EU Toys Safety Regulation 2025-2509
On December 12, 2025, Regulation (EU) 2025/2509 on the safety of toys was published and becomes officially operative. It will apply starting from August 1, 2030.
The reform introduces stricter requirements, updates the rules in response to the growth of e-commerce, and addresses new scientific evidence on chemical risks. This regulatory evolution is crucial for all operators in the sector, from manufacturers to importers and online marketplaces.
The three pillars of the reform are:
- Overcoming Directive 2009/48/EC: Old rules are replaced by a new, more robust regulatory framework suitable for current challenges.
- Introduction of the Digital Product Passport (DPP): Becomes mandatory for all toys, ensuring complete traceability and immediate access to safety information.
- Extension of Chemical Bans: New dangerous substances are banned, including endocrine disruptors, PFAS (“forever chemicals”), and the most harmful bisphenols.
Why a new regulation on toy safety?
The update of the regulation responds to a market context that has radically changed. The 2009 Directive has become obsolete in the face of the exponential increase in online sales, often from non-EU sellers, and the most recent scientific discoveries regarding the risks associated with certain chemical substances.
The new regulation aims to fill these gaps, guaranteeing that only safe and compliant toys can circulate in the single European market.
The data that guided this reform highlight a clear need for intervention:
- Second category at risk: Toys represent the second most reported consumer product category in the EU rapid alert system (Safety Gate), indicating a worrying frequency of non-compliance.
- Import flows: In 2023, the EU imported toys worth 6.5 billion euros, with 80% coming from China. This massive volume requires more effective customs controls and modern surveillance tools.
To counter the massive flow of imports and the frequency of Safety Gate alerts, the EU introduces the Digital Product Passport: a tool designed to make customs controls not only faster but surgically precise.
What does the Digital Product Passport (DPP) introduce?
The Digital Product Passport (DPP) is the main innovation introduced to improve the traceability of toys and market surveillance. Its purpose is to make information related to compliance and safety immediately accessible to customs authorities, surveillance bodies, and consumers, strengthening trust and transparency throughout the supply chain.
The DPP is a new obligation that revolutionizes customs controls and transparency towards consumers.
The key functions and requirements of the Digital Product Passport include:
- Visibility: The DPP must be clearly visible on all toys.
- Compliance: Acts as digital proof that the product respects all EU safety rules.
- Efficiency: Simplifies and makes border controls and market surveillance activities faster and more efficient.
- Access for consumers: Offers consumers facilitated access to safety information, warnings, and instructions, for example by scanning a QR code.
For operators, this means a complete digitalization of compliance documentation, which must be integrated into production and logistics processes from the origin.
Which chemical substances are banned or limited?
The new regulation imposes a chemical de-risking agenda without precedent. The goal is no longer just to limit, but to proactively eliminate entire classes of substances from materials destined for toys.
The list of prohibited substances is expanded to include endocrine disruptors, PFAS, and other compounds harmful to health.
The new chemical bans are structured as follows:
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Extension of general bans: The existing ban for substances classified as
carcinogenic, mutagenic, or toxic for reproduction (CMR) is extended to include:
- Endocrine disruptors.
- Substances that damage the respiratory system.
- Toxic substances for specific organs, including skin sensitizers.
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Specific bans: A ban is introduced on the intentional use of:
- Per- and polyfluoroalkyl substances (PFAS), known as “forever chemicals”.
- The most dangerous types of bisphenols.
- Allergenic fragrances: A total ban on allergenic fragrances is foreseen in toys intended for children under 3 years of age or in those designed to be put in the mouth.
What are the new obligations for manufacturers and importers?
The new regulation imposes direct and verifiable responsibility on every operator in the supply chain, eliminating gray areas and making every actor, including marketplaces, legally responsible for the compliance of products sold.
Clearer responsibilities are defined to guarantee that only safe and compliant toys reach the market.
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For Manufacturers:
- Perform a complete safety assessment covering all potential hazards: chemical, physical, mechanical, electrical, flammability, hygiene, and radioactivity.
- Include in the assessment also risks to mental health deriving from toys with digital components (e.g., designs that induce addiction, exposure to inappropriate content, or privacy risks).
- Affix clear warnings written in easily understandable language.
- Immediately inform surveillance authorities and consumers if risks emerge, taking all necessary corrective measures.
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For Online Marketplaces:
- In line with the Digital Services Act (DSA), online platforms must guarantee that sellers clearly display the CE marking, safety warnings, and the Digital Product Passport.
- Toys not compliant with safety requirements must be considered and treated as “illegal content“. This obliges platforms to treat listings of non-compliant toys with the same urgency with which they handle other illicit content, including rapid notification and removal mechanisms.
To allow all operators to adjust production processes and technical documentation, a transition period of 4 and a half years is foreseen from the entry into force of the regulation before these obligations become fully applicable.
Frequently Asked Questions (FAQ)
1. Is the Digital Product Passport (DPP) mandatory for all toys?
Yes. All toys placed on the EU market will be required to have a Digital Product Passport. This tool will improve traceability and make controls more efficient, guaranteeing rapid access to safety information for authorities and consumers. Companies must therefore plan the integration of the DPP into every product label and traceability system.
2. What are the main new categories of banned chemical substances?
The new regulation bans the intentional use of PFAS (“forever chemicals”) and the most dangerous bisphenols. It also extends the ban to endocrine disruptors, substances harmful to the respiratory system, and allergenic fragrances in toys for young children.
3. What are the main obligations of the manufacturer?
The manufacturer must ensure that the toy has been designed and manufactured in accordance with essential safety requirements. They are required to draw up technical documentation, execute the safety assessment, create the Digital Product Passport, and affix the CE marking.
4. What are the specific obligations for the importer?
The importer must ensure that the manufacturer has carried out the conformity assessment procedure and drawn up the technical documentation. They must also ensure that the toy bears the CE marking, the Digital Passport, and necessary warnings, and that storage or transport conditions do not compromise its compliance.
5. What responsibilities do online marketplaces have?
Marketplaces must verify that safety information, such as the CE marking and the Digital Product Passport, are visible in listings. Unsafe toys must be treated as “illegal content” and removed immediately from sale.
Do you need support for the new regulation?
Check the compliance of your products and prepare for the Digital Product Passport (DPP).
