The European Toy Safety Regulation was adopted on November 26, 2025, under number (EU) 2025/2509 and published in the Official Journal of the European Union on December 12, 2025. It replaces Directive 2009/48/EC, which had governed toys for fifteen years. It expands the list of prohibited chemicals, creates a digital product passport, regulates online sales and includes connected toys. It will apply fully after a 54-month transition period, around the middle of 2030. Until then, toys sold in Europe remain subject to the 2009 rules. This article explains what changes for parents, what remains unchanged, and why the timeline is so long.
Why a European Toy Safety Regulation instead of a directive?
The difference is not merely legal. A directive sets objectives that each Member State transposes into its own law, with national deadlines and nuances. A regulation applies as is, in the same terms, in all twenty-seven countries, on the same date. For a toy sold in France, Germany and Spain, this means a single rule that is easier for customs and market surveillance authorities to enforce. The European Commission proposed this text in July 2023. Parliament and the Council reached a provisional agreement in spring 2025, the Council adopted its position on October 13, 2025, and the final text was signed on November 26, 2025.
Which chemicals will be banned in toys?
This is the most significant change for children's health. The 2009 directive already banned carcinogenic, mutagenic and reproductive-toxic substances, with exemptions. The 2025 regulation extends this general ban to several other families whenever the substance is classified as hazardous under Regulation (EC) No 1272/2008 on the classification of chemicals.
- Endocrine disruptors, which interfere with the hormonal system. This is the first time that a European toy-related text has targeted them as a category.
- Substances toxic to certain target organs and respiratory sensitisers.
- PFAS, those perfluorinated and polyfluorinated compounds known as “forever chemicals,” whose intentional use in toys, their components and their distinct parts is prohibited.
- The most hazardous bisphenols, including those identified by the European Chemicals Agency, with migration limits for those that remain in certain plastics.
- Certain allergenic fragrance substances, specifically in toys intended for children under 36 months and in those designed to be placed in the mouth.
The text provides an exception for technically unavoidable traces, provided they remain at the lowest level permitted by good manufacturing practices. It excludes batteries from the toy's chemical requirements, as they are covered by a separate regulation, while requiring that they remain inaccessible to children. Our article on formamide, BPA and phthalates in baby products explains what these families of substances represent in practical terms in a childcare product.
What is the digital product passport?
Every toy placed on the European market will have to bear a data carrier, in practice a QR code or equivalent, affixed to the toy itself or its packaging. This carrier links to a digital product passport containing the compliance information currently compiled in the EU declaration of conformity, which will no longer exist as a separate document. The manufacturer must keep this passport up to date. Market surveillance authorities and customs will access it to inspect a batch; consumers will access it to view warnings, safety information and the manufacturer's identity.
For a parent, the expected effect is twofold. First, direct access to safety information without relying on what the retailer has chosen to display. Second, a way to verify that a toy purchased online, particularly on a marketplace, corresponds to a product actually declared by an identifiable manufacturer. The regulation specifies that warnings may be provided in digital format through this passport, in addition to physical labelling.
What changes for online sales?
The regulation builds on two horizontal texts already in force: the Digital Services Act, which regulates platforms, and the regulation on general product safety. It specifies that offers for non-compliant toys constitute illegal content within the meaning of the former, requiring marketplaces to remove them. It requires the CE marking, safety warnings and link to the digital passport to be displayed clearly and visibly in the listing before purchase. This addresses a repeated finding by enforcement authorities: a significant proportion of the non-compliant toys seized in recent years came from third-party sellers established outside the Union and operating through platforms. Our article on baby product recalls explains how to track market withdrawals while awaiting application of the new text.
Are connected toys covered?
The regulation does not create a technical regime specific to digital toys. It refers to specialised legislation. The Radio Equipment Directive covers privacy protection. The Cyber Resilience Act covers toys connected to the internet, and the Artificial Intelligence Act covers those that incorporate AI. However, it adds a new requirement to the safety assessment. Where relevant, the manufacturer must take into account the risks to a child's mental health that a connected toy may present. This is a first in a product safety text.
What remains unchanged for parents
Three familiar benchmarks remain in place.
- The CE marking remains the mandatory mark of conformity. It continues to be affixed by the manufacturer under its responsibility, without systematic prior third-party inspection, except for toys that do not follow harmonised standards.
- The EN 71 series of technical standards remains the basis for mechanical, physical, flammability and chemical-element migration testing. Our guide to CE, REACH, EN 71 and Oeko-Tex certifications explains what each one covers.
- The warning for toys unsuitable for children under 36 months remains mandatory, with an indication of the specific hazard, such as small parts.
A play mat falls under this regulation. It is designed for a child under 14 to play with, so it is a toy within the meaning of the European text and is tested according to the EN 71 standard. This is the case for the Treelys® baby play mat, whose product page mentions this standard. To understand what EN 71 testing checks on a floor mat, our article on materials and safety of foam baby mats details the inspection points.
When will the European Toy Safety Regulation apply?
The regulation entered into force twenty days after its publication in the Official Journal, at the beginning of January 2026. Its provisions will apply fully at the end of a 54-month transition period, that is, four and a half years, placing the deadline around the middle of 2030. Until that date, Directive 2009/48/EC and its French transposition will continue to apply to toys placed on the market.
This length of time is explained by the scale of the task: manufacturers must reformulate certain materials, establish the digital passport infrastructure, and standardisation bodies must adapt the EN 71 standards to the new requirements. The delegated acts that will clarify several points, such as the exact list of prohibited allergenic fragrances, have yet to be adopted by the Commission. A toy purchased today is therefore not “against the law” under the new text, and a toy compliant with the 2009 rules may continue to be sold during the transition.
What can parents do while waiting for 2030?
The new text formalises requirements that responsible manufacturers already partly apply, because the EN 71 standards and REACH regulation cover a substantial share of the substances concerned. Three habits remain valid right now. Prefer an identifiable manufacturer, with an address in Europe and a declaration of conformity available on request. Check for the CE marking and age warning on the packaging. Be wary of an unusually low price on a marketplace, especially for a toy intended to be placed in the mouth. Our article on European safety standards for childcare products presents the full framework currently in force. The article on the ban on PFAS in baby clothing shows that France has moved ahead of Europe on this point for textiles.
Key takeaways
- Regulation (EU) 2025/2509 replaces the 2009 directive and applies identically throughout the Union.
- It generically bans endocrine disruptors, PFAS, the most hazardous bisphenols and certain allergenic fragrances in toys for children under 36 months.
- Every toy will carry a digital passport accessible by QR code, replacing the declaration of conformity.
- Marketplaces will have to display the CE marking, warnings and the link to the passport before purchase, and remove non-compliant offers.
- Full application follows a 54-month transition period, around mid-2030. Until then, the 2009 rules remain in force.
Sources
- Regulation (EU) 2025/2509 of the European Parliament and of the Council of November 26, 2025 on the safety of toys and repealing Directive 2009/48/EC, Official Journal of the European Union, L series, December 12, 2025 (EUR-Lex).
- Council of the European Union, press release “Council adopts new rules to make toys safer,” October 13, 2025.
- European Commission, communication to the European Parliament on the Council's position at first reading, October 14, 2025.
- European Parliament, press release “Toy safety: new measures to protect children's health,” April 2025.
- Directive 2009/48/EC of the European Parliament and of the Council of June 18, 2009 on the safety of toys (EUR-Lex).
