A New Era for Toys in Europe: Stronger Compliance, Traceability and Safety

On 12 December 2025, the European Union published Regulation (EU) 2025/2509 on toy safety, which will gradually replace Directive 2009/48/EC by 2030. This new regulation strengthens child protection while introducing digital traceability through the Digital Product Passport (DPP) and tightening chemical requirements. For importers and customs professionals, the challenge is twofold: ensuring both documentary and chemical compliance while securing logistics flows into the EU.

The scope remains focused on toys intended for children under the age of 14, with a key clarification: the concept of “intended for use in play” must reflect what a parent or supervisor may reasonably assume.

Certain exemptions have been expanded, notably:

  • Paintball equipment
  • Educational and reading books intended for children over 36 months that have no play value

The Digital Product Passport (DPP) is central to the new traceability framework. It includes CE marking, the customs commodity code and the manufacturer’s contact details, and must be uploaded to a European digital registry. A QR code or equivalent data carrier affixed to the toy will enable customs authorities to verify compliance before the product is placed on the market.

Chemical requirements have been significantly reinforced, including:

  • A ban on PFAS and the listed bisphenols (B, TBMD, TG-SA, etc.)
  • Prohibition of endocrine disruptors (categories 1 and 2), respiratory and skin sensitizers (category 1A), and specific target organ toxicants (category 1)
  • Maintenance of heavy metal limits, with adjusted thresholds for aluminium (2,250 mg/kg for dry materials, 560 mg/kg for liquids and 28,130 mg/kg for scraped-off materials)
  • Restrictions on N-nitrosamines and N-nitrosatable substances across five toy categories
  • Extension of restrictions to all toys for substances such as TCEP, TCPP, TDCP, formamide, BIT, CIT, phenol, formaldehyde, aniline, acrylonitrile, BPA, butadiene, styrene and vinyl chloride
  • Prohibition of biocidal products and a strict limitation of allergenic fragrances to 10 mg/kg

The transitional period until 1 August 2030 provides time for adaptation, but early compliance is strategic. Integrating the DPP and new chemical restrictions into operational processes is essential to avoid delays, penalties and reputational risks. Compliance is becoming a core pillar of product traceability and safety on the European market.

This regulation applies to new toys manufactured by EU-established manufacturers, as well as new and second-hand toys imported from third countries and placed on the EU market. The safety of other second-hand toys already on the EU market falls under the scope of Regulation (EU) 2023/988. Products listed in Annex I of the Regulation are excluded from its scope.