Is it a toy? EU rules for borderline products
Is it a toy under EU law? How the Toy Safety Directive and Commission guidance classify borderline products, and what follows: CE marking or the GPSR.
Toys: EU safety rules and representation
Toys need CE marking and a business in the EU that holds the documents. The new Toy Safety Regulation applies from 1 August 2030 and brings a digital product passport for every toy.
- Toy Safety DirectiveDirective 2009/48/EC
- Toy Safety RegulationRegulation (EU) 2025/2509Applies from 1 August 2030
- Market Surveillance RegulationRegulation (EU) 2019/1020
- General Product Safety RegulationRegulation (EU) 2023/988
- RED cybersecurityDelegated Regulation (EU) 2022/30
- Batteries RegulationRegulation (EU) 2023/1542
Three key facts on toys
16%
Of Safety Gate alerts
Toys were the second most notified product category in the EU in 2025.
2030
New regulation applies
Regulation (EU) 2025/2509 applies from 1 August 2030 and replaces the Toy Safety Directive.
10 years
Documents on file
Technical documentation and declaration of conformity stay available to authorities for 10 years.
Who does what
Toys fall under Art. 4 of Regulation (EU) 2019/1020: a manufacturer outside the EU needs an importer, an authorized representative or a fulfilment service provider in the EU.
You, the manufacturer
- Safety assessment and EN 71 tests
- Technical documentation and declaration of conformity
- CE marking, warnings and instructions
- Notified body type-examination where standards are not applied in full
Written mandate
Representa, your EU Authorized Representative
- Keeps your toy documents available for 10 years
- Answers requests from market surveillance authorities
- Passes on information about risks and corrective action
- Our name and address on toy, packaging or documents
Deadlines ahead
The next dates from the rules on this page.
Toy Safety Regulation enters into force
Toy Safety Regulation
2 October 2026
Battery passport, QR code and replaceable portable batteries
Batteries Regulation
Due diligence obligations for battery raw materials
Batteries Regulation
Toy Safety Regulation applies, with a digital product passport for every toy
Toy Safety Regulation
How we help
EU Authorized Representative
We act as your EU Authorized Representative for toys and keep the documents ready for authorities.
CE marking support
We check EN 71 test reports, the safety assessment and your declaration of conformity.
Compliance verification
We review warnings, labels and packaging before your toys ship.
From 1 August 2030 the mandate of an authorized representative also covers keeping the digital product passport available for 10 years (Art. 8 of Regulation (EU) 2025/2509).
Free compliance guide: 5 steps to enter the EU market
Download our free checklist and learn what you need before selling in Europe.
- 01Classification
- 02Documentation
- 03Representative
- 04Labeling
- 05Ongoing compliance
Toys: frequently asked questions
Do I need an EU representative to sell toys online?
Yes, if you are outside the EU and have no EU importer. Toys fall under Article 4 of Regulation (EU) 2019/1020, so a business in the EU must hold the documents.
When does the new Toy Safety Regulation apply?
From 1 August 2030. Toys placed on the market under the current Directive before that date can still be sold afterwards.
Does every toy need a notified body?
No. If you apply the harmonised EN 71 standards in full, you declare conformity yourself. A notified body type-examination is needed where standards are missing, applied in part or cited with a restriction.
What is the digital product passport for toys?
A digital record of the toy's compliance information, reached through a data carrier such as a QR code. From 1 August 2030 it replaces the EU declaration of conformity.
Are PFAS banned in toys?
The Toy Safety Regulation bans the intentional use of PFAS in toys from 1 August 2030.
Does my EU representative also cover the UK?
No. In Great Britain an authorized representative for toys must be based in the UK. CE marking is accepted there.
Insights on this topic
CE marking for toys: six steps to the EU market
CE marking for toys under Directive 2009/48/EC: safety assessment, EN 71 standards, module A or notified body, warnings and the EU business you need.
RED cybersecurity requirements and EN 18031
RED cybersecurity requirements since August 2025: which devices are covered, when a notified body is needed despite EN 18031, and what the CRA changes.
Why companies choose Representa GmbH
Representa secured our EU Authorized Representative appointment within 48 hours, saving our shipment from costly delay.
U.S. electronic device manufacturerEU Authorized Representative They turned the CE Marking process into clear, actionable steps, helping us meet our launch timeline and pass compliance the first time.
Canadian consumer electronics companyCE marking Thanks to Representa, our products became fully GPSR-compliant well before the deadline, ensuring uninterrupted marketplace sales.
Asian consumer and healthcare exporterGPSR Responsible Person Our beauty cosmetics line faced labeling issues, but Representa's quick review and precise updates got us approved without delay.
Global beauty, fashion and cosmetics brandCompliance consulting The onboarding was fast and transparent. Representa made EU compliance simple and gave us confidence to expand across Europe.
Canadian industrial equipment supplier We were unsure how to manage new GPSR rules. Representa guided us step by step, keeping us fully compliant and avoiding delays.
U.S. consumer goods manufacturerGPSR Responsible Person
Selling toys in the EU?
Send us your toy range and target markets. We check the documents and set up your EU representation.
Get in touch with our team of experts
Tell us what you manufacture and where you want to sell. We identify the requirements for EU and UK market access and come back to you with the next steps.