EU Toy Safety Regulation & GPSR: 2026–2030 Guide
As of 1 September 2026, 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 obligations apply from 1 August 2030. The General Product Safety Regulation (GPSR) remains a complementary safety net for matters not covered by equally specific toy rules.
What changed in this EU toy-safety guide?
- 1 September 2026: Added the enacted Toy Safety Regulation (EU) 2025/2509 and its 2030 application date.
- 1 September 2026: Corrected the claim that every new or complex toy needs a notified body.
- 1 September 2026: Separated laboratory testing, EC-type examination, CE marking, the EU economic operator and the future digital product passport.
Which toy-safety law applies between 2026 and 2030?
The date on which a toy is placed on the market controls the transition. The new Regulation is legally in force, but the Directive remains the current market-access rule during the adaptation period.
| 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 | Transitional protection under Regulation (EU) 2025/2509 Article 57(1) | Member States may not prevent its continued making available solely because the new regime applies |
| 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 not a reason to delay current compliance. Toys placed on the market in 2026 must meet the Directive and every other EU rule applicable to their materials, electrical or radio functions, batteries and online offer.
How do the Toy Safety Directive and GPSR work together?
Toy-specific law controls safety objectives it regulates. GPSR Article 2 makes the general framework complementary where Union law does not contain equally specific provisions for the same safety objective. Do not prepare a generic GPSR file and assume it replaces the toy conformity route.
For a 2026 toy, the manufacturer should map the Directive together with the relevant GPSR duties, Regulation (EU) 2019/1020, chemical restrictions and any legislation triggered by electrical, radio, battery or connected functions. GPSR Article 19 also matters to the distance-sale offer: required manufacturer, EU economic operator, product identification and applicable warning information must be visible before purchase.
What must a toy manufacturer complete in 2026?
Directive 2009/48/EC assigns the safety assessment and technical evidence to the manufacturer. Importers and distributors have their own verification 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 | Directive 2009/48/EC Article 18 safety assessment linked to the exact toy |
| Conformity route | Choose internal production control or EC-type examination plus conformity to type under Directive 2009/48/EC Article 19 | 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 | Identify the Article 4 EU economic operator and display required distance-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 universal toy test. The manufacturer must identify the parts and other standards relevant to the toy's design, materials, age group, functions and hazards. Only references published for the Toy Safety Directive in the Official Journal can give the relevant presumption of conformity, and any restriction attached to a reference must be checked.
A test report answers a defined question for an identified sample. It does not replace the Directive 2009/48/EC Article 18 safety assessment, production controls, technical documentation or the duty to consider other applicable legislation. A material, supplier, component, age grade or design change can make earlier evidence unrepresentative.
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, as required by Directive 2009/48/EC Article 19(3) |
| The manufacturer considers the toy's nature, design, construction or purpose requires third-party verification | EC-type examination plus conformity to type | Yes |
Select the notified body through the Commission's NANDO database and confirm its exact notification scope. A laboratory logo or an “EN 71 certificate” does not by itself prove that an EC-type examination was performed.
What do CE marking and warnings prove?
CE marking is the manufacturer's declaration that the toy complies with applicable EU harmonisation requirements after the correct conformity process. It is not an approval issued by the European Commission, a market-surveillance authority, Grüner Baum or a test laboratory.
Warnings must follow the toy's real hazards and intended use. A warning cannot fix an unsafe design, contradict the toy's intended play pattern or reclassify a toy clearly intended for children under 36 months merely by adding a “not suitable under 3” symbol. 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 physical placement; the Article 19 online-sales guide covers the distance-sale offer.
Do toys need a digital product passport in 2026?
Regulation (EU) 2025/2509 creates a model-level digital product passport for toys, but that regime 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.
Manufacturers should still prepare the data now: unique product and operator identifiers, manufacturer and Article 4 operator, product image, applicable EU law, standards, notified-body certificate where relevant and CE marking. Early data mapping reduces the conversion risk without presenting a future QR code as current proof of compliance.
Does a non-EU toy manufacturer need an EU Responsible Person?
Directive 2009/48/EC is listed in Article 4(5) of Regulation (EU) 2019/1020. A toy can therefore be placed on the EU market only when an EU-established economic operator performs the Article 4(3) tasks. The statutory route is the EU manufacturer, importer, authorised representative with a written mandate or, if those actors do not exist, 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, perform 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 contained 479 toy alerts, representing 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 a toy file must connect the exact product, hazard, test evidence, warning and corrective-action record rather than rely on a generic certificate.
How does Grüner Baum support toy manufacturers?
Grüner Baum GmbH's GPSR compliance service can review scope, the Article 4 operator route, existing risk and technical records, labels and online offers. The optional Formal Technical Documentation Audit & Written Gap Report starts at €129 plus VAT per product family, but that price is not an all-inclusive toy conformity assessment or 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. Regulation (EU) 2025/2509 applies from 1 August 2030.
Do toys need a digital product passport in 2026?
Not solely under the new Toy Safety Regulation. Its toy DPP requirement applies from 1 August 2030.
Does every toy need a notified body?
No. The conformity route depends on coverage and use of relevant harmonised standards and the conditions in Directive 2009/48/EC Article 19.
Is an EN 71 test report enough for EU toy compliance?
No. The complete route also includes classification, safety assessment, technical documentation, production control, EU Declaration of Conformity, CE marking, traceability, warnings and supply-chain duties.
Does every non-EU toy manufacturer need a separate Responsible Person service?
No. First determine whether the EU manufacturer, importer, authorised representative or fulfilment service provider holds the Article 4 role.
Official sources
- Toy Safety Regulation (EU) 2025/2509 — EUR-Lex
- Toy Safety Directive 2009/48/EC — current EUR-Lex act
- European Commission: stronger toy-safety rules enter into force
- European Commission: placing toys on the EU market
- Regulation (EU) 2019/1020 — Article 4 responsible economic operator
- GPSR Regulation (EU) 2023/988 — consolidated text
This guide provides general information. Toy classification, standards, tests, warnings and the conformity route must be assessed for the exact product and target markets.
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