EN 71 toy safety standards: parts, testing and what else applies

EN 71 is a series of European standards titled “Safety of toys”. Each part is its own document with its own subject: Part 1 is mechanical and physical properties, Part 2 flammability, Part 3 migration of certain elements, and so on. The European standardisation organisations, CEN and Cenelec, develop them; the Commission’s toy safety page says the Directive “does not specify the technical detail of toy safety requirements” and that CEN and Cenelec develop it. A standard is not law. The law is the Toy Safety Directive 2009/48/EC. A listed EN 71 part is one way to show a toy meets it.

The EN 71 parts and the versions on the list

The Commission publishes the references of the harmonised standards for toys in Implementing Decision (EU) 2023/740, which replaced Implementing Decision (EU) 2021/1992 and has been amended three times; the original text is of 4 April 2023. Each amending Decision is published in the Official Journal on its own date and enters into force on the day it is published. The table gives the current references, what each part covers by its title, and the earlier version that sits before it. The dates are from the Commission’s summary list, generated on 14 September 2026, and from the Decisions.

Until the end date, the older and the newer version are both on the list. The Commission defers the withdrawal of the older one on purpose: “to allow toy manufacturers sufficient time to adapt their products to the revised specifications” (Implementing Decision (EU) 2025/2519, recital 8; Implementing Decision (EU) 2026/2032, recital 7). The deletion of the older EN 71-3 and EN 71-13 applies from 16 June 2027, and the deletion of the older EN 71-4 from 14 March 2028. The list has no entry for Parts 6, 9, 10 and 11. The Directive itself names EN 71-10:2005 and EN 71-11:2005, but only as the test methods for bisphenol A, phenol and one preservative, BIT (Annex II, Appendix C).

How the presumption of conformity works

A toy that conforms with harmonised standards or parts of them, whose references are published in the Official Journal, “shall be presumed to be in conformity with the requirements covered by those standards or parts thereof” (Art. 13Directive 2009/48/EC, Toy Safety DirectiveArticle 13Click opens the article on EUR-Lex.). A harmonised standard is one adopted by a European standardisation body on a request from the Commission (Art. 3Directive 2009/48/EC, Toy Safety DirectiveArticle 3Click opens the article on EUR-Lex., point 8). Three limits follow from the wording.

• Only what the standard covers. The presumption reaches “the requirements covered by those standards”. The Decision lists titles and references, not clauses, so which requirement a clause covers is in the standard’s own text. The Decision does reproduce two cautions: the restriction on EN 71-1 and the note on EN 71-12.
• All relevant requirements, for the no-notified-body route. The route needs standards “covering all relevant safety requirements for the toy” (Art. 19(2)Directive 2009/48/EC, Toy Safety DirectiveArticle 19, paragraph 2Click opens the article on EUR-Lex.). The manufacturer’s safety assessment of the chemical, physical, mechanical, electrical, flammability, hygiene and radioactivity hazards sits first, and the file records it (Art. 18Directive 2009/48/EC, Toy Safety DirectiveArticle 18Click opens the article on EUR-Lex.; Annex IV, point (b)).
• Only listed references. A reference that is no longer published gives no presumption.

The Commission can publish a reference with a restriction, maintain it with a restriction or withdraw it (Art. 14(2)Directive 2009/48/EC, Toy Safety DirectiveArticle 14, paragraph 2Click opens the article on EUR-Lex.). Two entries carry a caution today.

• EN 71-1:2014+A1:2018, wave rollers. Since 10 September 2025 (Implementing Decision (EU) 2025/1785), its clauses 3.19 and 4.15.1, for “a ride-on toy where the child is seated, the steering and propulsion of which are controlled with the feet, and which have wheels within reach during use”, give no presumption of conformity with Art. 10(2)Directive 2009/48/EC, Toy Safety DirectiveArticle 10, paragraph 2Click opens the article on EUR-Lex. and Annex II, Part I, point 3. The Commission’s reason in the Decision is the risk of crushing and shearing the finger and the hand. A published restriction is itself one of the four cases that send a toy to a notified body (Art. 19(3)Directive 2009/48/EC, Toy Safety DirectiveArticle 19, paragraph 3Click opens the article on EUR-Lex., point (c)). The Commission’s guidance reads that case as “the third case is when such standards or any of them have been published with restriction which applies to the toy in question”. So only a toy the restriction concerns, a wave roller, must go to a notified body on that ground. Another toy that relies on EN 71-1 does not.
• EN 71-12:2016, limit values. The Decision’s note: its limits for N-nitrosamines (0.01 mg/kg) and N-nitrosatable substances (0.1 mg/kg) are lower than the Directive’s (0.05 mg/kg and 1 mg/kg, Annex II, Part III, point 8). The standard asks for more than the law.

Where EN 71 alone is not enough

The standards cover what they cover. The Directive’s requirements are wider, and three situations leave a gap that the listed standards do not close.

Chemical rules the standards’ titles do not reach

Annex II, Part III sets the Directive’s chemical rules. The list has standards titled for migration of certain elements (EN 71-3, against the 19 migration limits of point 13), N-nitrosamines (EN 71-12, point 8), olfactory board games and cosmetic kits (EN 71-13), formamide (EN 71-15) and certain flame retardants (EN 71-16). It has none titled for the rules below. A title is not a list of clauses, so whether a clause of a listed standard covers one of them is in that standard’s text. The route without a notified body needs standards “covering all relevant safety requirements” (Art. 19(2)Directive 2009/48/EC, Toy Safety DirectiveArticle 19, paragraph 2Click opens the article on EUR-Lex.), and the Directive sends a toy to EC-type examination where such standards “do not exist” (Art. 19(3)Directive 2009/48/EC, Toy Safety DirectiveArticle 19, paragraph 3Click opens the article on EUR-Lex., point (a)).

• The ban on CMR substances. Substances classified as carcinogenic, mutagenic or toxic for reproduction, category 1A, 1B or 2, may not be used in toys or their parts, with the exceptions of points 4 to 7 (two derogations, nickel in stainless steel, and materials that meet the limits of Appendix C).
• The allergenic fragrances ban and labelling (point 11). It applies to toys generally. EN 71-13 is titled for olfactory board games, cosmetic kits and gustative games.
• The specific limits in Appendix C, for toys for children under 36 months and other toys meant to go in the mouth: bisphenol A, three isothiazolinone preservatives, phenol, formaldehyde and aniline, besides formamide, TCEP, TCPP and TDCP. For bisphenol A, phenol and one preservative (1,2-benzisothiazol-3(2H)-one, BIT) the law names EN 71-10:2005 and EN 71-11:2005 as the test methods, and those two are not on the harmonised list.
• The other chemicals law. Toys “shall comply with the relevant Community legislation relating to certain categories of products or to restrictions for certain substances and mixtures” (point 1). That includes REACH, covered in REACH compliance.

Electric toys and EN IEC 62115

EN IEC 62115:2020 is the listed standard for electric toys. The Directive’s electrical rules are in Annex II, Part IV: no toy powered above 24 volts DC or the equivalent AC voltage, accessible parts not above that, insulation and mechanical protection, limits on surface temperature, protection under foreseeable fault conditions and against fire, safe behaviour when an electronic control system fails, no health hazard from lasers, LEDs or other radiation, and a transformer that is not an integral part of the toy. The standard’s reference gives the presumption for what the standard covers; what it does not cover stays with the manufacturer.

The Regulation names Directives 2011/65/EU (RoHS), 2014/30/EU (electromagnetic compatibility), 2014/35/EU (low voltage) and 2014/53/EU (radio equipment) among the laws whose declaration of conformity the digital product passport can carry for a toy (Art. 19(5)Regulation (EU) 2025/2509, Toy Safety RegulationArticle 19, paragraph 5Click opens the article on EUR-Lex.). For RoHS, see RoHS compliance.

Toys that go to a notified body

The Directive sends a toy to EC-type examination, together with conformity to type, in four cases (Art. 19(3)Directive 2009/48/EC, Toy Safety DirectiveArticle 19, paragraph 3Click opens the article on EUR-Lex.):

Who tests: a laboratory or a notified body

The Directive uses two different words. A conformity assessment body is “a body that performs conformity assessment activities, including calibration, testing, certification and inspection” (Art. 3Directive 2009/48/EC, Toy Safety DirectiveArticle 3Click opens the article on EUR-Lex., point 12). A notified body is one of those bodies that an EU country has notified under Art. 22Directive 2009/48/EC, Toy Safety DirectiveArticle 22Click opens the article on EUR-Lex. to carry out EC-type examination (Art. 20Directive 2009/48/EC, Toy Safety DirectiveArticle 20Click opens the article on EUR-Lex., paragraph 3). What notified bodies are and how to find one is in notified body. Only a body that went through the notification procedure “shall be considered a notified body” (Art. 31(5)Directive 2009/48/EC, Toy Safety DirectiveArticle 31, paragraph 5Click opens the article on EUR-Lex.).

Sources for the table: Art. 21Directive 2009/48/EC, Toy Safety DirectiveArticle 21Click opens the article on EUR-Lex., Art. 26Directive 2009/48/EC, Toy Safety DirectiveArticle 26Click opens the article on EUR-Lex., Art. 30Directive 2009/48/EC, Toy Safety DirectiveArticle 30Click opens the article on EUR-Lex., Art. 32Directive 2009/48/EC, Toy Safety DirectiveArticle 32Click opens the article on EUR-Lex. and Annex IV, point (g). The Commission’s page on placing toys on the market names the NANDO database. The two laboratory rows come from the Commission’s technical documentation guidance, version 1.5, section 8 (test reports “may be done by the manufacturer himself or by an external source”), and from Art. 11(5)Regulation (EU) 2019/1020, Market Surveillance RegulationArticle 11, paragraph 5Click opens the article on EUR-Lex. of Regulation (EU) 2019/1020Regulation (EU) 2019/1020, Market Surveillance RegulationThe whole regulationClick opens the law on the EU Publications Office.. The guidance is not law. The Directive itself lets the manufacturer “carry out or have carried out” the conformity assessment procedure (Art. 4(2)Directive 2009/48/EC, Toy Safety DirectiveArticle 4, paragraph 2Click opens the article on EUR-Lex.).

What the notified-body route involves, from Decision No 768/2008/EC, Annex II, Module B, which the Directive applies (Art. 20Directive 2009/48/EC, Toy Safety DirectiveArticle 20Click opens the article on EUR-Lex., paragraph 1):

• The manufacturer applies to one notified body of its choice, with a written statement that it has applied to no other, and with the technical documentation and the test reports.
• The supporting evidence “shall include, where necessary, the results of tests carried out by the appropriate laboratory of the manufacturer, or by another testing laboratory on his behalf and under his responsibility”.
• The notified body checks that the standards the manufacturer chose were applied correctly, and whether the solutions used where no standard was applied meet the essential requirements.
• The EC-type examination certificate for a toy carries a reference to the Directive, a colour image, a description with dimensions and “a list of the tests performed, together with a reference to the relevant test report” (Art. 20Directive 2009/48/EC, Toy Safety DirectiveArticle 20Click opens the article on EUR-Lex., paragraph 4). It is reviewed whenever the process, raw materials or components change, and at least every five years.

On the standards route the Directive provides for no certificate. The documents it names are the test reports in the file (Annex IV, point (g)), the manufacturer’s EC declaration of conformity (Art. 15Directive 2009/48/EC, Toy Safety DirectiveArticle 15Click opens the article on EUR-Lex.) and, on the other route, the EC-type examination certificate. An “EN 71 certificate” is not one of them.

A market surveillance authority can also bring a notified body in. If the manufacturer fails to meet the technical documentation duties, the authority “may require it to have a test performed by a notified body at its own expense” (Art. 21(4)Directive 2009/48/EC, Toy Safety DirectiveArticle 21, paragraph 4Click opens the article on EUR-Lex.).

What the Toy Safety Regulation changes for EN 71

The Regulation (EU) 2025/2509Regulation (EU) 2025/2509, Toy Safety RegulationThe whole regulationClick opens the law on the EU Publications Office. of 26 November 2025 was published in the Official Journal on 12 December 2025. It enters into force on the twentieth day after publication, and applies from 1 August 2030. Its notified-body rules (Articles 28 to 44) and its rules on delegated acts, ECHA and penalties (Articles 49 to 55) apply from 1 January 2026 (Art. 59Regulation (EU) 2025/2509, Toy Safety RegulationArticle 59Click opens the article on EUR-Lex.). The Directive is repealed with effect from 1 August 2030 (Art. 56Regulation (EU) 2025/2509, Toy Safety RegulationArticle 56Click opens the article on EUR-Lex.). The Commission’s toy safety page gives the same dates: in force on 1 January 2026, applying from 1 August 2030. The whole Regulation is on the Toy Safety Regulation page.

What the Regulation says about standards, and what it does not:

• The same mechanism. Toys in conformity with harmonised standards whose references are published in the Official Journal “shall be presumed to be in conformity with the essential safety requirements to the extent that those requirements are covered by those standards” (Art. 15Regulation (EU) 2025/2509, Toy Safety RegulationArticle 15Click opens the article on EUR-Lex.). The route without a notified body is internal production control (Art. 26Regulation (EU) 2025/2509, Toy Safety RegulationArticle 26Click opens the article on EUR-Lex., paragraph 2).
• Common specifications as a fallback. Where no harmonised standard covers a requirement and none is expected within a reasonable period, the Commission may adopt implementing acts with common specifications, which give the same presumption (Art. 16Regulation (EU) 2025/2509, Toy Safety RegulationArticle 16Click opens the article on EUR-Lex.).
• The restriction rule says it outright. EU-type examination applies where a standard was published with a restriction “and the restriction is applicable to the toy in question” (Art. 26Regulation (EU) 2025/2509, Toy Safety RegulationArticle 26Click opens the article on EUR-Lex., paragraph 3, point (c)). The Directive’s text has no such words (Art. 19(3)Directive 2009/48/EC, Toy Safety DirectiveArticle 19, paragraph 3Click opens the article on EUR-Lex., point (c)), but the Commission’s guidance on the Directive reads it the same way (section 4.2.3).
• No EN number is named. The Regulation’s text names no EN 71 part and no EN IEC 62115. The Directive names two, EN 71-10 and EN 71-11, as test methods in Appendix C.
• No list under it yet. The Commission’s harmonised standards page, read on 6 October 2026, shows the Regulation as applicable from 1 August 2030 and the implementing decisions under the Directive; it lists no references under the Regulation. Neither Art. 56Regulation (EU) 2025/2509, Toy Safety RegulationArticle 56Click opens the article on EUR-Lex. nor Art. 57Regulation (EU) 2025/2509, Toy Safety RegulationArticle 57Click opens the article on EUR-Lex. says that the Directive’s list carries over. Which EN 71 parts will give the presumption after 1 August 2030 is not published in any text read today.
• The standards go into the passport. The digital product passport lists “references to the relevant harmonised standards used, or references to common specifications” and, where one was involved, the name and number of the notified body and the reference of its certificate (Annex VI, Part I, points (i) and (j)). The passport replaces the declaration of conformity (recital 54). More on it in digital product passport.
• Test reports stay in the file. The technical documentation holds test reports where the internal production control route was followed (Annex V, point (6)), and the passport and the documentation stay available for 10 years on that route (Annex IV, Part I, point 4.2).
• Wider chemical bans. Annex II, Part III bans substances classified as CMR 1A, 1B or 2, endocrine disruptors and other classes, the intentional use of PFAS and the bisphenols listed in Part D of the Appendix (points 4 to 6). The summary is in CE marking for toys.

Great Britain: designated standards under the Toys (Safety) Regulations 2011

Great Britain has its own toy law, the Toys (Safety) Regulations 2011. It is not EU law. It works the same way as the Directive, with UK terms:

• A “designated standard” is a standard the Secretary of State designates by publishing its reference (regulation 3A). A toy that conforms with designated standards is presumed to comply with the essential safety requirements to the extent they cover them, and the presumption can be rebutted (regulation 7).
• If the manufacturer has applied designated standards covering all the essential safety requirements, it uses internal production control. Type examination by an approved body applies in the same four cases as under the Directive, one of them a designated standard published with a restriction (regulation 13; regulation 14 for the application).
• The UK Government’s list of designated standards for toy safety is version 6 of 17 February 2026. It carries the same EN 71 parts as the EU list as far as Part 14 and EN IEC 62115, with the same restriction on EN 71-1 for wave rollers from 13 February 2026 and the same end date of 16 June 2027 for EN 71-3:2019+A1:2021 and EN 71-13:2021+A1:2022. That version has no entry for EN 71-4:2020+A1:2025, EN 71-15 or EN 71-16.
• In Great Britain, the CE marking is recognised alongside the UKCA marking. Where third-party assessment is needed, a toy assessed by an EU notified body, and not by a UK approved body, can be CE marked; one assessed by a UK approved body must be UKCA marked. For the EU market the CE marking is required (GOV.UK guidance, section 9). Northern Ireland has its own guidance.

What the law leaves open

• Whether a laboratory must be accredited. It need not be. The Directive asks for test reports in the file (Annex IV, point (g)) and names accreditation only for notified bodies and their notifying authorities (Art. 23Directive 2009/48/EC, Toy Safety DirectiveArticle 23Click opens the article on EUR-Lex., Art. 30Directive 2009/48/EC, Toy Safety DirectiveArticle 30Click opens the article on EUR-Lex.). The Commission’s guidance says the manufacturer or an external source may run the tests. Authorities “shall take due account” of a report from an accredited laboratory (Art. 11(5)Regulation (EU) 2019/1020, Market Surveillance RegulationArticle 11, paragraph 5Click opens the article on EUR-Lex.), so accreditation helps a report carry weight without being a condition.
• Which clauses cover which requirement. The Decision lists references and titles. What a clause of EN 71-3 or EN 71-1 covers is in the standard’s text, and the Decision does not reproduce it.
• Standards under the Regulation. No reference is published under it yet, and no text says whether the current list carries over (see above).
• How national authorities treat a test report. The law and the guidance say who may test. How much weight a given authority gives a report from an unaccredited laboratory is not set out in any text read for this page.

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