EU Toy Safety Regulation & GPSR: 2026–2030 Guide
Toy manufacturers still place toys on the EU market under Directive 2009/48/EC. The new Toy Safety Regulation (EU) 2025/2509 entered into force on 1 January 2026, but its main product duties apply from 1 August 2030. The General Product Safety Regulation (GPSR) only fills the safety gaps that the toy rules do not cover.
Which toy-safety law applies between 2026 and 2030?
What counts is the date you place the toy on the market. The new Regulation is already in force, but during the transition the Directive is still the rule you must meet to sell.
| Date or product status | Applicable position | Practical consequence |
|---|---|---|
| 1 January 2026 | Regulation (EU) 2025/2509 entered into force | Businesses can prepare for the new chemical, digital-product-passport and enforcement structure |
| Through 31 July 2030 | Directive 2009/48/EC remains applicable to toys placed on the market | Use the Directive's safety assessment, conformity assessment, technical file, EU Declaration of Conformity and CE-marking route |
| From 1 August 2030 | Regulation (EU) 2025/2509 applies and repeals the Directive | New toys must follow the Regulation, including the toy digital product passport |
| Toy placed on the market in conformity with the Directive before 1 August 2030 | Protected by the new Regulation's transition rule | Member States may not stop it from staying on sale just because the new rules apply |
| EC-type examination certificate issued under the Directive | Valid until its own earlier expiry or 1 February 2031 | Review the certificate, product changes and conversion plan before the deadline |
The 2030 date is no reason to wait. A toy you place on the market in 2026 must meet the Directive and every other EU rule that applies to its materials, electrical or radio functions, batteries and online offer.
How do the Toy Safety Directive and GPSR work together?
The toy rules come first for the safety risks they cover. The GPSR only adds rules where EU law has no equally specific provision for the same risk. So a generic GPSR file does not replace the toy conformity route.
For a toy sold in 2026, map the Directive together with the relevant GPSR duties, the EU market surveillance regulation, chemical restrictions and any rules triggered by electrical, radio, battery or connected functions. The GPSR also sets what your online offer must show before purchase: the manufacturer, the EU economic operator, product identification and any warnings.
What must a toy manufacturer complete in 2026?
Under the Directive, the safety assessment and the technical evidence are the manufacturer's job. Importers and distributors have their own checking and cooperation duties.
| Workstream | Current 2026 requirement | Evidence to keep |
|---|---|---|
| Product classification | Decide whether the product is designed or intended, whether exclusively or not, for play by children under 14 and check exclusions or grey-zone guidance | Intended-use record, age grading, design and marketing evidence |
| Safety assessment | Analyse chemical, physical, mechanical, electrical, flammability, hygiene and radioactivity hazards and potential exposure before market placement | A written safety assessment for the exact toy, as the Directive requires |
| Conformity route | Choose internal production control, or EC-type examination plus conformity to type | Standards review, route rationale, reports and certificate where required |
| Technical documentation | Document design and manufacture, components and materials, safety assessment, standards, reports and production controls | Version-controlled technical file kept for 10 years |
| Declaration and CE marking | Draw up the EU Declaration of Conformity and affix CE marking before placing the toy on the market | Signed declaration, artwork, product and packaging records |
| Traceability and warnings | Add toy identification, manufacturer/importer details, instructions and applicable warnings in required target-country languages | Approved label, packaging, instruction and translation versions |
| EU supply chain and online offer | Name the responsible EU economic operator and show the required online-sale information | Written mandate or importer route, offer screenshots and change log |
Use the toy safety assessment and risk-analysis structure, technical documentation guide and EU Declaration of Conformity guide to keep these records connected.
Does every toy need EN 71 testing?
“EN 71” is a family of standards, not one test for every toy. You pick the parts and other standards that fit the toy's design, materials, age group, functions and hazards. Only standards published for the Toy Safety Directive in the Official Journal give the presumption of conformity. Also check any restriction attached to a published standard.
A test report answers one defined question for one identified sample. It does not replace the safety assessment, production controls, the technical file or other laws that apply. If you change a material, supplier, component, age grade or design, older evidence may no longer represent the toy.
When is a notified body required for a toy?
A laboratory and a notified body are not the same role. A competent laboratory can perform tests. A notified body designated for the Toy Safety Directive performs EC-type examination within its notified scope.
| Situation under Directive 2009/48/EC | Conformity route | Notified body? |
|---|---|---|
| Harmonised standards cover all relevant safety requirements and the manufacturer applies them | Internal production control, Module A | No EC-type examination solely because the product is new or commercially important |
| Harmonised standards do not exist for all relevant requirements | EC-type examination plus conformity to type, Module C | Yes |
| Relevant harmonised standards exist but the manufacturer does not apply them, or applies them only partly | EC-type examination plus conformity to type | Yes |
| A standard is published with a restriction affecting the toy | EC-type examination for the uncovered requirement | Yes, for the requirement the restricted standard does not cover |
| The manufacturer considers the toy's nature, design, construction or purpose requires third-party verification | EC-type examination plus conformity to type | Yes |
Find the notified body in the Commission's NANDO database and check its exact notified scope. A lab logo or an “EN 71 certificate” does not by itself prove that an EC-type examination took place.
What do CE marking and warnings prove?
With the CE marking, the manufacturer declares that the toy meets the EU rules that apply, after the correct conformity process. It is not an approval from the European Commission, a market surveillance authority, Grüner Baum or a test laboratory.
Warnings must match the toy's real hazards and intended use. A warning cannot fix an unsafe design or contradict how the toy is meant to be played with. A “not suitable under 3” symbol does not move a toy clearly made for children under 36 months into an older age group. The EU warning-label and pictogram guide separates the current toy rule, the 2030 transition and the false universal 10 mm claim. The GPSR labelling guide explains what goes on the product; the GPSR online-sales guide covers the online offer.
Do toys need a digital product passport in 2026?
The new Toy Safety Regulation creates a digital product passport for each toy model, but that system applies from 1 August 2030. A toy does not need the new toy passport in September 2026 solely because the Regulation has entered into force.
You can still prepare the data now: unique product and operator identifiers, the manufacturer and the responsible EU operator, a product image, the EU laws that apply, standards, any notified-body certificate and the CE marking. Early data work lowers the switch-over risk. Do not present a future QR code as proof of compliance today.
Does a non-EU toy manufacturer need an EU Responsible Person?
A toy needs an economic operator established in the EU. The Toy Safety Directive is one of the laws covered by the EU market surveillance regulation, so a toy may only be placed on the EU market when such an operator carries out the responsible-person tasks. By law, that operator is the EU manufacturer, the importer, an authorised representative with a written mandate or, if none of these exists, a fulfilment service provider.
A separate service is not automatic if an EU importer already holds the role. An authorised representative cannot take over the manufacturer's duty to design a safe toy, carry out the safety assessment or create the technical file. See the EU Responsible Person service and acceptance rules.
Why is current toy evidence commercially important?
On 1 September 2026, the Commission's Safety Gate search held 479 toy alerts. That is 19.1% of 2,508 alerts recorded for 2026. The EU Safety Gate child-product analysis explains the dataset and search method. The figure shows why your toy file must connect the exact product, hazard, test evidence, warning and corrective-action record. A generic certificate is not enough.
How does Grüner Baum support toy manufacturers?
Grüner Baum GmbH's GPSR compliance service can review scope, the responsible EU operator route, existing risk and technical records, labels and online offers. The optional Formal Technical Documentation Audit & Written Gap Report starts at €129 per product family. That price is not a full toy conformity assessment or a CE certificate.
Toys are specially regulated products. Testing, notified-body work and the annual authorised-representative mandate are scoped and quoted individually after document and product review. Grüner Baum does not act as a notified body and does not issue toy CE approval.
EU toy safety questions
Which EU toy safety law applies in 2026?
Directive 2009/48/EC remains the operative toy market-access framework until 31 July 2030. The new Toy Safety Regulation (EU) 2025/2509 entered into force on 1 January 2026, but its main requirements apply from 1 August 2030. The GPSR only fills gaps that the toy rules do not cover.
Do toys need a digital product passport in 2026?
No, not just because the new Toy Safety Regulation has entered into force. Its toy passport applies from 1 August 2030. A separate EU law that covers a component or function can create an earlier, independent duty.
Does every toy need a notified body?
No. You can use internal production control if you apply harmonised standards that cover all relevant safety requirements. You need an EC-type examination by a notified body when such standards are missing, restricted or not fully applied, or when you decide the toy needs a third-party check.
Is an EN 71 test report enough for EU toy compliance?
No. One EN 71 report does not prove all toy duties. You must also classify the toy, carry out the safety assessment, choose the right conformity route and keep the technical file. Then you issue the EU Declaration of Conformity, affix the CE marking and meet the traceability, warning and supply-chain duties.
Does every non-EU toy manufacturer need a separate Responsible Person service?
No. A toy needs one responsible economic operator in the EU. That can be an EU manufacturer, an importer, an authorised representative with a written mandate or, if none of these exists, a fulfilment service provider. Check first who already holds the role.
Official sources
| Topic | Legal basis | Official text |
|---|---|---|
| Dates: new Regulation in force on 1 January 2026, applies from 1 August 2030, Directive repealed | Toy Safety Regulation (EU) 2025/2509, entry into force, application and repeal provisions | Toy Safety Regulation (EU) 2025/2509 — EUR-Lex; European Commission: stronger toy-safety rules enter into force |
| Toys already on the market before 1 August 2030; EC-type examination certificates until 1 February 2031 | Regulation (EU) 2025/2509, Article 57(1) and its transitional rules for certificates | Toy Safety Regulation (EU) 2025/2509 — EUR-Lex |
| GPSR only covers risks the toy rules do not cover | GPSR Regulation (EU) 2023/988, Article 2(1) | GPSR Regulation (EU) 2023/988 — consolidated text |
| Safety assessment before market placement | Directive 2009/48/EC, Article 18 | Toy Safety Directive 2009/48/EC — current EUR-Lex act |
| Conformity routes and when a notified body is needed | Directive 2009/48/EC, Article 19, in particular Article 19(3) | Toy Safety Directive 2009/48/EC — current EUR-Lex act; European Commission: placing toys on the EU market |
| Technical file (10 years), EU Declaration of Conformity, CE marking, warnings, importer and distributor duties | Directive 2009/48/EC, economic-operator obligations, warnings and CE marking rules | Toy Safety Directive 2009/48/EC — current EUR-Lex act |
| Information in the online offer | GPSR Regulation (EU) 2023/988, Article 19 | GPSR Regulation (EU) 2023/988 — consolidated text |
| Responsible EU economic operator for toys and who can hold the role | Regulation (EU) 2019/1020, Article 4(2), 4(3) and 4(5) | Regulation (EU) 2019/1020 — Article 4 responsible economic operator |
| Toy digital product passport from 1 August 2030 | Toy Safety Regulation (EU) 2025/2509, digital product passport rules | Toy Safety Regulation (EU) 2025/2509 — EUR-Lex |
This guide is general information, not legal advice; the exact toy and its target markets decide the route.
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