A new law with a long runway
The EU’s toy rules are moving from a directive to a regulation. Regulation (EU) 2025/2509 on the safety of toys was adopted on 26 November 2025, published in the Official Journal on 12 December 2025 and entered into force twenty days later. It will replace the Toy Safety Directive 2009/48/EC – but not yet.
Under Article 59, the regulation applies from 1 August 2030. Until then, toys are placed on the market under the 2009 directive and the national laws that implement it. That gives importers four years. They will need them: the regulation adds a digital product passport for every toy, widens the chemical bans, and changes what an online listing must show.
For the rules that apply today, see our Toy Safety Directive guide. For the new regulation in short, see the glossary entry on the Toy Safety Regulation.
The key dates
| Date | What happens | Legal basis |
|---|---|---|
| 1 January 2026 | Entry into force; the rules on notifying conformity assessment bodies (Articles 28–44) and on delegated powers, committee procedure, ECHA opinions, confidentiality and penalties (Articles 49–55) apply | Article 59 |
| Until 31 July 2030 | Toys are placed on the market under Directive 2009/48/EC | Articles 56 and 59 |
| 1 August 2030 | The regulation applies; the directive is repealed | Articles 56 and 59 |
| After 1 August 2030 | Toys placed on the market in conformity with the directive before that date may still be made available | Article 57(1) |
| 1 February 2031 | EC type-examination certificates issued under the directive expire, unless they expire earlier | Article 57(3) |
The provisions applying from 1 January 2026 are mainly about the system around toys rather than the toys themselves: the notification of the conformity assessment bodies that will certify toys under the new rules, and the Commission’s powers to adopt delegated acts – including on chemicals – before the main obligations start.
The stock rule matters for importers. Article 57(1) protects toys that were placed on the market in conformity with the directive before 1 August 2030. Placing on the market means the first making available in the EU. A toy imported and placed on the market in July 2030 can still be sold afterwards; a toy still held outside the EU on 1 August 2030 must meet the regulation when it is placed on the market.
The toy digital product passport
The most visible change is the digital product passport. Under Article 19(1), before placing a toy on the market the manufacturer must create a passport for it. The passport must correspond to a specific toy model, state that compliance with the regulation has been demonstrated, contain at least the data in Part I of Annex VI, be kept accurate and up to date, and be available in the languages required by the Member State where the toy is sold.
Annex VI lists, among other things:
- the toy’s unique product identifier and, where applicable, its commodity code;
- the name and address of the manufacturer, any authorised representative and the economic operator responsible under the Market Surveillance Regulation, each with a unique operator identifier;
- a colour image clear enough to identify the toy;
- references to all Union law the toy complies with and the harmonised standards or common specifications applied;
- where applicable, the notified body and its certificate;
- the CE marking and the allergenic fragrances subject to labelling.
The passport takes over the role of the EU declaration of conformity. Before placing the toy on the market, the economic operator must also upload its unique product and operator identifiers to the registry set up under the Ecodesign for Sustainable Products Regulation (Article 22). For how that registry fits the wider picture, see our article on the first ESPR acts and the digital product passport, and the glossary entry on the digital product passport.
Chemicals and ECHA’s role
The regulation tightens the chemical requirements in Annex II, Part III. From 1 August 2030 it prohibits the presence in toys, their components or micro-structurally distinct parts of substances classified as:
- carcinogenic, mutagenic or toxic for reproduction (CMR) in category 1A, 1B or 2;
- endocrine disruptors for human health in category 1 or 2;
- specific target organ toxicants in category 1, respiratory sensitisers in category 1 and skin sensitisers in category 1A.
It also prohibits the intentional use of PFAS in toys and the presence of the bisphenols listed in the Appendix to Annex II. Derogations for specific substances can be granted by delegated act after a request has been assessed by the European Chemicals Agency. Under Article 52, ECHA gives the Commission its opinion on such requests within 12 months, extendable once by up to six months.
For importers, this means supplier declarations that cover the full list of hazard classes, not only the substances restricted under the directive. If your range includes plastic or soft toys, phthalates in toys is a good place to start.
Warnings and online listings
Under Article 6, warnings must state appropriate user limitations, including at least the minimum age of the user where necessary for safe use, and must be clearly visible to the consumer before purchase – including in distance sales. From 1 August 2030, Article 14(3) requires online marketplaces to design their interface so that sellers can provide, in addition to the information required by Article 22(9) of the GPSR, the CE marking, those warnings and the data carrier or weblink to the passport. For current warning practice, see warning texts on toys.
A transition plan for importers
- Confirm scope. Check which products in your range are toys. Borderline cases – collectibles, decorative items, sports equipment – are covered in is my product a toy?
- Inventory your certificates. List EC type-examination certificates and their expiry dates; none will be valid after 1 February 2031.
- Start the chemical conversation. Ask suppliers which toys contain substances in the new prohibited hazard classes, intentionally added PFAS or listed bisphenols.
- Prepare passport data. Unique identifiers, colour images, standards and operator identifiers per toy model – most of it already sits in today’s technical file.
- Plan the stock cut-over. Toys must be placed on the market before 1 August 2030 to benefit from Article 57(1).
- Follow the delegated and implementing acts the Commission adopts before 2030, including those on passport access rights and chemical exemptions.
How Conphora helps
The Toy Safety Regulation turns today’s technical file into tomorrow’s passport. Conphora helps you get there step by step:
- Toy records per model with identifiers, images, standards and responsible operators – the core of Annex VI.
- Certificate tracking with expiry dates and the 1 February 2031 cut-off.
- Supplier chemical declarations stored against each toy and component.
- A transition calendar for the directive-to-regulation switch.
Four years sounds long until the passport data has to exist for every model. Start with your certificates and suppliers. See plans and pricing →