On 12 November 2025 the Official Journal of the EU published Regulation (EU) 2025/2509 on the safety of toys, replacing Directive 2009/48/EC. The new rules will apply from 13 July 2028, giving the industry roughly 30 months to adapt. Below are the seven changes with the biggest practical impact on manufacturers and importers.
2025/2509
New Regulation number
30 months
Transition period
27 EU states
Direct applicability
1. From Directive to Regulation — one rulebook across all 27 Member States
The old Toy Safety Directive allowed each country to transpose its requirements slightly differently. Regulation 2025/2509 is directly applicable in every EU Member State, eliminating national interpretation gaps. For companies operating across borders this means a single set of obligations, a single set of deadlines, and far less legal ambiguity.
Practical takeaway
Review any country-specific compliance checklists you maintain — most will collapse into one EU-wide process after July 2028.
2. Digital Product Passport (DPP) replaces the paper trail
Every toy placed on the EU market will need a Digital Product Passport accessible via a data carrier (QR code, RFID, or similar) on the product or its packaging. The DPP must link to:
- EU Declaration of Conformity
- Test reports and technical documentation references
- Instructions and safety information
- Supply chain traceability data
The European Commission will adopt implementing acts specifying the exact data elements, but manufacturers should start mapping their documentation systems now.
How the DPP works
QR Code
on product
DPP endpoint
hosted URL
DoC & reports
technical file
Compliant
market access
3. Stricter chemical requirements — endocrine disruptors in scope
The Regulation explicitly brings endocrine-disrupting chemicals (EDCs) into the toy-safety framework. Substances classified as CMR category 1A, 1B, or 2 remain restricted, and new provisions target:
- EDCs identified under REACH or CLP criteria
- Sensitising fragrances — the allowed list is tightened significantly
- Lower migration limits for specific heavy metals and nitrosamines
Laboratories certified under LCAS™ will see an increase in chemical-analysis test scopes, and base costs (BC) for EN 71-9/10/11 suites are expected to rise as new analytes are added.
Chemical compliance alert
If your toys contain scented materials, rubber, or painted surfaces, request updated Safety Data Sheets from suppliers now. The expanded EDC and fragrance restrictions may affect formulations that were previously compliant.
4. Tighter rules for toys sold online
For the first time, EU toy safety legislation places explicit obligations on online marketplaces. Fulfilment service providers and platforms that facilitate the sale of toys to EU consumers must:
- Ensure a responsible economic operator is identified for every listed toy
- Cooperate with market surveillance authorities
- Remove non-compliant listings without undue delay
Importers selling via e-commerce platforms should confirm their marketplace partners’ readiness and update product listings with the required digital links.
5. Expanded age-grading and new hazard categories
The Regulation introduces refined age-grading guidance in the essential safety requirements and adds new hazard categories for:
- Connected toys / IoT — cybersecurity-related risks to children’s safety
- AI-enabled toys — behavioural risks from adaptive interactions
- Sensory hazards — expanded acoustic and optical limit values
Harmonised standards (EN 71 series) will be updated to reflect these categories. Until revised standards are published, manufacturers may use the Regulation’s Annex II essential requirements directly.
Connected / IoT
AI-enabled
Sensory hazards
6. Reinforced market surveillance and RAPEX/Safety Gate integration
National authorities gain stronger enforcement powers: the ability to purchase toys anonymously online for testing, request technical documentation digitally, and impose EU-wide recalls more quickly via the Safety Gate system. The Regulation also mandates that economic operators respond to authority requests within 10 working days.
Manufacturers and importers should ensure their compliance team can locate and transmit any technical file within that timeframe — a well-organised DPP back-end will make this straightforward.
7. Transition timeline — key dates at a glance
12 November 2025
Publication in the Official Journal
2 December 2025
Entry into force (20 days after publication)
13 July 2028
Application date — full compliance required
13 July 2030
End of sell-off period for toys placed under the old Directive
The 30-month transition window may seem generous, but experience with previous EU product regulations (MDR, Machinery Regulation) shows that supply-chain adjustments, laboratory capacity planning, and IT systems for the DPP require early action.
What should you do now?
- Gap analysis — compare your current compliance file against the new Regulation’s essential requirements.
- Chemical screening — check your formulations and materials against the expanded restriction lists, especially EDCs and fragrances.
- DPP readiness — evaluate your product data management: can you generate machine-readable technical data linked to a unique product identifier?
- Laboratory planning — contact your test laboratory early. New test scopes will increase demand, and lead times may stretch as the 2028 deadline approaches.
- Cost estimation — use the LCAS™ Calculator to estimate updated testing costs under new EN 71 scopes once base-cost data is published.
The LCAS Technical Committee will publish updated base-cost presets for the revised EN 71 series as soon as harmonised standards reflecting Regulation 2025/2509 are adopted. Subscribe to our updates to be notified.