Guide · updated 2026-11-07
EU Toy Regulation 2025/2509 and the DPP
The EU has replaced its toy safety directive with a regulation, and the change is not cosmetic. Regulation (EU) 2025/2509 entered into force on 1 January 2026, replaces Directive 2009/48/EC and applies fully from 1 August 2030. During the transition, toys complying with the old directive can still be placed on the market.
For importers of 0–3 wooden toys the headline is the digital product passport: a machine-readable record that must exist before the toy is placed on the market. The second headline is chemistry — PFAS, bisphenols, endocrine disruptors and fragrance allergens all move. It also covers who does what.
What changes, and when
| Date | What happens |
|---|---|
| 1 January 2026 | Regulation (EU) 2025/2509 enters into force; the old directive starts its transition out |
| During transition | Toys compliant with 2009/48/EC may still be placed on the market |
| 1 August 2030 | The regulation applies in full; transition ends |
Confirm the exact transitional arrangements for your product category with your EU importer or compliance adviser, because the answer depends on when the goods are placed on the market, not when they are made.
The digital product passport in plain terms
The DPP is a digital record of the toy's compliance information. Before placing a toy on the market, the manufacturer must create it and upload it to the EU registry. A data carrier — typically a QR code — links the physical toy to the record.
The passport has to carry at least:
- A unique product identifier.
- Identification of the economic operators in the chain.
- The legal references the toy is compliant with.
- The CE marking information.
- Information on fragrance allergens that must be declared.
Technical documentation must be kept for 10 years. Importers and distributors have a verification duty: they must check that the DPP exists and that the carrier on the toy points to it. A toy without a valid carrier is a compliance problem on the shelf, not just at customs.
Chemicals: what tightened
The regulation keeps the existing framework and adds new restrictions that hit 0–3 products hardest:
- PFAS: intentional use in toys is banned.
- Bisphenols: requirements tightened beyond the previous BPA focus.
- Endocrine disruptors: new restrictions, in addition to the existing CMR rules.
- Respiratory and skin sensitisers: new categories of restricted substances.
- Fragrance allergens: the declaration threshold moves from below 100 mg/kg to below 10 mg/kg.
- Under-3 emphasis: toys for children under 3 receive specific attention, because mouthing is the exposure route.
For a wooden teether that means a longer material conversation: wood species, finish, paint, ink, silicone parts, adhesives and fragrance. Ask your lab which of these need a new test rather than assuming an old EN 71-3 report answers every question.
Who does what in the DPP chain
| Actor | Obligation |
|---|---|
| Manufacturer (EU or non-EU) placing the toy on the market | Creates the DPP, uploads it to the registry, keeps technical documentation 10 years, maintains a channel for safety complaints from end users |
| Importer | Verifies the DPP and the carrier, and that the manufacturer has met its obligations; puts its own name and address on the toy |
| Distributor | Acts with due care; verifies the carrier and DPP where applicable |
| Fulfilment service provider | Now treated as an economic operator with corresponding obligations |
| Online marketplace | Non-compliant toys are treated as illegal content under the DSA; CE, warnings and the DPP carrier must be visible before purchase |
Another change worth putting on the packaging spec sheet: manufacturers and importers must show their name, postal address and email address on the toy. A name and address alone is no longer enough.
What a non-EU supplier can and cannot do
This is the part Chinese suppliers need to say out loud. A non-EU factory or trading company cannot create the DPP on its own account for the EU market, and cannot act as the EU responsible operator. What it can do is supply the inputs: material declarations, component lists, coating and ink specifications, test reports, factory identity and production data.
In practice, a supplier of wooden baby toys should be able to hand you a DPP-ready data pack — the same information that goes into the technical file, structured so your EU importer can load it into the passport. If a supplier has never heard of the DPP, that is useful information about how the next three years will go.
Preparation checklist
- Map every SKU to its EU importer or authorised representative.
- Confirm which test reports exist, which standard editions they cover, and which materials were sampled.
- Ask each material supplier for PFAS and bisphenol statements, in writing.
- Build a component-level bill of materials, including adhesives, inks and finishes.
- Design the label so it can carry the QR carrier, the CE mark, the importer details and the email address.
- Keep the technical file retrievable for 10 years — a folder on a laptop is not a records system.
FAQ
Q: Do we need the DPP now?
The regulation is in force, but full application is 1 August 2030, with a transition period for toys compliant with the old directive. The prudent answer is to start collecting the data now, because the passport is built from records you should already hold.
Q: Can our Chinese supplier create the digital product passport?
No. The manufacturer placing the toy on the EU market creates and uploads the passport. A non-EU supplier provides the underlying data.
Q: Does EN 71 still apply?
Yes. EN 71 remains the harmonised standard route to presumption of conformity. What changes is the legal framework around it, plus the additional chemical restrictions and the passport.
Q: Is a QR code on the packaging enough?
A QR code is a data carrier, not the passport. It must resolve to a valid DPP record. If the record does not exist, the code is decoration.
Q: What happens to stock that complies with 2009/48/EC?
During the transition they may still be placed on the market. Confirm the cut-off with your EU importer before committing to a large production run.
For the market reference page, see EU 2025/2509 and the digital product passport. For the standards that still apply, read EN 71 parts explained. If you are preparing an EU launch, the EU responsible person guide covers the other obligation that arrives before the passport does. Ask for a model-level document check through the quote form.
This is a commercial explainer, not legal advice. Certification is model-specific and market-specific.
Sourcing 0–3 wooden toys?
Send the market and the model list; we confirm the documents before the price.