Updated: 18 August 2026
Regulation (EU) 2025/2509 on toy safety entered into force on 1 January 2026. It will generally apply from 1 August 2030, when it replaces Directive 2009/48/EC. For toy manufacturers and exporters, the transition period is intended for a structured upgrade of chemical-risk controls, testing plans, technical documentation and Digital Product Passport (DPP) data—not for postponing the review until 2030.
The regulation covers products designed or intended, whether exclusively or not, for play by children under 14, including toys sold online and toys imported from outside the EU. Specific exclusions are listed in Annex I. CE marking remains, but the evidence supporting conformity and the way authorities access that evidence will evolve.
Three dates to keep separate
- 1 January 2026: the new regulation entered into force.
- 1 August 2030: the regulation generally applies and Directive 2009/48/EC is repealed.
- 1 February 2031: EC type-examination certificates issued under the former directive generally cease to be valid, unless they expire earlier.
Toys that were placed on the EU market in compliance with Directive 2009/48/EC before 1 August 2030 may continue to be made available under the transition provision. The legal concept of “placed on the market” is important; it should not automatically be replaced with the manufacturing date or export date.
A wider chemical-safety framework
The regulation expands protection beyond the existing controls for substances classified as carcinogenic, mutagenic or toxic for reproduction. Public guidance from the European Commission and Council highlights controls covering:
- endocrine disruptors and substances affecting the respiratory system or specific organs;
- specified skin sensitisers, fragrance allergens and preservatives;
- PFAS and bisphenols; and
- toys with a biocidal function or treated with biocidal products, subject to limited exceptions.
This does not mean that every toy should receive the same indiscriminate test package. Chemical safety should still be evaluated using the material composition, accessibility, intended age, foreseeable use and reliable supply-chain information. The resulting testing plan should target the risks identified for the actual product.
The Digital Product Passport becomes part of toy compliance
Every toy will require a DPP that makes safety and compliance information accessible through a data carrier. Consumers, customs and market-surveillance authorities will be able to access the relevant information, including for products sold online or imported into the EU.
A DPP is more than an extra QR code. Product identifiers, model information, manufacturer and importer details, conformity data, warnings and technical-document references need to remain consistent over time. Changes to the product or its evidence must flow through to the digital record. Building the data model and assigning ownership now is usually more reliable than a large data-conversion exercise immediately before 2030.
A transition roadmap for exporters
- Inventory products and materials. Map bills of materials, coatings, inks, adhesives, soft plastics, electronic components, fragrance or preservative systems, and child-accessible parts by product family.
- Compare old and new requirements. Map existing EN 71, mechanical, physical, flammability, chemical, electrical, hygiene and warning evidence against the new regulation and identify new chemical or documentation gaps.
- Strengthen supplier controls. Add critical-substance, traceability and change-notification requirements to purchasing specifications. Do not leave every risk for finished-product testing.
- Design the DPP dataset. Standardise model and batch identifiers, economic-operator data, CE and conformity information, warnings and report references. Assign responsibilities for creation, approval and maintenance.
- Plan retesting and certificate transition. Use the product lifecycle, redesign schedule and expiry of existing EC type-examination certificates to work backwards from the relevant market date.
How Qianxin can support your transition
Based on the toy type, intended age, materials and sales channel, Qianxin can assist with EU regulatory and standards scoping, mechanical/physical and flammability test planning, selection of relevant chemical tests, CE technical-information preparation and planning of the underlying DPP dataset. Any project involving a notified body, a specific conformity-assessment route or a defined laboratory-recognition scope should be confirmed once complete product information is available.
This is general transition guidance. It does not mean that all new requirements are already fully applicable in 2026 and does not replace a product-specific safety assessment or final conformity decision.
