If you source toys for the EU, the single most important date is 1 August 2030—that is when Regulation (EU) 2025/2509 actually applies to most toys. The Regulation entered into force on 1 January 2026, yet only specific articles (28–44 and 49–55) took effect immediately. Until August 2030, toys placed on the EU market must still comply with the existing Toy Safety Directive 2009/48/EC, including CE marking and conformity assessment against EN 71 harmonised standards. This article explains what buyers must do during the transition and what changes in 2030, so you can plan sourcing and compliance without panic.
Key Takeaways
- Now (2026) until 31 July 2030: keep placing toys under Directive 2009/48/EC, using current EN 71 harmonised standards and CE marking; the new Regulation does not yet apply to your products.
- From 1 August 2030, Regulation (EU) 2025/2509 will apply to toys placed on the EU market, introducing stricter chemical limits (e.g., BPA migration at 0.005 mg/l) and a mandatory Digital Product Passport replacing the paper Declaration of Conformity.
- Some provisions of the Regulation, particularly those on economic operator obligations and market surveillance (Articles 28–44 and 49–55), apply from 1 January 2026—these affect your role as importer or distributor even before 2030.
- The Digital Product Passport is not required now; its technical specifications are still pending delegated acts, but you should start building data-sharing processes with suppliers to be ready by 2030.
- Updated EN 71 standards are expected to fully replace current versions around July 2027; monitor these changes because testing against outdated standards could lead to non-compliance.
What Is Regulation (EU) 2025/2509 and Why It Matters for Toy Buyers?
Regulation (EU) 2025/2509 is the new EU toy safety framework that will replace the Toy Safety Directive 2009/48/EC. It was adopted on 26 November 2025 and entered into force on 1 January 2026, but it applies mainly from 1 August 2030—a 4.5-year transition. As a regulation, it will apply directly in all EU member states without national transposition, creating a single set of rules across the bloc.
Buyers face two distinct compliance tracks during this transition. Today, your toys must meet the requirements of Directive 2009/48/EC, including CE marking and conformity assessment via self-verification against harmonised standards or third-party verification by notified bodies. From 2030, the new regulation will impose stricter chemical rules, mandatory digital product passports, and cybersecurity requirements for connected toys.
Understanding this timeline is critical because many suppliers or secondary articles may blur the dates, implying that the new rules already apply. In reality, you have until August 2030 to adjust your product lines and documentation, but starting early is wise given the scale of changes.
Key Transition Dates for Regulation (EU) 2025/2509
| Adoption | 26 November 2025 |
|---|---|
| Entry into force | 1 January 2026 |
| Early application (Articles 28–44 and 49–55) | 1 January 2026 |
| Full application (most requirements) | 1 August 2030 |
| Until full application | Directive 2009/48/EC remains the legal framework for placing toys on the market |
Which Rules Apply to Your Toys Now (2026–2030)?
Toys placed on the EU market today must comply with the Toy Safety Directive 2009/48/EC, which has applied since 20 July 2011 (chemical safety requirements since 20 July 2013). Your products must meet essential safety requirements covering physical, mechanical, flammability, chemical, electrical, hygiene, and radioactivity risks. Conformity is demonstrated through CE marking, supported by a Declaration of Conformity referencing the directive and harmonised standards like EN 71-1 (mechanical/physical), EN 71-2 (flammability), and EN 71-3 (migration of elements).
The directive sets specific chemical restrictions, including bans on CMR substances in accessible parts, limits on 19 heavy elements, and restrictions on 55 allergenic fragrances (with labelling exceptions). These remain in force until 2030, so your existing compliance documentation is still valid.
However, some provisions of Regulation 2025/2509 already apply from 1 January 2026. Articles 28–44 and 49–55 cover obligations for economic operators (manufacturers, importers, distributors) and market surveillance authorities. For you as an importer or distributor, this may mean updated traceability requirements or cooperation duties with authorities, even though the substantive product safety rules haven't changed yet.
What Changes on 1 August 2030?
From 1 August 2030, Regulation (EU) 2025/2509 will apply to all toys placed on the EU market, replacing the directive. Key changes for buyers include:
Stricter chemical limits: The regulation expands restrictions beyond CMR substances to include endocrine disruptors (Category 1 or 2), respiratory and skin sensitisers, specific target organ toxicants, and other substances. It bans intentional use of PFAS and ten bisphenols, including BPA, with a migration limit lowered to 0.005 mg/l. Allergenic fragrance thresholds drop by 90% (from 100 mg/kg to 10 mg/kg). For slime/putty, specific nitrosamine limits apply (0.02 mg/kg). These changes will require reformulation of many products, so plan for potential cost increases.
Mandatory Digital Product Passport (DPP): Every toy placed on the EU market must have a DPP, replacing the paper Declaration of Conformity. The DPP will be a machine-readable data carrier (e.g., QR code) affixed to the toy, packaging, or accompanying documents, containing a unique product identifier and manufacturer/economic operator ID. Data must be kept for 10 years after placing on market. Technical specifications are pending delegated acts, but you should start building data-sharing processes with suppliers now.
New labeling rules: Warnings must be visible before purchase, including online. Font x-height minimum is 1.2mm, or 0.9mm for surfaces smaller than 80 cm². The word 'Warning' can be replaced by an optional triangle mark (yellow background, black border, black exclamation mark) with a minimum pictogram height of 10mm.
Cybersecurity requirements: For internet-connected toys, safety assessments must include cybersecurity and privacy by design. AI-enabled toys must comply with applicable EU regulations on AI. This adds a new layer of product development and testing.
Updated harmonised standards: New versions of EN 71-1 and EN 71-8 are expected to fully replace current versions around July 2027. Until then, continue referencing existing EN 71 standards under the directive. Monitor these updates to avoid non-compliance.
How to Prepare Your Supply Chain for the 2030 Transition
Audit your current product lines against the future chemical limits now. Even though full application is 2030, identifying reformulation needs early reduces last-minute costs. Ask suppliers for updated test reports covering PFAS, bisphenols, and N-nitrosamines, not just legacy EN 71-3 elements.
Develop a 'DPP-ready' evidence pack. This includes test reports, product identifiers, and manufacturer IDs. Build data-sharing processes with suppliers to ensure traceability data is available when the DPP becomes mandatory.
For connected or AI-enabled toys, factor cybersecurity and privacy-by-design into product development. Engage with suppliers who understand these requirements, as they will become essential for market access.
Compliance costs may rise due to chemical restrictions and testing, so factor potential increases into pricing negotiations and sourcing decisions.
Finally, verify that your EU-based importer or distributor is aligned with the new regulation's enforcement mechanisms. Under the regulation, online sales are also subject to obligations under the Digital Services Act, so ensure your e-commerce listings have robust compliance documentation.
FAQ
Does my toy need to comply with Regulation (EU) 2025/2509 now?
No, not for most requirements. The regulation is in force since 1 January 2026, but it applies mainly from 1 August 2030. Until then, toys placed on the EU market must comply with Directive 2009/48/EC and existing EN 71 standards. Only specific articles (28–44 and 49–55) apply now, covering economic operator obligations and market surveillance.
When is the Digital Product Passport (DPP) mandatory?
From 1 August 2030. The DPP will replace the paper Declaration of Conformity for every toy placed on the EU market. Technical specifications are still pending delegated acts, so start preparing your data management and supplier collaboration now, but do not expect to issue DPPs before 2030.
What are the new chemical limits I should prepare for?
From 2030, the regulation bans intentional use of PFAS and ten bisphenols, and lowers BPA migration limit to 0.005 mg/l. Allergenic fragrance thresholds drop to 10 mg/kg (from 100 mg/kg). For slime/putty, nitrosamine limit is 0.02 mg/kg. These are stricter than current directive limits, so request updated test reports from suppliers covering these substances.
I sell toys on Amazon EU. Do online sales have extra obligations?
Yes, under the new regulation, online sellers must comply with the General Product Safety Regulation (EU) 2023/988 regarding consumer information at the point of purchase. Additionally, the Digital Services Act imposes obligations on marketplaces, so ensure your listings include compliant warning labels and product information.
How can I ensure my supplier is ready for the 2030 changes?
Ask suppliers about their compliance roadmap for Regulation 2025/2509, including updated chemical testing, DPP data readiness, and awareness of new labeling rules. Prioritize suppliers with strong supply-chain control over input composition, as testing final products alone may be insufficient under the new regulation.
Sources
Request Certificates
When sourcing toys for the EU, always request up-to-date EN 71 test reports and declarations of conformity from your suppliers. To prepare for 2030, ask for chemical testing that covers the new restricted substances. For guidance on specific products or to verify supplier compliance, contact our team—we can help you navigate the transition.