the toy supply chain:

Manufacturers

• Ensure toys comply with all safety requirements, including chemical restrictions and DPP obligations.
• Conduct conformity assessments, including laboratory testing for prohibited substances, and draw up technical documentation.
• Affix the CE marking and provide a unique product identifier (e.g., QR code) for DPP access.
• Maintain records of compliance, including test reports and DPP data, for 10 years after the toy is placed on the market.
• Update DPPs in case of design or material changes to reflect compliance with the latest requirements.

Importers

• Verify that manufacturers have complied with EU safety requirements and DPP obligations before placing toys on the market.
• Ensure toys are accompanied by the required documentation, including the DPP and CE marking.
• Keep records of compliance and cooperate with market surveillance authorities during inspections.
• Ensure that toys are stored and transported under conditions that do not compromise safety or DPP accessibility.

Distributors

• Verify that toys bear the CE marking and are accompanied by the required documentation, including DPP access.
• Ensure toys are stored and transported under conditions that do not compromise safety or DPP functionality.
• Report any safety risks or non-compliance to market surveillance authorities.

Authorized Representatives

• Act on behalf of manufacturers to ensure compliance with the regulation, including DPP and chemical safety requirements.
• Maintain technical documentation and cooperate with authorities during inspections and audits.

Market Surveillance Authorities

• Monitor compliance with the regulation, including DPP requirements and chemical restrictions.
• Conduct random testing, inspections, and audits of toys on the market.
• Take enforcement actions, such as recalls, fines, or market bans, for non-compliant products.
• Collaborate with authorities in other EU member states to ensure consistent enforcement.

Penalties and Enforcement

Non-compliance with the Toy Safety Regulation (EU) 2025/2509 may result in severe penalties, including:

• Product recalls: Mandatory removal of non-compliant toys from the market, with costs borne by the economic operator.
• Fines: Financial penalties proportional to the severity of the violation, which may reach up to 4% of annual turnover in the EU for repeat offenses or deliberate non-compliance.
• Market bans: Temporary or permanent prohibition on placing non-compliant toys on the EU market.
• Criminal liability: In cases of deliberate non-compliance, fraud, or repeated violations, individuals (e.g., company directors) may face criminal charges under national law.
• Reputational damage: Non-compliance may lead to public disclosure of violations, loss of consumer trust, and exclusion from public procurement processes.

Market surveillance authorities in EU member states are responsible for enforcing the regulation. They conduct random testing, inspections, and audits to verify compliance with chemical restrictions and DPP requirements. Economic operators found to be non-compliant may also face joint enforcement actions across multiple member states under the EU Market Surveillance Regulation (EU) 2019/1020.

Market Surveillance and Enforcement Mechanisms

The Toy Safety Regulation (EU) 2025/2509 strengthens market surveillance and enforcement mechanisms to ensure compliance with chemical safety and DPP requirements. Key aspects include:

Role of Market Surveillance Authorities

• Risk-based inspections: Authorities prioritize inspections based on risk assessments, focusing on high-risk toys (e.g., those intended for children under 36 months) or products with a history of non-compliance.
• Digital compliance checks: Authorities use DPP data to verify compliance remotely, reducing the need for physical inspections and accelerating the process.
• Cross-border collaboration: The EU Market Surveillance Regulation (EU) 2019/1020 facilitates cooperation between national authorities, enabling joint enforcement actions and information sharing.

Enforcement Tools

• Rapid Alert System (RAPEX): Non-compliant toys are reported via RAPEX, triggering swift action across the EU to remove unsafe products from the market.
• Customs controls: EU customs authorities screen imported toys for compliance with chemical restrictions and DPP requirements, preventing non-compliant products from entering the market.
• Mandatory reporting: Economic operators must report safety risks or non-compliance to authorities, ensuring proactive identification of hazards.

Guidance and Support for Economic Operators

• The European Commission provides guidance documents and harmonized standards to help economic operators understand and comply with the regulation.
• Notified bodies offer conformity assessment services, particularly for high-risk toys or complex chemical compliance issues.
• Industry associations, such as Toy Industries of Europe (TIE), provide best practices, training, and updates on regulatory developments.