Toy Safety Regulation (EU) 2025/2509: what changes for toy sellers on 1 August 2030

The Regulation applies from 1 August 2030, and some parts already apply

The Commission puts it in one line: the Regulation “enters into force on 1 January 2026 and will start applying after a transition period of 4 and a half years on 1 August 2030” (toy safety page). The text itself says it enters into force “on the twentieth day following that of its publication”, and it was published on 12 December 2025; that day is 1 January 2026 (Art. 59Regulation (EU) 2025/2509, Toy Safety RegulationArticle 59Click opens the article on EUR-Lex.). It applies “from 1 August 2030”, except Articles 28Regulation (EU) 2025/2509, Toy Safety RegulationArticle 28Click opens the article on EUR-Lex. to 44Regulation (EU) 2025/2509, Toy Safety RegulationArticle 44Click opens the article on EUR-Lex. and 49Regulation (EU) 2025/2509, Toy Safety RegulationArticle 49Click opens the article on EUR-Lex. to 55Regulation (EU) 2025/2509, Toy Safety RegulationArticle 55Click opens the article on EUR-Lex., which apply from 1 January 2026.

A Regulation applies directly in every EU country; it is not turned into national law first (Art. 59Regulation (EU) 2025/2509, Toy Safety RegulationArticle 59Click opens the article on EUR-Lex., last paragraph). The recital gives the reason for the change of form: rules on essential safety requirements and conformity assessment have to apply uniformly “and not allow for divergent implementation by Member States” (recital 5).

Toys placed on the market before 1 August 2030 can still be sold

The transition is one sentence: “Member States shall not impede the making available on the market of toys which were placed on the market in conformity with Directive 2009/48/ECDirective 2009/48/EC, Toy Safety DirectiveThe whole regulationClick opens the law on the EU Publications Office. before 1 August 2030” (Art. 57(1)Regulation (EU) 2025/2509, Toy Safety RegulationArticle 57, paragraph 1Click opens the article on EUR-Lex.). Two words decide it for you. “Placed on the market” means “the first making available of a toy on the Union market” (Art. 3Regulation (EU) 2025/2509, Toy Safety RegulationArticle 3Click opens the article on EUR-Lex., point (2)). And “in conformity with” the Directive means the toy met the Directive on the day it was placed.

The Regulation does not say when a single unit counts as placed. The Commission’s Blue Guide does, and it counts each unit: “the concept of placing on the market refers to each individual product, not to a type of product”. A model that was already on sale does not keep the old rules for its later units: “individual units of the same model or type, which are placed on the market after the new requirements have become applicable, must comply with these new requirements” (section 2.3). It is guidance, not law. For toys it gives these cases:

Three more rules sit in the same Article.

• Market surveillance runs under the Regulation. For toys placed under the Directive before the date, the Regulation’s Chapter VIII, on market surveillance, applies instead of Articles 42, 43 and 45 of the Directive, including toys for which a procedure had already begun (Art. 57(2)Regulation (EU) 2025/2509, Toy Safety RegulationArticle 57, paragraph 2Click opens the article on EUR-Lex.). A toy sold under the old transition can still be withdrawn or recalled.
• Certificates. EC-type examination certificates issued under Article 20 of the Directive “shall remain valid until 1 February 2031, unless they expire before that date” (Art. 57(3)Regulation (EU) 2025/2509, Toy Safety RegulationArticle 57, paragraph 3Click opens the article on EUR-Lex.). The Directive already asks for a review of each certificate at least every five years (Art. 20(4)Directive 2009/48/EC, Toy Safety DirectiveArticle 20, paragraph 4Click opens the article on EUR-Lex.).
• Nothing for old units to do. A unit that qualifies under Art. 57(1)Regulation (EU) 2025/2509, Toy Safety RegulationArticle 57, paragraph 1Click opens the article on EUR-Lex. carries no passport and needs no new chemical test. Stock that has not been placed has to be ready for the Regulation before you place it.

Who and what the Regulation covers

It applies to “products that are designed or intended, whether or not exclusively, for use in play by children under 14 years of age”, and a product counts when “a parent or supervisor can reasonably assume, by virtue of the functions, dimensions and characteristics of that product” that it is for play (Art. 2(1)Regulation (EU) 2025/2509, Toy Safety RegulationArticle 2, paragraph 1Click opens the article on EUR-Lex.). Adaptive toys, made for children with physical or cognitive limitations, are included (recital 2). What counts as a toy under the Directive is on CE marking for toys; the Regulation keeps the Directive’s definition and adds the test of what a parent or supervisor can reasonably assume.

Annex I takes products out. Part I names four toys it does not apply to: playground equipment for public use, automatic playing machines for public use, toy vehicles with combustion engines and toy steam engines. Part II lists 21 products that are not toys, among them detailed scale models and other collectors’ items marked for collectors of 14 and above, puzzles of more than 500 pieces, computers and game consoles not designed for children, babies’ soothers, and two items the Directive’s list did not carry: paint ball equipment and reading and educational books for children older than 36 months with no play value. Decorative objects for festivities are out only if they have no play value, and luminaires only if “continuously wired”. The Directive named slings and catapults among its excluded toys (Art. 2(2)Directive 2009/48/EC, Toy Safety DirectiveArticle 2, paragraph 2Click opens the article on EUR-Lex.); Annex I to the Regulation does not.

For a seller outside the EU the reach is the same as today:

• New and imported toys. The Regulation applies to new toys by an EU manufacturer and to toys, “whether new or second-hand”, imported from a third country and placed on the Union market. The safety of other second-hand toys already on the Union market falls under the General Product Safety Regulation (recital 11).
• Distance sales. It applies “to all forms of supply of toys, including distance sales” (recital 12). An offer for sale online is made available on the Union market if it is targeted at end users in the Union (Art. 6Regulation (EU) 2019/1020, Market Surveillance RegulationArticle 6Click 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 EU-based operator. A toy may be placed on the market only if an operator established in the EU is responsible for the tasks of Article 4(3)Regulation (EU) 2019/1020, Market Surveillance RegulationThe whole regulationClick opens the law on the EU Publications Office. of Regulation (EU) 2019/1020Regulation (EU) 2019/1020, Market Surveillance RegulationThe whole regulationClick opens the law on the EU Publications Office.: a manufacturer in the EU, an importer, an authorised representative with a written mandate, or a fulfilment service provider established in the EU for the toys it handles, where none of the others is established there (Art. 4(1)Regulation (EU) 2019/1020, Market Surveillance RegulationArticle 4, paragraph 1Click opens the article on EUR-Lex., Art. 4(2)Regulation (EU) 2019/1020, Market Surveillance RegulationArticle 4, paragraph 2Click opens the article on EUR-Lex.). That Article names Directive 2009/48/ECDirective 2009/48/EC, Toy Safety DirectiveThe whole regulationClick opens the law on the EU Publications Office. (Art. 4(5)Regulation (EU) 2019/1020, Market Surveillance RegulationArticle 4, paragraph 5Click opens the article on EUR-Lex.); the Regulation says references to the Directive are read as references to itself (Art. 56Regulation (EU) 2025/2509, Toy Safety RegulationArticle 56Click opens the article on EUR-Lex.). The operator’s name and contact details go on the toy, its packaging, the parcel or an accompanying document (Art. 4(4)Regulation (EU) 2019/1020, Market Surveillance RegulationArticle 4, paragraph 4Click opens the article on EUR-Lex.).

What changes from the Directive

The Commission names two aims: stronger protection against “particularly harmful” chemicals, and better enforcement “by relying on digital technologies” (toy safety page). Against the Directive, for a seller:

What does not change: the CE marking is affixed before the toy is placed on the market (Art. 18(2)Regulation (EU) 2025/2509, Toy Safety RegulationArticle 18, paragraph 2Click opens the article on EUR-Lex.), the manufacturer runs a safety assessment (Art. 25Regulation (EU) 2025/2509, Toy Safety RegulationArticle 25Click opens the article on EUR-Lex.) and either applies harmonised standards or has a notified body carry out EU-type examination (Art. 26Regulation (EU) 2025/2509, Toy Safety RegulationArticle 26Click opens the article on EUR-Lex.), and keeps technical documentation for 10 years (Art. 7(3)Regulation (EU) 2025/2509, Toy Safety RegulationArticle 7, paragraph 3Click opens the article on EUR-Lex.). How that works for a toy today is on CE marking for toys, and the standards are on EN 71.

Every toy model needs a digital product passport

A digital product passport is “a set of data specific to a toy” that holds the information of Annex VI and is reached through a data carrier (Art. 3Regulation (EU) 2025/2509, Toy Safety RegulationArticle 3Click opens the article on EUR-Lex., point (17)). The manufacturer creates it before the toy is placed on the market; it corresponds to one toy model; it states that the toy meets the Regulation; and by creating it the manufacturer takes responsibility for the toy’s compliance (Art. 19(1)Regulation (EU) 2025/2509, Toy Safety RegulationArticle 19, paragraph 1Click opens the article on EUR-Lex., Art. 19(2)Regulation (EU) 2025/2509, Toy Safety RegulationArticle 19, paragraph 2Click opens the article on EUR-Lex., Art. 19(4)Regulation (EU) 2025/2509, Toy Safety RegulationArticle 19, paragraph 4Click opens the article on EUR-Lex.). A toy model is a group of toys of one manufacturer with uniform design, characteristics, materials and manufacturing processes, defined by a type number or another element that identifies the group (Art. 3Regulation (EU) 2025/2509, Toy Safety RegulationArticle 3Click opens the article on EUR-Lex., point (15)).

What it holds. Annex VI, Part I:

Part II lets the passport also carry safety information, warnings and instructions for use.

The data carrier.

• It is on the toy or an affixed label. Where the size or nature of the toy does not allow it, it goes on the packaging or a document with the toy, as a delegated act will set. It must be “clearly visible to the consumer or other end users before any purchase”, distance sales included (Art. 19(7)Regulation (EU) 2025/2509, Toy Safety RegulationArticle 19, paragraph 7Click opens the article on EUR-Lex.).
• Where other Union law asks for a data carrier or a passport for the same toy, one carrier and one passport serve all of them (Art. 19(8)Regulation (EU) 2025/2509, Toy Safety RegulationArticle 19, paragraph 8Click opens the article on EUR-Lex., Art. 19(9)Regulation (EU) 2025/2509, Toy Safety RegulationArticle 19, paragraph 9Click opens the article on EUR-Lex.). The passport must be interoperable with the passports other laws require (Art. 20(1)Regulation (EU) 2025/2509, Toy Safety RegulationArticle 20, paragraph 1Click opens the article on EUR-Lex.). How the passport works across other laws is on digital product passport.
• The passport is free to access, and a consumer is not asked to register or give a password (Art. 20(3)Regulation (EU) 2025/2509, Toy Safety RegulationArticle 20, paragraph 3Click opens the article on EUR-Lex., Art. 20(4)Regulation (EU) 2025/2509, Toy Safety RegulationArticle 20, paragraph 4Click opens the article on EUR-Lex.). It stays available for 10 years after the toy is placed on the market, “including in cases of insolvency, liquidation or cessation of activity in the Union” (Art. 19(2)Regulation (EU) 2025/2509, Toy Safety RegulationArticle 19, paragraph 2Click opens the article on EUR-Lex., point (g)).
• The passport shows a link to the Safety Gate Portal’s page for reporting toys that might present a risk (Art. 19(11)Regulation (EU) 2025/2509, Toy Safety RegulationArticle 19, paragraph 11Click opens the article on EUR-Lex.).
• When placing the toy, the operator makes a back-up copy available through a passport service provider (Art. 19(13)Regulation (EU) 2025/2509, Toy Safety RegulationArticle 19, paragraph 13Click opens the article on EUR-Lex.). The passport is stored by the operator or by such providers (Art. 20(5)Regulation (EU) 2025/2509, Toy Safety RegulationArticle 20, paragraph 5Click opens the article on EUR-Lex.).
• The operator placing the toy gives distributors and online marketplaces a digital copy of the data carrier or the unique product identifier, or a web link, free of charge, “promptly and in any event within 5 working days” of a request (Art. 19(12)Regulation (EU) 2025/2509, Toy Safety RegulationArticle 19, paragraph 12Click opens the article on EUR-Lex.).

It replaces the declaration of conformity. The recital says it: “The digital product passport should replace the EU declaration of conformity pursuant to Directive 2009/48/ECDirective 2009/48/EC, Toy Safety DirectiveThe whole regulationClick opens the law on the EU Publications Office.” (recital 54), and “by creating the digital product passport for a toy and by affixing the CE marking, the manufacturer declares that the toy is in compliance” (recital 58). The articles do not name an EU declaration of conformity of their own. For toys that also fall under another law, the passport can do that law’s declaration too, if it holds all the information that declaration needs: the AI Act, the Cyber Resilience Act, the RoHS, EMC, Low Voltage and Radio Equipment Directives, and the drone Delegated Regulation 2019/945 are listed (Art. 19(5)Regulation (EU) 2025/2509, Toy Safety RegulationArticle 19, paragraph 5Click opens the article on EUR-Lex.). The passport then says so (Annex VI, Part I, point (h)). For the cybersecurity side, see the Cyber Resilience Act; for the declaration itself, the declaration of conformity.

The registry and customs. Before placing a toy on the market, the operator uploads the unique product identifier and its unique operator identifier to the registry set up under Regulation (EU) 2024/1781Regulation (EU) 2024/1781, Ecodesign for Sustainable Products RegulationThe whole regulationClick opens the law on the EU Publications Office.. For toys released for free circulation, the registry stores the commodity code. It gives back a unique registration identifier, and the registry’s reply “shall not be deemed to be proof of compliance” (Art. 22(1)Regulation (EU) 2025/2509, Toy Safety RegulationArticle 22, paragraph 1Click opens the article on EUR-Lex., Art. 22(2)Regulation (EU) 2025/2509, Toy Safety RegulationArticle 22, paragraph 2Click opens the article on EUR-Lex.). Whoever releases a toy for free circulation gives customs that registration identifier. Customs “may release a toy for free circulation only after having verified, as a minimum, that the unique registration identifier and the commodity code” match the registry, on the commodity codes listed in Annex VII (Art. 23(2)Regulation (EU) 2025/2509, Toy Safety RegulationArticle 23, paragraph 2Click opens the article on EUR-Lex., Art. 23(3)Regulation (EU) 2025/2509, Toy Safety RegulationArticle 23, paragraph 3Click opens the article on EUR-Lex., Art. 23(6)Regulation (EU) 2025/2509, Toy Safety RegulationArticle 23, paragraph 6Click opens the article on EUR-Lex.). The check is automatic once the registry is linked to the EU customs single window, or from 1 August 2030 if that is later (Art. 23(4)Regulation (EU) 2025/2509, Toy Safety RegulationArticle 23, paragraph 4Click opens the article on EUR-Lex.).

The chemical bans

The Directive barred CMR substances; the Regulation adds more hazard groups and two named families. The substances are banned “in the form classified in Part 3 of Annex VI” to the CLP Regulation (EC) No 1272/2008, the EU’s list of harmonised classifications. Annex II, Part III, sets them:

Exceptions. The bans are not absolute. The text allows:

• Technically unavoidable traces from impurities or the manufacturing process, “provided that, despite such presence, toys remain in conformity with the general safety requirement” (point 7).
• The cases in Part C of the Appendix: nickel in stainless steel and in components that conduct current, and cobalt in stainless steel, in current-conducting components and in neodymium magnets that cannot be swallowed or inhaled (point 8; Appendix, Part C).
• Batteries in toys; toy components needed for electronic or electric functions where the substance is fully inaccessible to children, including by inhalation; materials that meet a substance-specific limit in Part A of the Appendix; and materials that meet a toy-specific restriction in Annex XVII to REACH (point 9). On REACH Annex XVII the restriction list is explained.
• A substance ECHA has found safe, with no suitable alternative and not prohibited in consumer articles under REACH (point 10). Requests go to ECHA (Art. 51Regulation (EU) 2025/2509, Toy Safety RegulationArticle 51Click opens the article on EUR-Lex., Art. 52Regulation (EU) 2025/2509, Toy Safety RegulationArticle 52Click opens the article on EUR-Lex.), and the Commission can then add the substance to Part C by delegated act (Art. 49(6)Regulation (EU) 2025/2509, Toy Safety RegulationArticle 49, paragraph 6Click opens the article on EUR-Lex.).

Limits and labels that stay or tighten. The limit values for chemicals that the Directive set only for toys for children under 36 months or toys meant for the mouth now apply to all toys (recital 28). In the Appendix, Part A:

• Migration limits for 19 listed elements and compounds, among them aluminium, antimony, arsenic, cadmium, chromium, cobalt, lead, mercury, nickel and organic tin (point 1). Recital 27 says the limits for arsenic, cadmium, chromium (VI), lead, mercury and organic tin are set at half the values the scientific body considers safe.
• Limits for N-nitrosamines and N-nitrosatable substances (point 2), and for substances such as TCEP, TCPP, TDCP, formamide, formaldehyde, styrene and aniline (point 3).
• Bisphenol A: a migration limit of 0.005 mg/l (point 3). Recital 28 says it falls under the generic ban on CMR substances.
• Allergenic fragrances: toys may not contain the 59 listed fragrances beyond technically unavoidable traces of 10 mg/kg, and toys for children under 36 months or for the mouth also not those of Part B, point 1 (points 4 and 5). One exception: entries 41 to 51 and 53 to 55 of Part A, point 4, and entries 1 to 9 of Part B, point 1, are allowed in olfactory board games, cosmetic kits and gustative games, if the fragrances are labelled on the packaging, the packaging carries the warning of Annex III, point 11, and the toy is not for children under 36 months (Appendix, Part B, point 2). The Part B allergens are named on the toy, its label, the packaging or a leaflet, and in the passport, when present above 10 mg/kg (Appendix, Part B, point 1).

Toys that are themselves chemical mixtures still follow the CLP Regulation, and play cosmetics follow the Cosmetics Regulation (Annex II, Part III, points 2 and 12). Toys also still follow the general chemicals law; that is on REACH compliance. The safety assessment, which the Directive already had, now also covers “any known additional hazards from combined exposure to the different chemicals present in the toy” (Art. 25(2)Regulation (EU) 2025/2509, Toy Safety RegulationArticle 25, paragraph 2Click opens the article on EUR-Lex., point (b)).

What online marketplaces must do

The Regulation has a chapter for marketplaces, and the General Product Safety Regulation adds to it. Recital 6 says GPSR Chapter III, Section 2, and Chapters IV and VI apply to toys as well.

The Toy Safety Regulation, Article 14Regulation (EU) 2025/2509, Toy Safety RegulationArticle 14Click opens the article on EUR-Lex..

• An offer of a toy that does not conform to the Regulation “shall be considered to be illegal content” for the Digital Services Act, and the measures of that Act apply (Art. 14(1)Regulation (EU) 2025/2509, Toy Safety RegulationArticle 14, paragraph 1Click opens the article on EUR-Lex.).
• Providers of online marketplaces comply with Articles 30 to 32 of the Digital Services Act and Article 22Regulation (EU) 2023/988, General Product Safety RegulationArticle 22Click opens the article on EUR-Lex. of the GPSR (Art. 14(2)Regulation (EU) 2025/2509, Toy Safety RegulationArticle 14, paragraph 2Click opens the article on EUR-Lex.).
• The marketplace designs its interface so that a trader can provide the CE marking, any warning that must be clearly visible before purchase, and the data carrier or web link to the passport, besides the information of GPSR Article 22(9)Regulation (EU) 2023/988, General Product Safety RegulationArticle 22, paragraph 9Click opens the article on EUR-Lex. (Art. 14(3)Regulation (EU) 2025/2509, Toy Safety RegulationArticle 14, paragraph 3Click opens the article on EUR-Lex.).
• A toy that fails the particular safety requirements, or meets them and still poses a risk to children, counts as a “dangerous product” for GPSR Article 22Regulation (EU) 2023/988, General Product Safety RegulationArticle 22Click opens the article on EUR-Lex. (Art. 14(4)Regulation (EU) 2025/2509, Toy Safety RegulationArticle 14, paragraph 4Click opens the article on EUR-Lex.).
• The Commission may issue guidelines for marketplaces and operators (Art. 14(5)Regulation (EU) 2025/2509, Toy Safety RegulationArticle 14, paragraph 5Click opens the article on EUR-Lex.).

GPSR Article 22Regulation (EU) 2023/988, General Product Safety RegulationArticle 22Click opens the article on EUR-Lex., which now covers toys. The marketplace names a single contact point for authorities and one for consumers, registers with the Safety Gate Portal, acts on a removal order within two working days, processes product safety notices within three working days, and suspends traders that frequently offer non-compliant products after a warning. Its interface must let the trader give at least: the manufacturer’s name and addresses; for a manufacturer outside the EU, the name and addresses of the responsible person or of the operator under Article 4(1)Regulation (EU) 2019/1020, Market Surveillance RegulationThe whole regulationClick opens the law on the EU Publications Office. of Regulation (EU) 2019/1020Regulation (EU) 2019/1020, Market Surveillance RegulationThe whole regulationClick opens the law on the EU Publications Office.; a picture, type and identifier of the product; and any warning or safety information that goes with it, in a language the buyers understand (GPSR Art. 22Regulation (EU) 2023/988, General Product Safety RegulationArticle 22Click opens the article on EUR-Lex., paragraphs 1, 2, 4, 8, 9 and 11).

What you show in a listing. GPSR Article 19Regulation (EU) 2023/988, General Product Safety RegulationArticle 19Click opens the article on EUR-Lex. applies to a toy you sell at a distance: the offer “shall clearly and visibly” show the manufacturer’s name and addresses, the EU-based operator where the manufacturer is outside the EU, an identification of the toy including a picture, and the warnings and safety information, in the language of the country you sell to (GPSR Art. 19Regulation (EU) 2023/988, General Product Safety RegulationArticle 19Click opens the article on EUR-Lex.; GPSR Art. 2(1)Regulation (EU) 2023/988, General Product Safety RegulationArticle 2, paragraph 1Click opens the article on EUR-Lex., third subparagraph, point (b)). From 1 August 2030 the Toy Safety Regulation adds that the warnings and the passport’s data carrier must be clearly visible before purchase, also in distance sales (Art. 6(3)Regulation (EU) 2025/2509, Toy Safety RegulationArticle 6, paragraph 3Click opens the article on EUR-Lex., Art. 19(7)Regulation (EU) 2025/2509, Toy Safety RegulationArticle 19, paragraph 7Click opens the article on EUR-Lex.). If a marketplace asks you for the carrier or the identifier, the 5-working-day rule applies to you if you placed the toy on the market (Art. 19(12)Regulation (EU) 2025/2509, Toy Safety RegulationArticle 19, paragraph 12Click opens the article on EUR-Lex.). What each marketplace asks today is on GPSR marketplace requirements.

Accidents. The Regulation has no accident-reporting rule of its own and sends economic operators to the GPSR procedures (recital 6). Under GPSR Article 20Regulation (EU) 2023/988, General Product Safety RegulationArticle 20Click opens the article on EUR-Lex. the manufacturer makes sure an accident that caused death or serious harm to health is notified through the Safety Business Gateway without undue delay, and the EU-based operator that knows of it makes sure it is done where the manufacturer is outside the EU (GPSR Art. 20Regulation (EU) 2023/988, General Product Safety RegulationArticle 20Click opens the article on EUR-Lex.).

What each operator owes under the Regulation

This is the outline. How a toy gets its CE marking, step by step, is on CE marking for toys.

A toy that falls under the AI Act, the Cyber Resilience Act or the Radio Equipment Directive gets a safety assessment that also takes account of “the particular vulnerabilities of children” (Art. 25(2)Regulation (EU) 2025/2509, Toy Safety RegulationArticle 25, paragraph 2Click opens the article on EUR-Lex., point (c)).

What happens if you sell without it

Where an authority has sufficient reason to believe a toy presents a risk, it evaluates the toy against the whole Regulation and requires corrective action within a reasonable period. If the operator does not act, the authority prohibits or restricts the toy on its national market, withdraws it or recalls it, and tells the Commission and the other EU countries (Art. 45(1)Regulation (EU) 2025/2509, Toy Safety RegulationArticle 45, paragraph 1Click opens the article on EUR-Lex., Art. 45(4)Regulation (EU) 2025/2509, Toy Safety RegulationArticle 45, paragraph 4Click opens the article on EUR-Lex.). The operator must see that corrective action reaches all the toys it made available throughout the Union (Art. 45(3)Regulation (EU) 2025/2509, Toy Safety RegulationArticle 45, paragraph 3Click opens the article on EUR-Lex.).

Faults on paper count. The authority requires the operator to end a non-compliance where the CE marking is missing or wrongly affixed, the digital product passport is not drawn up, the data carrier is not affixed, or the technical documentation is missing or incomplete; if that continues, the toy is restricted, prohibited, recalled or withdrawn (Art. 47Regulation (EU) 2025/2509, Toy Safety RegulationArticle 47Click opens the article on EUR-Lex.).

The penalties are national. EU countries set rules that “shall be effective, proportionate and dissuasive” and tell the Commission by 1 August 2028 (Art. 55Regulation (EU) 2025/2509, Toy Safety RegulationArticle 55Click opens the article on EUR-Lex.). The Regulation names no amount. A listing of a non-compliant toy on an online marketplace is illegal content, and the marketplace has to act on it (Art. 14(1)Regulation (EU) 2025/2509, Toy Safety RegulationArticle 14, paragraph 1Click opens the article on EUR-Lex.).

What the law leaves open

• The passport’s technical details. Which data carrier, its layout and position, who may read or write which data and how, are left to delegated acts. Each applies no earlier than 18 months after it enters into force, except in duly justified cases (Art. 49(1)Regulation (EU) 2025/2509, Toy Safety RegulationArticle 49, paragraph 1Click opens the article on EUR-Lex.). No act under Article 49Regulation (EU) 2025/2509, Toy Safety RegulationThe whole regulationClick opens the law on the EU Publications Office. had been adopted when this page was last checked (2 October 2026). The registry itself is covered: Implementing Regulation (EU) 2026/1778 sets its implementation arrangements for toy passports under Article 19Regulation (EU) 2025/2509, Toy Safety RegulationArticle 19Click opens the article on EUR-Lex. of the Toy Safety Regulation (Art. 1(1)Regulation (EU) 2025/2509, Toy Safety RegulationThe whole regulationClick opens the law on the EU Publications Office., point (d)) and has been in force since 6 August 2026. The SME guidelines are due by 1 August 2029 (Art. 24Regulation (EU) 2025/2509, Toy Safety RegulationArticle 24Click opens the article on EUR-Lex.).
• Standards under the Regulation. A toy that meets a harmonised standard whose reference is published in the Official Journal is presumed to meet the requirements it covers (Art. 15Regulation (EU) 2025/2509, Toy Safety RegulationArticle 15Click opens the article on EUR-Lex.). The Commission’s harmonised standards page, read on 2 October 2026, lists the Regulation as applicable from 1 August 2030 and the implementing decisions under the Directive only. It does not yet publish which standards give the presumption under the Regulation. The standard series is on EN 71.
• A Directive certificate for a toy placed after 1 August 2030. The certificate “shall remain valid until 1 February 2031” (Art. 57(3)Regulation (EU) 2025/2509, Toy Safety RegulationArticle 57, paragraph 3Click opens the article on EUR-Lex.). That does not extend placing: Art. 57(1)Regulation (EU) 2025/2509, Toy Safety RegulationArticle 57, paragraph 1Click opens the article on EUR-Lex. protects only toys placed before 1 August 2030, so a unit placed from that date must meet the Regulation. The Regulation does not say how such a unit uses the certificate; no official guidance read for this page covers the point.
• Customs checks. They start once the registry is linked to the EU customs single window (EU CSW-CERTEX), or on 1 August 2030 if that is later, and run on the commodity codes of Annex VII (Art. 23(4)Regulation (EU) 2025/2509, Toy Safety RegulationArticle 23, paragraph 4Click opens the article on EUR-Lex., Art. 23(6)Regulation (EU) 2025/2509, Toy Safety RegulationArticle 23, paragraph 6Click opens the article on EUR-Lex.).
• Which substances ECHA will allow. Part C of the Appendix lists nickel and cobalt now. The Commission can add or withdraw a permitted use by delegated act after an ECHA opinion (Art. 49(6)Regulation (EU) 2025/2509, Toy Safety RegulationArticle 49, paragraph 6Click opens the article on EUR-Lex., Art. 52Regulation (EU) 2025/2509, Toy Safety RegulationArticle 52Click opens the article on EUR-Lex.).
• Penalty amounts. Each EU country sets them, and none was read for this page.

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