On 12 December 2025 the EU formally published the Toy Safety Regulation (EU) 2025/2509 (TSR) in the Official Journal. It enters into force on 1 January 2026 and provides a transition period of up to 55 months, applying in full from 1 August 2030, when it will completely replace the Toy Safety Directive 2009/48/EC that has served for more than a decade.

Scope

The scope is unchanged, covering products designed or intended for use in play by children under 14, whether or not exclusively for that purpose, but it is now explicit that "intended for use in play" is to be interpreted according to the reasonable perception of a parent or guardian.

In addition to products already excluded from the definition of a toy, the following are newly exempt:

- paintball equipment;

- reading and educational books for children over 36 months that have no play value.

Digital product passport (DPP)

The technical design and operating model of the digital product passport are still to be developed. Its content is similar to the current declaration of conformity but must additionally include the CE marking, the customs commodity code and how consumers can contact the manufacturer with complaints.

Manufacturers must upload the information to an EU digital registry, which is yet to be developed.

The information must be made available to the public through a data carrier such as a QR code and must be affixed to the toy itself or its label. Customs may release a toy only after verifying that the data carrier and commodity code match the data in the EU digital registry.

Chemical requirements

The chemical requirements for toys have been strengthened, with the following main changes.

Newly prohibited substances, in addition to the existing CMR requirements

- substances with endocrine-disrupting properties for human health (category 1 or 2);

- specific target organ toxicants (category 1, single or repeated exposure);

- respiratory sensitisers (category 1);

- skin sensitisers (category 1A);

- per- and polyfluoroalkyl substances (PFAS) intentionally added to toys. "PFAS" means any substance containing at least one perfluorinated methyl (CF3-) or methylene (-CF2-) carbon atom with no hydrogen, chlorine, bromine or iodine atoms attached.

Ten prohibited bisphenols

Heavy metal limits (unchanged except for aluminium)

N-nitrosamines and N-nitrosatable substances in five toy categories

Extension of specific substance restrictions

Restrictions previously applying only to toys for children under three now extend to toys for all age groups. The substances concerned include TCEP, TCPP, TDCP, formamide, BIT, CIT, phenol, formaldehyde and aniline, with the following new limits:

- acrylonitrile migration no more than 0.01 mg/l (polymeric materials)

- bisphenol A (BPA) migration no more than 0.005 mg/l

- butadiene migration no more than 0.07 mg/l (polymeric materials)

- styrene migration no more than 0.77 mg/l (polymeric materials)

- vinyl chloride migration no more than 0.01 mg/l (polymeric materials)

Other requirements

- toys must not be biocidal products;

- allergenic fragrances are added to the list of prohibited substances. They are permitted only where technically unavoidable under good manufacturing practice and must not exceed 10 mg/kg, down from 100 mg/kg under the current rules.

Transition

Directive 2009/48/EC is repealed on 1 August 2030, from which date only Regulation 2025/2509 applies. During the transition, companies may demonstrate compliance under either the new regulation or the current directive.

The implementation of the TSR is a major test for the global toy industry and an opportunity for high-quality development. As the compliance system matures and technical innovation deepens, Chinese toy companies can be expected to take a stronger position in the global high-end toy market, moving from scale advantage to quality advantage and injecting new momentum into the long-term health of the sector.