Compliance
EU 2025/2509: the new Toy Safety Regulation and the digital product passport
This page is the reference version of the 2026 EU toy regime. For the explanatory version, see EU Toy Regulation 2025/2509 and the DPP.
Core position: the digital product passport is created and uploaded by the manufacturer placing the toy on the EU market. A non-EU supplier cannot create it, but must supply the data it is built from. We supply documentation inputs, not representation.
Timeline
| Date | Status |
|---|---|
| 26 November 2025 | Regulation adopted |
| 12 December 2025 | Published in the Official Journal as Regulation (EU) 2025/2509 |
| 1 January 2026 | Enters into force; replaces Directive 2009/48/EC |
| Transition period | Toys compliant with 2009/48/EC may continue to be placed on the market |
| 1 August 2030 | Applies in full; transition ends |
Confirm the transitional arrangements for your product and channel with your EU importer before committing to a production run that will land after the change.
What the regulation changes
- Digital product passport (DPP). A machine-readable compliance record, created before the toy is placed on the market and uploaded to the EU registry, reached through a data carrier such as a QR code.
- Tighter chemical requirements. PFAS, bisphenols, endocrine disruptors, sensitisers and fragrance allergens all move.
- Extended operator obligations. Fulfilment service providers become economic operators, and contact requirements expand.
- Marketplace obligations aligned with the DSA. Non-compliant toys are treated as illegal content, and CE, warnings and the DPP carrier must be visible before purchase.
- Explicit attention to under-3 toys. Mouthing exposure is the reason the chemical requirements matter most for this age grade.
The DPP: data content and ownership
| Data element | What it is | Who supplies it |
|---|---|---|
| Unique product identifier | A code identifying the specific toy or model | Manufacturer, with supplier data |
| Economic operator identification | Manufacturer and importer identities | Manufacturer; importer details |
| Legal references | The legislation and standards the toy conforms to | Manufacturer, from the assessment |
| CE marking information | The conformity statement behind the mark | Manufacturer |
| Fragrance allergen information | The declared allergens and their levels | Material and fragrance supplier |
| Technical documentation | Design, BOM, reports, risk assessment | Supplier inputs; manufacturer assembles |
The DPP is not a copy of the technical file made public. It is a record that points to compliance information, with a defined data set. Importers and distributors must verify that the DPP exists and that the carrier on the toy resolves to it.
Chemical requirements to plan for
| Substance group | Direction of change | Practical action |
|---|---|---|
| PFAS | Intentional use in toys banned | Ask material suppliers for PFAS statements, including coatings and stain repellents |
| Bisphenols | Tightened beyond BPA | Screen polycarbonate, epoxy and some adhesives |
| Endocrine disruptors | New restrictions added | Review finishes, plasticisers and any flexible component |
| Respiratory and skin sensitisers | New restricted categories | Check adhesives, inks and fragrance |
| Fragrance allergens | Declaration threshold moves from below 100 mg/kg to below 10 mg/kg | Reconfirm fragrance data; most wooden toys should avoid fragrance entirely |
| CMR substances | Existing framework retained | Keep the current screening in place |
For a wooden toy, the highest-risk items are usually finishes, inks, adhesives and any silicone or plastic component. A generic "EN 71-3 passed" statement does not answer these categories.
Operator obligations
| Operator | Obligation |
|---|---|
| Manufacturer | Create and upload the DPP; hold technical documentation 10 years; display name, postal address and email; maintain a channel for consumer safety complaints |
| Importer | Verify the DPP and carrier; verify the manufacturer's obligations are met; display its own name, postal address and email |
| Distributor | Act with due care; verify carrier and DPP where applicable |
| Fulfilment service provider | Treated as an economic operator, with corresponding duties |
| Online marketplace | Treat non-compliant toys as illegal content; show CE, warnings and the DPP carrier before purchase |
Two details that change packaging artwork immediately: the email address requirement, and the DPP data carrier. A label designed before 2026 may have room for a name and address but not for a QR code and an email line.
What we supply, and what stays with the buyer
| Item | We supply | Buyer does |
|---|---|---|
| Material declarations, including PFAS and bisphenol statements | Yes, per component | Passes to the responsible operator |
| Test reports and scope | Yes | Files in the technical documentation |
| BOM and component list | Yes | Uses to build the DPP data set |
| Label and carrier artwork | Yes | Approves and prints |
| DPP creation and upload | No | Manufacturer or EU importer |
| EU responsible person | No | Buyer appoints an EU-established entity |
What to do now
- Map each SKU to the EU importer or manufacturer that will hold the DPP obligation.
- Collect material-level declarations for finishes, inks, adhesives and silicone.
- Check existing reports for scope: which materials, which editions, which parts.
- Reserve label space for the carrier, CE mark, importer details and email.
- Keep documentation retrievable for 10 years.
FAQ
Q: Is the DPP required today?
The regulation is in force and the transition runs to 1 August 2030. The data collection can start now; the passport must exist before a toy is placed on the market under the new regime.
Q: Can our supplier create the DPP?
No. The manufacturer placing the toy on the market creates and uploads it. A non-EU supplier provides the data.
Q: Does the DPP replace the technical file?
No. The technical file remains, is retained for 10 years, and is the source of much of the DPP data.
Q: What happens to stock that meets 2009/48/EC?
During the transition it may still be placed on the market. Confirm the cut-off with your EU importer before committing to volume.
Related pages: EU EN 71 and CE and GPSR and the responsible person. For model-level document status, use the quote form.
This is a commercial explainer, not legal advice. Certification is model-specific and market-specific.
Tell us the model and the market
We confirm whether a report exists, or whether testing can be commissioned.