We do not know which warnings a toy needs
Under the Toy Safety Directive 2009/48/EC, where needed for safe use, a toy carries warnings on user limitations, at least the minimum or maximum age, and the specific warnings in Annex V, Part B for its category, points 2 to 10 as worded. Warnings start with ‘Warning’; those that decide the purchase are visible before purchase, also online. Regulation (EU) 2025/2509 replaces the directive from 1 August 2030.
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Reviewed 4 October 2026 by the Conphora compliance team · Not legal advice
Why this happens
Toys follow a general rule and a list. Under the Toy Safety Directive 2009/48/EC, toys must not jeopardise the safety or health of users when used as intended or in a foreseeable way, bearing in mind the behaviour of children, and labels and instructions draw attention to the inherent hazards and how to avoid them (Article 10(2)). Where appropriate for safe use, the warnings specify user limitations under Annex V, Part A: at least the minimum or maximum age and, where appropriate, the abilities and weight of the user and the need for adult supervision (Article 11(1)).[1]
For the categories in Annex V, Part B, the warnings set out there are used, and those in points 2 to 10 are used as worded (Article 11(1)). The categories are toys that might be dangerous for children under 36 months, activity toys, functional toys, chemical toys, skates, scooters and toy bicycles, aquatic toys, toys in food, imitations of protective masks and helmets, toys strung across a cradle, cot or pram, and packaging for fragrances in olfactory games, cosmetic kits and gustative games (Annex V, Part B, points 1 to 10). A toy must not carry a specific warning that conflicts with its intended use (Article 11(1)).[1]
The directive also says how warnings are shown. The manufacturer marks them clearly, legibly, understandably and accurately on the toy, an affixed label or the packaging and, if appropriate, in the instructions; small toys sold without packaging have the warnings affixed to them; and warnings begin with ‘Warning’ or ‘Warnings’ (Article 11(2)). Warnings that determine the decision to purchase, such as minimum and maximum ages, appear on the consumer packaging or are otherwise clearly visible before purchase, including online (Article 11(2)). A Member State may require the warnings and safety instructions in a language easily understood by consumers (Article 11(3)).[1]
Online sellers carry the same warnings. Under the General Product Safety Regulation, an online offer clearly and visibly shows any warning or safety information to be affixed to the product or its packaging under the applicable Union harmonisation legislation, in a language easily understood by consumers in the Member State concerned (Regulation (EU) 2023/988, Article 19(d)).[3]
A new regulation is adopted. Regulation (EU) 2025/2509 on the safety of toys was published on 12 December 2025, entered into force on the twentieth day after publication (1 January 2026) and applies from 1 August 2030; Articles 28 to 44 (notification of conformity assessment bodies) and 49 to 55 (among them delegated powers, committee procedure and penalties) apply from 1 January 2026 (Article 59). It repeals the directive from 1 August 2030 (Article 56). Its Article 6 keeps the user limitations, now including at least the minimum age of the user, and the category warnings in its Annex III, and requires all those warnings to be clearly visible before purchase, including in distance sales (Article 6(1) to (3)). Annex III, point 1, adds presentation rules: warnings are preceded by ‘Warning’ or a generic pictogram, and characters have an x-height of at least 1.2 mm (0.9 mm where the largest surface of the packaging is under 80 cm²). Toys placed on the market in conformity with the directive before 1 August 2030 may continue to be made available (Article 57(1)).[2]
How to solve it
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Set the user limitations for the toy
Decide the minimum or maximum age of the user and, where relevant, the abilities, the minimum or maximum weight, and whether the toy must only be used under adult supervision. These are the general warnings every toy carries where they are needed for safe use.
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Check whether the toy is in a Part B category
Annex V, Part B lists categories with their own warnings: toys that might be dangerous under 36 months, activity toys, functional toys, chemical toys, skates and scooters, aquatic toys, toys in food, imitation protective masks, cot and pram toys, and fragrances in certain games. Points 2 to 10 must be used as worded.
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Do not add warnings that contradict the toy's use
A toy must not bear a specific warning that conflicts with its intended use as determined by its function, dimensions and characteristics. Check each Part B warning against what the toy is designed for before you print it.
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Place the warnings where the buyer sees them
Mark the warnings clearly, legibly and accurately on the toy, an affixed label or the packaging, and where appropriate in the instructions. Begin with ‘Warning’ or ‘Warnings’. Age limits and other purchase-deciding warnings go on the consumer packaging or are otherwise visible before purchase, including online.
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Write them in the language of each market
Member States may require the warnings and safety instructions in a language or languages easily understood by consumers. Online offers repeat the warnings in that language. Keep a translation table per market with the exact Annex V wording.
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Plan for the Toy Safety Regulation
Regulation (EU) 2025/2509 applies from 1 August 2030 and repeals the directive from that date. Its Article 6 and Annex III set the warnings, including visibility before purchase in distance sales. Annex III adds presentation rules: ‘Warning’ or a generic pictogram, and a minimum character size (x-height of at least 1.2 mm, or 0.9 mm on small packaging). Toys placed on the market in conformity with the directive before 1 August 2030 may continue to be made available.
Work through the steps in the platform with your own product.
What you need to show
| Document | Where it comes from | Legal ground |
|---|---|---|
| Warning texts per toy and per language, with the Annex V point they come from | The manufacturer | Directive 2009/48/EC Article 11 and Annex V |
| Artwork of the packaging and label showing the warnings | The manufacturer | Directive 2009/48/EC Article 11(2) |
| The online offer with the warnings | The seller | GPSR Article 19(d); Directive 2009/48/EC Article 11(2) |
If you do nothing
Authorities can order warnings, a withdrawal or a recall
Where a toy does not conform, market surveillance authorities require corrective action, which may include affixing clear warnings, withdrawal or recall; if the operator fails to act, they ensure the toy is withdrawn or recalled or its sale is prohibited (Regulation (EU) 2019/1020 Article 16(2), (3) and (5)).[4]
The online offer must carry the warnings
An online offer must show any warning or safety information to be affixed to the product or packaging under the applicable Union harmonisation legislation, in a language easily understood by consumers (GPSR Article 19(d)).[3]
Questions about this problem
Is ‘not suitable for children under 36 months’ needed on every toy?
No. It is for toys that might be dangerous for children under 36 months, with a brief indication of the specific hazard, and does not apply to toys manifestly unsuitable for that age group (Directive 2009/48/EC Annex V, Part B, point 1).
Can we write the warning in our own words?
For points 2 to 10 of Annex V, Part B, no: those warnings are used as worded (Directive 2009/48/EC Article 11(1)). Point 1 allows the listed wordings or the graphic symbol.
Must the warnings appear in our web shop?
Yes. Warnings that determine the decision to purchase must be clearly visible before the purchase, including online (Directive 2009/48/EC Article 11(2)), and online offers show warnings and safety information (GPSR Article 19(d)).
What changes with the new Toy Safety Regulation?
Regulation (EU) 2025/2509 applies from 1 August 2030 and repeals the directive from that date (Articles 56 and 59). Warnings are set by its Article 6 and Annex III. The user limitations include at least the minimum age (Article 6(1)), all warnings under Article 6(1) and (2) must be clearly visible before purchase, including in distance sales (Article 6(3)), and Annex III, point 1, sets the visibility and legibility criteria, including a minimum character size.
Can we keep selling toys made under the old directive after 2030?
Member States may not impede the making available of toys placed on the market in conformity with Directive 2009/48/EC before 1 August 2030 (Regulation (EU) 2025/2509 Article 57(1)).
Sources
- Directive 2009/48/EC on the safety of toys (consolidated text of 29 August 2026) EUR-Lex · accessed 4 October 2026
- Regulation (EU) 2025/2509 on the safety of toys and repealing Directive 2009/48/EC EUR-Lex · accessed 4 October 2026
- Regulation (EU) 2023/988 on general product safety (consolidated text of 29 May 2026) EUR-Lex · accessed 4 October 2026
- Regulation (EU) 2019/1020 on market surveillance and compliance of products (consolidated text of 12 August 2026) EUR-Lex · accessed 4 October 2026
About this page
- Reviewer
- Conphora compliance team
- Reviewed
- 4 October 2026
General information, not legal advice. Check the legal text or ask an adviser about your own product.
Conphora (2026). We do not know which warnings a toy needs. Retrieved 13 October 2026 from https://www.conphora.com/solutions/problem/warning-texts-toys/
Conphora (2026) We do not know which warnings a toy needs. Available at: https://www.conphora.com/solutions/problem/warning-texts-toys/ (Accessed 13 October 2026).
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author = {Conphora},
title = {We do not know which warnings a toy needs},
year = {2026},
url = {https://www.conphora.com/solutions/problem/warning-texts-toys/},
note = {Retrieved 13 October 2026}
} See it working before you add a product
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