The EU's new toy regulations (EU) 2025/2509 (TSR) have been officially implemented and will be mandatory in 2030!

1. The directive and its amendments shall be transposed into domestic law by the Member States

1. directive and its amendments apply directly to all EU member states, without requiring any conversion by individual countries.

2. EU declaration of conformity (DoC)

2. Digital product passport (DPP)

3. The CE marking indicates the conformity of a toy; it is the visual result of the entire conformity assessment process, encompassing a broad definition. General principles regarding the CE marking are clearly defined in EU Regulation (EC) No 765/2008. The rules governing the affixing of the CE marking shall be stipulated in this directive.

3. New addition:

(a) The CE mark should be displayed on the toy and its packaging. If the toy is on display and the CE mark cannot be displayed on the toy itself, it should be displayed on the shelf.

(b) The CE mark should be immediately followed by a safety icon or other safety warning information.

4. Warnings made to comply with Article 10, paragraph 2, where safe use is required, shall clearly state appropriate user restrictions in accordance with Part A of Annex V.

Manufacturers shall affix these warnings in a clear, legible, easily understood, and accurate manner on the toy, on accompanying labels, on packaging (if applicable), or on the instructions for use accompanying the toy. Small toys not accompanied by packaging shall bear appropriate warning labels.

According to Article 4, paragraph 7, a Member State may stipulate within its territory that these warnings and safety instructions shall be written in a language easily understood by consumers or in a language (as determined by that Member State).

5. New Additions:

(a) Toys should be accompanied by general warning instructions (if necessary) clearly stating appropriate usage restrictions. These restrictions should include at least the minimum and maximum age, required abilities, and weight.

(b) For products sold online, it must be ensured that consumers can clearly see the warning information.

(c) All warning messages must begin with the word "Warning," but this word can now be replaced by a triangle symbol (graphical symbol). This symbol should be 10 mm high.

5. The obligations of manufacturers, authorized representatives, importers, and distributors are stipulated separately.

5(a). It is emphasized that toys with artificial intelligence (AI) functions requiring third-party conformity assessment are classified as high-risk AI systems under regulations such as the Artificial Intelligence Regulation (EU) 2024/1689, the Cybersecurity Regulation (EU) 2024/2847, and the Radio Equipment (RED) Directive 2014/53/EU. Furthermore, interconnected toys with extensive social interaction functions (such as speaking or taking pictures) or location tracking functions are considered significant products with digital elements (Class I) and require third-party conformity assessment unless the manufacturer has adopted harmonized standards, general specifications, or European cybersecurity certification schemes and achieved a “substantial” level of assurance.

(b) Obligations of Manufacturers and Importers

(c) Data Carrier:

• The data carrier should be physically attached to the toy or affixed to a label on the toy. If the toy is too small, the data carrier may be placed on the packaging. However, it must be visible to the consumer at the point of sale, including online sales.

• The toy's data carrier should be unique.

• Consumers should not be required to download and install any software, register, or provide a password to access the Digital Product Passport.

• Data in the DPP should be stored by the operator responsible for its creation. Other operators may not sell, reuse, or process such data.

• Before placing the toy on the market, the operator should upload it to the affiliate registration system and insert a unique product identifier and a unique operator identifier.

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6. When using these toys, their potential impact on children's mental health and cognitive development should be considered.

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7. Content regarding food imitations, intestinal obstruction, and magnets has been added to the basic safety requirements.

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For small, battery-powered toys, the batteries should be designed to be inaccessible without tools.

If the size or characteristics of the toy necessitate this, rechargeable batteries may be designed to be inaccessible, requiring only a qualified professional to remove or replace them.

1. Toys must not contain the following categories of substances:

(a) Carcinogens, reproductive toxins, and mutagens, categories 1A, 1B, and 2 (CMR Cat. 1A, 1B, 2)

1. Toys must not contain the following categories of substances:

(a) Carcinogens, reproductive toxins, and mutagens, categories 1A, 1B, and 2 (CMR Cat. 1A, 1B, 2)

(b) Endocrine disruptors, categories 1 and 2 (ED for human health Cat. 1 and 2)

(c) Target organ toxins (single exposure/repeated exposure), category 1 (STOT SE/RE Cat. 1)

(d) Respiratory sensitizers, category 1 (Resp. Sens. Cat. 1)

(e) Skin sensitizers, category 1A (Skin Sens. Cat. 1A)

2. There are no limits for nitrosamines and their precursors in slime and putty.

2. Limits for nitrosamines and their precursors in slime and putty: 0.02 mg/kg and 1 mg/kg, respectively.

3. Requirements for TCEP, TCPP, TDCP, formamide, BIT, CMI, phenol, formaldehyde, aniline, and bisphenol A (BPA) apply to toys intended for use by children under 36 months of age or toys intended to be put in the mouth.

3. TCEP, TCPP, TDCP, formamide, BIT, CMI, phenol, formaldehyde, aniline, and bisphenol A (BPA) requirements apply to all types of toys intended for use by children under 14 years of age.

4. Migration limit for bisphenol A (BPA): 0.04 mg/L

4. Migration limit for bisphenol A (BPA): 0.005 mg/L

5. No migration limits are specified for monomers acrylonitrile, butadiene, styrene, and vinyl chloride (VC).

5. Migration limits for acrylonitrile, butadiene, styrene, and vinyl chloride (VC) monomers in all types of toys for children under 14 years of age: 0.01 mg/L, 0.07 mg/L, 0.77 mg/L, and 0.01 mg/L, respectively.

6. Limits for allergenic flavorings (or limits that trigger labeling obligations): 100 mg/kg (0.01%) (per substance)

6. Limits for allergenic flavorings (or limits that trigger labeling obligations): 10 mg/kg (0.001%) (per substance).

When labeling obligations are triggered, information on allergenic flavorings must also appear in the Digital Product Passport (DPP).

7. There are no specific requirements for toys.

Toys can also be classified as treated articles under EU Regulation (EU) 528/2012.

7. Toys must not be biocidal products or treated articles as defined in EU Regulation (EU) 528/2012 (except for toys intended for permanent outdoor use and preservatives in certain leave-on cosmetics).

8. There are no specific perfluorinated and polyfluoroalkyl substances (PFAS) requirements for toys.

The toy complies with general CMR content requirements, Annex XVII and SVHC requirements of REACH Regulation (EC) No 1907/2006, and the requirements of POPs Regulation (EU) 2019/1021.

8. The intentional use of perfluorinated and polyfluoroalkyl substances (PFAS) in toys is prohibited.

9. There are no specific bisphenol (BPA) requirements for toys.

The toy complies with general CMR requirements and REACH Regulation (EC) No 1907/2006 SVHC requirements.

9. Ten bisphenol-related substances are prohibited in toys.

(Note: This number may be increased to 34 bisphenol-related substances in the future.)

10. There are no exemptions for cobalt (Co).

10. Exemption for cobalt (Co) as an impurity in stainless steel components containing nickel (Ni).

Exemption for cobalt (Co) in components intended to conduct electricity.

Exemption for cobalt (Co) in neodymium (Nd)-based magnets, provided that these magnets cannot be swallowed or attracted.