Compliance
EU: EN 71 and CE marking
This page is the reference version of the EU toy requirement for wooden toys: what applies, what the file contains, and who signs. For the walkthrough, see EN 71 parts explained.
Core position: CE marking is a declaration, not a certificate. The Declaration of Conformity is signed by the manufacturer, or by the importer when it places the toy on the market under its own name. We supply the test reports and technical inputs; we do not sign DoCs for importers.
Requirements at a glance
| Requirement | Detail | Evidence | Signed or held by |
|---|---|---|---|
| Toy legislation | Directive 2009/48/EC, in transition; Regulation (EU) 2025/2509 in force since 1 January 2026, fully applicable from 1 August 2030 | DoC referencing the applicable framework | Manufacturer / EU importer |
| Mechanical and physical safety | EN 71-1 | Test report | Lab; manufacturer holds |
| Flammability | EN 71-2, where soft components are in scope | Test report | Lab |
| Element migration | EN 71-3, 19 elements, limits by material category | Test report | Lab |
| CE marking | Applied by the manufacturer, size and proportion rules | Photo of product and packaging | Manufacturer |
| Technical file | Design, BOM, reports, risk assessment, warnings, age grading rationale | Document set | Manufacturer, kept 10 years |
| Warnings | In the language of the country of sale; Annex V warning types | Artwork and label | Importer approves |
| Under-36-month rules | No detachable small parts; chemical requirements including phthalates and CMR | Design plus reports | Manufacturer |
What each EN 71 part covers
| Part | Scope on a wooden toy |
|---|---|
| EN 71-1 | Small parts, sharp edges and points, gaps and holes, cords, mouth-actuated toys, stability, drop tests, packaging film |
| EN 71-2 | Flammability of textiles, ropes, felt, paper and other soft components |
| EN 71-3 | Migration of 19 elements from wood, coatings, inks and materials |
The parts are revised periodically. Confirm the current edition with your lab and note it on the report and technical file.
CE marking: what it is
CE marking is the manufacturer's visible statement that the toy meets the applicable requirements of the toy legislation. There is no authority-issued "CE certificate". The mark is only meaningful when it is supported by:
- A technical file containing design information, bill of materials, test reports, risk assessment, warning texts and the age grading rationale.
- A Declaration of Conformity, signed by the responsible economic operator.
- Correct application: legible, durable, minimum size, required proportions.
The technical file must be kept 10 years after the toy is placed on the market. Market surveillance authorities can ask for it years later.
The Declaration of Conformity
A usable DoC identifies:
- The product, by model or type, and the batch or serial reference where applicable.
- The manufacturer's name and address, and the authorised representative where one is appointed.
- The legislation the products are declared to conform to.
- The harmonised standards applied, with editions.
- The notified body details, where one was involved.
- Name, signature and date of the signatory.
The DoC should track the technical file: if the file cites EN 71-1/-2/-3, the DoC references the same standards and editions.
Warnings and language
Toy warning requirements are part of the toy legislation, and the warning must be in the language of the country where the toy is sold. Across several EU markets, that means multiple language versions on the packaging or in an accompanying document, depending on format.
For a wooden toy range:
- A toy sold in Germany needs German warnings, not English only.
- Warnings must be legible and durable, and placed where the consumer sees them.
- The warning must match the actual hazard, not a generic safety statement.
- Age grading and the warning must not contradict each other.
The transition to Regulation (EU) 2025/2509
The EU has replaced Directive 2009/48/EC with Regulation (EU) 2025/2509, in force from 1 January 2026 and fully applicable from 1 August 2030, with a transition period for toys compliant with the old directive. EN 71 remains the route to presumption of conformity, but the surrounding framework changes: a digital product passport, tighter chemical restrictions, and extended economic operator obligations.
Do not plan a 2027–2030 EU range assuming nothing changes. The 2025/2509 and DPP page covers the data and obligations.
What we supply, and what stays with the buyer
| Item | We supply | Buyer does |
|---|---|---|
| EN 71 reports per model | Yes, with part editions and sample scope | Holds in the technical file |
| Material and component data | Yes | Uses in the technical file |
| Label and warning text data | Yes, with translation via partner | Approves in destination languages |
| Technical file inputs | Yes | Assembles and retains it |
| Declaration of Conformity | No | Signed by manufacturer or EU importer |
| CE mark application | Artwork support | Applied by the responsible manufacturer |
| EU responsible person | No | Buyer appoints an EU-established entity |
FAQ
Q: Is there a CE certificate for toys?
No. CE marking is a self-declaration supported by a technical file and a DoC. A supplier offering a "CE certificate" is describing something that does not exist in EU law.
Q: Who signs the DoC for our order?
The manufacturer, or the importer placing the toy on the EU market under its own name. A non-EU supplier cannot sign a DoC for an EU importer.
Q: How long must the technical file be kept?
10 years. Plan for retrieval years after the shipment, not just for the current season.
Q: Which EN 71 parts does a wooden toy need?
EN 71-1 and EN 71-3 in almost all cases. EN 71-2 where the toy has textile, rope, felt or paper components. The report should state explicitly where a part is not applicable.
Related pages: Regulation 2025/2509 and the DPP and the UK page for the GB equivalent. For model-level report 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.