European Union Releases Revised Draft of Toy Safety Regulations

February 27, 2025 — The European Commission announced the revised draft of the Toy Safety Regulations (TSR), intended to replace the current Toy Safety Directive (TSD) (Directive 2009/48/EC). If approved, the new regulations will enter into force 20 days after their publication in the Official Journal of the EU.

The TSR draft introduces significant revisions to the TSD, including (but not limited to) the following:

● Adjustments to the Scope of Toy Definition Exemptions

The following two categories are explicitly excluded from the definition of toys:
• Scooters designed for children weighing over 20 kg
• Books intended for children older than 36 months, that are made entirely of paper or cardboard, without additional materials or components.

• Risks to Mental Health, Well-being, and Cognitive Development

Manufacturers must assess risks to children's mental health and cognitive development. These requirements apply to toys that interact with digital technologies, such as smartphones, tablets, or other smart devices.

• Introduction of a Digital Product Passport (DPP) to Replace the Current Declaration of Conformity (DoC)

The DPP is a product-specific dataset accessible via electronic carriers (e.g., QR codes) and includes the DoC and other relevant information. The European Commission must adopt delegated acts within 12 months of TSR’s entry into force to clarify technical requirements for DPPs. Implementation guidelines and automated translation tools for all EU official languages will be published within one year of TSR’s effective date.

• Risk Communication Requirements for Online Platform Sales

Online warnings must be clearly visible and immediately accessible (e.g., displayed on product detail pages) to ensure consumers are informed of toy-related risks, particularly for remote and online sales.

• Alignment with the General Product Safety Regulation (GPSR, 2023/988) for Online Sales

For example, online platforms must register on the Safety Gate Portal and designate a single point of contact.

• Enhanced Chemical Safety Assessment Mechanisms

Assessments must consider risks from single chemical exposures and combined exposures from multiple chemicals in toys, while aligning with obligations under the REACH Regulation.

• Expanded List of Banned Substances

Prohibited categories now include:
• Endocrine disruption category 1 or 2 , for human health and the environment;
• Specific target organ toxicity category 1, either in single exposure or in repeated exposure;
• Respiratory sensitisation category 1;
• Skin sensitisation category 1;
• Persistent, Bioaccumulative, and Toxic (PBT);
• Very Persistent and Very Bioaccumulative (vPvB);
• Persistent, Mobile, and Toxic (PMT);
• Very Persistent and Very Mobile (vPvM).

• Newly Banned Substances

• Per- and polyfluoroalkyl substances (PFAS)

• Bisphenols

• Revised Restrictions on Chemical Substances

• Refine warning label specifications
The term 'Warning' may be replaced such as the following pictogram, which shall be displayed in a prominent way."

• Composition and Labeling Requirements for Specific Toys
Slime, Finger-paint or Modelling clay shall comply with the compositional and labeling requirements laid down in Regulation (EC) No 1223/2009 of the European Parliament and of the Council.

• Implementation Timeline
A 30-month transition period begins after TSR’s entry into force (some provisions apply immediately). Toys compliant with the current TSD may remain on the EU market for up to 50 months after the transition period ends.

CTT Advisory Notice

The TSR draft signals a comprehensive upgrade to toy safety standards. Relevant enterprises should monitor updates, develop compliance strategies, and complete adjustments during the transition period. As a leading testing agency, CTT offers expert support and efficient product testing services. For inquiries, please contact CTT.