EU regulation
Toy Safety Regulation: product passports and safety requirements
Overview
Short answer
Regulation (EU) 2025/2509 is adopted and in force, but its product requirements generally apply from 1 August 2030. It replaces the Toy Safety Directive and introduces a digital product passport. Certain provisions concerning authorities, notified bodies and rulemaking apply earlier. Articles 56 and 59.
Legal status
Adopted; general application in 2030
Checked 11 October 2026. In force since 1 January 2026. General application and repeal of the Directive on 1 August 2030.
Part 1
Which toys are covered?
The Regulation covers products intended for play by children under 14, even where they have other functions. Article 2 and Annex I define products within scope and exclusions. Manufacturers, importers and distributors have responsibilities according to their roles. Record the classification for the actual product rather than relying on a broad sales category. Articles 2 and 7–10.
Part 2
Two dates that must stay separate
The Regulation entered into force on 1 January 2026. Articles 28–44 and 49–55 apply from the same date. General application is nevertheless 1 August 2030. Until then, the Toy Safety Directive remains central to product assessment. A future product passport requirement must not be described as a general obligation already applying in 2026. Article 59.
Part 3
Assess the toy’s complete risk profile
When the product requirements apply, safety assessment must cover relevant hazards and exposure, including chemical and mechanical risks. Harmonised standards or common specifications can support the assessment within their coverage. Article 26 determines when internal production control or EU-type examination followed by conformity to type is required. Articles 25 and 26.
Part 4
Read chemical requirements alongside their exceptions
Annex II extends controls on certain hazardous substances and prohibits intentional PFAS use within the specified scope. It also addresses technically unavoidable unintended presence, specifically permitted uses and excluded situations. Describing every substance as prohibited in every component would therefore misrepresent the requirements. Annex II, Part III, points 4–11.
Part 5
The passport connects to the evidence
From 1 August 2030, before market placement, the manufacturer must create a passport that normally corresponds to a toy model and contains the required information. It must remain accurate and up to date and connect to a persistent unique product identifier through a data carrier. Technical documentation and CE marking remain necessary. Follow technical details under Article 49 separately. Articles 7 and 19–20.
Part 6
Keep control of earlier and future versions
Toys lawfully placed on the market under the Directive before 1 August 2030 may continue to be supplied. EC-type examination certificates under the Directive remain valid until 1 February 2031 at the latest, unless they expire earlier. Start connecting material data and test evidence to identifiable model versions and distinguish these from planned changes. Article 57.
Checklist
Key takeaways
- Distinguish entry into force from general product application in 2030.
- From 1 August 2030, manufacturers must create a passport before market placement.
- Chemical requirements include prohibitions and defined exceptions.
- Transitional provisions cover earlier toys lawfully placed on the market.
Questions and answers
Frequently asked questions
Is this still a proposal?
No. Regulation 2025/2509 is adopted and in force; different provisions have different application dates.
Does every toy need a passport already in 2026?
No. The passport rules form part of general application from 1 August 2030.
Does the passport replace the safety assessment?
No. Safety assessment, technical documentation and the applicable conformity procedure remain necessary.
Must earlier stock be removed on 1 August 2030?
Not merely because of that date. The transition covers toys lawfully placed on the market under the Directive before it.
Further reading
Official sources
How Verca helps
How Verca can support the process
Verca organises product evidence, documents and version history. The company remains responsible for assessment. Explore the platform.