EU Toy Safety Regulation (TSR) FAQ

On December 12, 2025, the EU published the Toy Safety Regulation (EU) 2025/2509 (TSR). It will replace the Toy Safety Directive (2009/48/EC) which has been in place since 2009. The Regulation represents a major update to the EU’s toy safety framework, aiming to strengthen health and safety protection for children and to modernise rules for today’s market realities. It introduces restrictions on more chemicals, the Digital Product Passport, new risks related to cybersecurity, new rules for warnings, stronger responsibilities over the supply chain, and more. Updated compliance to the new Regulation will be mandatory from August 1, 2030, following a transition period of 4.5 years. Toy businesses will be affected at multiple levels of their operations and should start preparing now to adapt their processes, documentation, and testing programmes in time for full compliance. 

The TSR applies to all toys placed on the EU market for children up to 14 years of age, including:

• Physical toys (traditional toys, dolls, construction sets, etc.) 
• Digital and connected toys (smart toys, app-integrated toys) 
• Toys imported or manufactured in the EU for sale in EU Member States

It sets out rules for: 

• Safety requirements (specified requirements for mechanical, chemical, electrical, flammability, hygiene, and radioactivity) 
• Chemical restrictions (CMRs, endocrine disruptors, PFAS, etc.) 
• Labelling, packaging, and warnings 
• Traceability and documentation (including the Digital Product Passport)

Unlike the Directive, the TSR is a Regulation, meaning it is directly applicable across all EU Member States with uniform implementation, removing the variability previously caused by national transposition.

According to the TSR, a toy is any product or material designed or intended, whether exclusively or not, for use in play by children under 14 years of age. This definition remains largely consistent with the former Toy Safety Directive (2009/48/EC), but the Regulation clarifies that “play” includes all products intended for stimulation, amusement, or learning, including digital and connected toys. Non-toy products, even if children play with them (like certain household items), are not automatically considered toys under the TSR. 
If you’re unsure whether your product qualifies as a toy, contact our experts. 

If you sell “toy-like” items — such as promotional gifts for children, novelty products, or collectibles — you must first determine whether your product meets the definition of a “toy” under the EU Toy Safety Regulation. 
A toy is defined as any product designed or intended, whether exclusively or not, for use in play by children under 14 years of age. 
This means that even if your product’s main function is decorative or promotional, it may still be considered a toy if it is intended — or likely to be perceived — as something for children to play with. If that’s the case, it must comply fully with the Toy Safety Regulation and carry the CE marking before being placed on the EU market. 
If you’re unsure whether your product qualifies as a toy, you should perform an assessment based on its design, presentation, and target users, or consult our experts. 

Full compliance with the Toy Safety Regulation (TSR) will be required to place toys on the EU market once the transition period ends. Preparing early is important because it may involve updating processes, documentation, testing programmes, and supply-chain traceability. Complying early with the TSR offers several benefits: 

• Uniform EU compliance: Unlike the former Directive, the Toy Safety Regulation is directly applicable in all Member-States, ensuring uniform implementation. Ensuring compliance to the TSR means you’ll be compliant EU-wide, without variability in national implementation.
• Uninterrupted market access: Demonstrating TSR compliance can help you continue selling without delays or national restrictions.
• “TSR-ready” status for customers and partners: Early compliance signals reliability to retailers, distributors, and customers.
• Reduced risk: Anticipating stricter requirements, particularly on chemicals and traceability, lowers the risk of market surveillance actions, product recalls, or reputational damage.
• Streamlined internal processes: Upgrading compliance often improves supplier control, material traceability, testing programmes, and overall product quality, which can reduce defects, returns, and customer complaints. 

The Toy Safety Regulation (TSR) updates and strengthens the EU’s toy safety rules. Key changes include: 

• Stricter chemical requirements: Expanded restrictions for PFAS, endocrine disruptors, and other hazardous substances, beyond CMRs.
• Digital Product Passport (DPP): Each toy model must have a digital record with safety and traceability information, accessible via a data carrier (e.g., QR code). 
• New provisions for connected toys: The TSR includes rules addressing cybersecurity and data protection risks for digital and connected toys.
• Stronger supply-chain responsibilities: Clearer obligations for manufacturers, importers, distributors, and online marketplaces. 
• New rules for labelling and warnings: age grading recommandations, pictograms, and links to the DPP. 

These updates ensure safer toys, greater transparency, and uniform compliance across the EU. 

The Toy Safety Regulation (TSR) introduces stricter chemical rules for toys compared to the Toy Safety Directive: 

• Expanded substance restrictions: In addition to CMRs (carcinogenic, mutagenic, reproductive-toxic substances) and heavy metals, the TSR now restricts endocrine disruptors, organo-toxic substances, respiratory and certain skin sensitisers, PFAS (“forever chemicals”), and inhalation allergens.
• Emphasis on bisphenols: Use of certain bisphenols (listed in part D of the Appendix of the regulation) in toys and toy components is prohibited, and limits for Bisphenol A are stricter.
• PFAS ban: The intentional use of per- and polyfluoroalkyl substances (PFAS) in toys, components of toys or micro-structurally distinct parts of toys, is prohibited.
• Specific chemical limits: New migration limits are set for styrene, acrylonitrile, butadiene, and vinyl chloride. Five categories of toys with migration limits for N-nitrosamines and N-nitrosatable substances were introduced, with new limits for finger paints, slimes and putties. 

This requires deeper chemical risk assessments and possibly additional testing for previously less-emphasised substances. 

The Toy Safety Regulation (TSR) introduces a Digital Product Passport (DPP) for each toy model or type to improve traceability, transparency, and regulatory oversight. 
 
Key points: 

• The DPP must be accessible via a data carrier, such as a QR code, on the toy (where not possible on the toy itself, it should be on the packaging or in the instructions) and it shall be visible at purchase, including online.
• It must include information such as the product identifier, a unique operator identifier, CE mark, harmonised standards used, substances of concern, etc.  
• Up to date technical documentation and risk assessment information must be uploaded to the DPP.
• The DPP replaces the Declaration of Conformity of the Toy Safety Directive (2009/48/EC)
• The European Commission will define the technical requirements for the DPP during the transition period, no later than 18 months before the TSR becomes fully enforceable.

This means businesses will need to prepare documentation and digital traceability systems ahead of full compliance.  

Under the EU Toy Safety Regulation (TSR), toys must have clear warnings and labels visible to consumer before purchase, including online. And not just those warnings related to decision to purchase. 
 
There are new requirements for data carriers (QR codes or similar) to link the toy to its Digital Product Passport (DPP).  The TSR also introduces enhanced warning and labelling, and information about the company placing the toy product on the EU market. The updated requirements include for instance: 

• General warnings (where necessary) specifying minimum/maximum age, required abilities, or weight.
• Font size requirements.
• Warnings must include the word “Warning” or a triangle pictogram as specified in the TSR.
• Age grade recommendations, pictograms, and supply-chain responsibilities for importers, distributors, and fulfilment providers 

These updates ensure better safety information, traceability, and compliance across all EU sales. Contact us to verify your labelling, packaging and consumer information.

The Toy Safety Regulation (TSR) explicitly adds “food imitation,” “obstruction of intestines,” and “magnets” as specific essential safety requirements (ESRs) in Annex II of the new Regulation. These hazards were already addressed under the Toy Safety Directive (TSD) — but only indirectly, through the general safety requirements or harmonised standards (e.g., EN 71-1).
Under the new Regulation, they now have stronger legal status and must be explicitly assessed and documented in the conformity assessment process. 

If you manufacture, import, distribute or retail toys (defined as “products for use in play by children under 14 years of age” under the TSR) you are in scope and hold responsabilities. This includes:

• Toy manufacturers in the EU (or outside the EU placing under their name/brand) 
• Brands/own-labellers who contract production and place their brand on the market 
• EU importers bringing toys into the EU 
• EU distributors, fulfilment services (warehousing, packaging, shipping) and online marketplaces engaged in toy sales 
• Retailers and e-commerce platforms selling toys into the EU market 
• Anyone in the supply-chain who places a toy on the EU market, whether physical shop or online. 

The new Toy Safety Regulation requires that only one single EU contact address is indicated on the toy, its packaging, or accompanying documentation. 
This address must belong to the responsible economic operator (manufacturer, importer, or authorised representative) established in the EU. 
The change aims to make it clear who is accountable for the toy’s compliance and to simplify traceability for market surveillance authorities and end user. 

Here’s how the regulatory change translates into practical steps and implications for your business. This is where your testing & QA service becomes a strategic asset. 
 
Review and update your compliance documentation 

• Your current EU Declaration of Conformity (DoC) will eventually be replaced by the Digital Product Passport (DPP) under the TSR. This means you will need to prepare a DPP per toy-model showing all required data. 
• The technical documentation you maintain must be reviewed and updated to include the broader chemical hazard screening (EDCs, PFAS, sensitizers etc). 
• You’ll need to ensure you retain documentation and traceability for the longer durations required  
• Your labelling/packaging must be updated: the data-carrier (e.g., QR-code) linking to the DPP, plus more explicit warnings, CE mark location, age warnings, etc. 

Enhanced testing and chemical risk assessment 

• Even if you already test to EN 71 (Parts 1-3 etc) and other current harmonised standards, you should proactively check whether additional tests will be required under the Toy Safety Regulation (TSR) — for example for substances now newly restricted, PFAS traces. 
• If your supply-chain uses materials/components that previously were considered low-risk under the Directive, you may now face new scrutiny (e.g., for endocrine-disrupting substances or subtle organ-toxicity mechanisms) — you will likely require more in-depth chemical analytics, supplier-material audits and perhaps third-party testing laboratories. 
• You’ll want to update your risk-assessment process and good manufacturing practice (GMP) for toy production: design review, component change control, traceability of materials, supplier qualification. 

Supply-chain and marketplace readiness 

• If you are an importer/distributor or operate online marketplaces, you will be required to verify that your toys comply with the TSR, that the manufacturer has prepared the DPP, that you keep records, that you display the required information (CE mark, warnings, link to DPP) on your platform. You’ll need procedures for verifying upstream conformity and responding to non-conformance (e.g., withdrawal / recall). 
• Online marketplaces must adapt their user interface so that before the purchase a child or parent can see the CE mark, warnings and link to the DPP.  
• Logistics/fulfilment services must ensure they handle toys only when they meet the compliance chain requirements. 

Timing and transition planning 

• If you continue placing toys under the old Directive regime, you must monitor when that route no longer remains valid — after the transition period toys not compliant with the TSR may be prevented from being placed. 
• Use the transition period time to upgrade your internal systems: tracking, documentation, supply-chain transparency, testing programmes, labelling/packaging redesign and updating your conformity assessment strategy. 

• Conduct a gap-analysis: compare your current compliance status under TSD with the likely requirements under TSR. 
• Map out your product-portfolio: which toy models, which suppliers, which materials may be impacted. 
• Update your testing programme: ensure your labs and materials are ready for new chemical scope. 
• Review your documentation and labelling: prepare for DPP, data-carrier, updated warnings, CE mark visibility etc. 
• Engage your supply-chain: communicate the upcoming changes with your suppliers, ensure material traceability and supplier qualification. 
• Partner with a testing/compliance expert (that’s us!) to guide you through this transition. 

The EU Toy Safety Regulation (EU) 2025/2509 (TSR) was published in the Official Journal of the European Union on December 12, 2025. The regulation will enter into force on January 1, 2026, and will fully apply on August 1, 2030 (after a transition period of approximately 4.5 years).
 
The European Commission is expected to adopt the delegated act defining the DPP technical specifications at least 18 months before full enforcement begins. Guidelines on the DPP are also expected to be published 1 year before full enforcement.

Manufacturers remain responsible for the design, production, documentation, and conformity assessment of their toys. Key obligations include: 

• Technical documentation and safety assessment: Prepare a technical file, assess risks, and conduct conformity assessment.
• Digital Product Passport (DPP): Create a DPP for each toy model or type, including a visible data carrier on the toy, packaging, or instructions. The DPP must be accessible at the point of purchase, including online.
• Product registration: Upload the unique product identifier and operator identifier to the EU Product Passport registry.
• Contact information: Include contact details as specified in the Toy Safety Regulation if the manufacturer is the responsible economic operator established in the EU.  
• Market surveillance & consumer information: Immediately inform authorities via the Safety Business Gateway and notify consumers and marketplaces if a risk is detected. 

 Importers are responsible for ensuring that toys placed on the EU market comply with the TSR. Key obligations include: 

• Verify manufacturer compliance: Confirm that the manufacturer has created a DPP and that toys bear a data carrier.
• Product registration: Ensure the DPP is registered in the EU Product Passport registry.
• Contact information: Include contact details as specified in the Toy Safety Regulation if the importer is the responsible economic operator established in the EU.  
• Consumer & authority notification: Inform customers and authorities if a hazardous product is identified. Ensure manufacturer communication channels are operational.
• Upstream control: Check that manufacturers comply with TSR requirements, including CE marking and safety documentation. 

Distributors must verify that the toys they sell comply with the TSR. This includes: 

• Checking manufacturer and importer obligations: Ensure the toy has CE marking, a DPP, and correct safety documentation.
• Traceability and supply chain control: Maintain awareness of upstream compliance and act if a toy is found to pose a risk. 

Online marketplaces facilitating toy sales must comply with the General Product Safety Regulation (GPSR 2023/988/EU) and TSR requirements. Key obligations include: 

• Display product information: Ensure all critical safety information (CE marking, DPP link, warnings) is clearly visible to consumers before purchase.
• Upstream compliance verification: Confirm that suppliers provide compliant toys.
• Consumer protection: Support authorities and notify consumers in case of hazardous products. 

If a toy product was lawfully placed on the EU market under the former Toy Safety Directive regime prior to the full applicability of the Toy Safety Regulation, then complying means that the economic operator who placed the product on the market needs to be able to demonstrate they conducted suitable risk assessment according to the GPSR. 

Discover our services for toy manufacturers, importers and retailers in the EU market. Our experts will guide you through the requirements of the TSR, including testing, quality assurance, inspection and certification, to ensure your products are compliant and your processes are optimally prepared for the transition.