What You Need to Know: EU Officially Issues Toy Safety Regulation (EU) 2025/2509

On December 12, 2025, the Official Journal of the European Union adopted the Toy Safety Regulation (EU) 2025/2509 (referred to as "TSR"), marking a new era of "direct application" for EU toy safety supervision. The regulation will take effect on January 1, 2026, and be fully implemented on August 1, 2030—at which point the 16-year-old Toy Safety Directive (2009/48/EC, "TSD") will be repealed. A transitional period is provided, during which toys compliant with the Toy Safety Directive (2009/48/EC) may continue to be placed on the EU market until 1 August 2030.

As a third-party compliance testing institution focusing on global consumer goods, RTS Test has sorted out TSR’s key points from three dimensions ("Regulatory Changes, Core Requirements, Compliance Responses") based on the regulation text and official interpretations, to help your products access the EU market smoothly.

I.Regulatory Nature Transformation: From "Directive" to "Regulation"

The core difference between TSR and TSD lies in regulatory nature:

Old TSD (Directive): Required EU member states to transpose it into national laws, leading to potential implementation discrepancies. Enterprises faced "country-specific" compliance costs.

New TSR (Regulation): Applies directly to all EU member states without secondary transposition by members, enabling "one compliance, pan-EU access" and significantly reducing cross-market compliance barriers.

RTS Tip: Enterprises should focus on EU members’ TSR implementation details (e.g., language requirements, market inspection frequency). RTS provides localized compliance consulting to avoid market access delays due to detail omissions.

II.Core Revision Highlights: 6 Key Adjustments (Definition → Digitalization → Labeling)

1.Clear Toy Definition Exemptions

TSR adds two categories of "non-toy" exempt products to avoid compliance misclassification:

Explicit exclusions: Paintball equipment; purely educational books (no entertainment value, no additional materials/components) for children over 36 months.

Supplementary exclusions (per EU Parliament draft): Scooters for children over 20kg; puzzles with over 500 pieces; compressed air guns (excluding water guns); supervised educational scientific equipment (see EU Official Journal C/2025/1032 for details).

2.Digital Product Passport (DPP) Replaces Declaration of Conformity (DoC)

The Digital Product Passport (DPP) becomes the primary carrier of the EU Declaration of Conformity and related compliance documentation, replacing traditional paper-based formats:

DPP core content: Includes conformity declaration, chemical test reports, production information, etc., accessible via electronic carriers (e.g., QR codes, cloud links).

Timeline: The European Commission will issue DPP technical details within 12 months after TSR takes effect; SMEs will receive official guidance support.

3.Tighter Warning Label Specifications

All toys must meet stricter warning label standards to reduce child misoperation risks:

Warning messages: Must start with "Warning", or use a ≥10mm yellow triangular icon with a black exclamation mark.

Age warnings: For toys unsuitable for children under 36 months, the pictogram diameter must be ≥10mm, and font size and visibility must ensure clear legibility in accordance with harmonised EU standards and general safety principles.

4.New Requirements for Digital/Smart Toys (Mental Health + Cyber Safety)

For radio-controlled, internet-connected, and AI toys, TSR for the first time includes "child mental health risks" in basic safety requirements:

Assess potential impacts on children’s cognitive development (e.g., excessive addiction, information leakage).

Comply with Article 22 of the EU Digital Services Act (EU 2023/988): Online platforms must verify DPP authenticity.

III.Upgraded Safety Requirements: Physical + Electronic + Hygiene Protection

1.Physical & Mechanical Requirements (Choking, Hearing, Magnet Risks)

TSR adds 4 physical safety controls to address child injury incidents:

Food-simulating toys: Prohibit choking/inhalation risks (e.g., easily detachable small parts).

Expandable toys: Pass "no intestinal blockage after expansion" tests (referencing CPSC water bead test logic, better aligned with children’s physiology).

Non-sounding toys: Repeat operation noise ≤85 decibels to avoid hearing damage.

Magnet-containing toys: Magnet size/strength must prevent intestinal perforation; small magnets must be fixed and non-detachable.

2.Electrical Requirements (Battery Safety: Anti-access + Anti-disassembly)

For electric toy battery design, TSR sets mandatory requirements:

Small-part batteries: Accessible only via tools (e.g., screw-fixed, to prevent child disassembly/ingestion).

Rechargeable batteries: If toy size permits, designed to be detachable only by professionals; child self-replacement is prohibited.

RTS Testing: Provides battery anti-disassembly testing and electrical safety (IEC 62115) testing, issuing test reports compliant with EU CE certification.

3.Hygiene Requirements (Microbial Limits for Water-based Materials)

TSR first specifies microbial limits for "touchable water-based material toys":

Prohibit pathogenic bacteria (e.g., E. coli, Staphylococcus aureus).

Mold count ≤100 CFU/g, to avoid skin allergies after child contact.

IV.Chemical Safety Control: Tighter Limits + New Bans

TSR is the "strictest ever" for chemical substance control—expanding scope and tightening key substance limits. Key differences between TSR and TSD (core substances comparison) are shown below:

TSR also expands banned substance categories:

Endocrine disruptors (ED Category 1/2), acute target organ toxicity (STOT) Category 1 substances;

Skin sensitizer Category 1, respiratory sensitizer Category 1 substances;

Biocidal functions (e.g., antibacterial-coated toys, except outdoor permanent toys).

New specific bans:

Prohibit intentional use of PFAS in toys.

Prohibit 10 bisphenols in Annex D (may expand to 34 in the future).

Prohibit biocidal functions/products (per EU (EU) 528/2012), except outdoor permanent toys and some cosmetic preservatives.

New cobalt (Co) exemptions:

Co as Ni impurity in stainless steel parts;

Co in conductive parts;

Co in neodymium magnets (if non-swallowable/inhalable).

RTS Tip: The European Commission will consult ECHA on the safety of Pb/Cd/Hg/hexavalent Cr 12–24 months after TSR takes effect—limits are expected to tighten further. Enterprises should reserve low-toxic alternative materials early; RTS provides full-chain support (substance screening → alternative material recommendation → compliance testing). With only 1 month until TSR takes effect and the 2030 full implementation deadline approaching, early compliance testing is key for toy enterprises exporting to the EU to seize market opportunities.