The new EU Toy Safety Regulation (2025/2509): what changes for testing

What was adopted

Regulation (EU) 2025/2509 was adopted on 12 December 2025 and entered into force on 23 December 2025, replacing the Toy Safety Directive 2009/48/EC. It becomes fully applicable on 1 August 2030 after a 54-month transition, so EN 71 testing under the current directive continues in the meantime — but the new chemical bans are coming and are worth designing for now.

What changes for chemicals

The regulation extends the ban beyond CMR substances to other groups considered especially harmful to children: endocrine disruptors, substances toxic to the respiratory system, and chemicals toxic to the skin or other organs. It also bans, where intentionally used, PFAS and bisphenols in toys, their components and micro-structurally distinct parts, and tightens the rules on allergenic fragrances.

• +EN 71-3 — migration of elements (continues as the core chemical test)
• +PFAS — screening and targeted analysis as the ban takes effect
• +Bisphenols (e.g. BPA) — targeted analysis
• +Phthalates and other restricted plasticisers (REACH)
• +Endocrine disruptors and allergenic fragrances — per the new lists

The Digital Product Passport

The new regulation introduces a Digital Product Passport for toys: batch-level data, including test results proving the absence of banned substances, will need to be stored and made accessible. Keeping structured test records now makes the passport straightforward when it applies.

What it costs and what to do now

EN 71 toy testing today is indicatively from €400 net; added PFAS and bisphenol screening will widen the chemical scope as the new limits bite. Until 1 August 2030 the current EN 71 dossier remains valid — the practical move is to design out PFAS, bisphenols and restricted substances now, and keep the test data for the passport.