On 12 December 2025, the EU published EU Toy Safety Regulation (EU) 2025/2509 (TSR). The new regulation replaces the previous directive 2009/48/EC and will apply on 1 August 2030.

Key changes include:

1. The legal status has been upgraded from directive to regulation, the regulation and its amendments will apply directly to all Member States.

2. Exempting the following products from the definition of toys:

• paint ball equipment;

• reading and educational books intended for children older than 36 months, that do not have a play value.

3. Replacing the EU declaration of conformity (DoC) with the digital product passport (DPP) .

4. Allows the use of a pictogram with an exclamation mark as an alternative for the word ‘warning’.

5. Adds food imitation, obstruction of intestines and magnets in the essential safety requirement.

6. Adds safety requirement for electric toys with batteries that constitute small parts or rechargeable battery.

7. Adds microbiological requirement for toys with accessible aqueous materials.

8. Emphasising that toys with artificial intelligence (AI) that require third-party conformity assessment are classified as high-risk AI systems under AI Act (Regulation (EU) 2024/1689), Cyber Resilience Act (Regulation (EU) 2024/2847), RED Directive 2014/53/EU, etc. Additionally, interconnected toys with substantial social interactive features (e.g., speaking or filming) or location tracking features are considered important products with digital elements (Class I) and require undergoing a third-party conformity assessment, unless the manufacturer has applied harmonised standards, common specifications or European cybersecurity certification schemes at a “substantial” assurance level.

9. Revising the general ban on toys containing substances that are classified as carcinogenic, mutagenic or toxic for reproduction (CMR substances) in Regulation (EC) No. 1272/2008, to include the following categories:

• endocrine disruption for human health category 1 or 2;

• specific target organ toxicity category 1, either in single exposure or in repeated exposure;

• respiratory sensitisation category 1;

• skin sensitisation category 1A.

10. Prohibiting per- and polyfluoroalkyl substances (PFAS) if these are intentionally added.

11. Forbidding 10 bisphenols listed in part D of the Appendix added.

12. Emphasizing that toys must not have a biocidal function where they would be considered as a biocidal product, or be treated with, or intentionally incorporate, one or more biocidal products, under Regulation (EU) 528/2012.

13. Revising the restriction of nitrosamines and nitrosatable substances in five categories of toys.

14. Restricting 14 chemicals in (all) toys – TCEP, TCPP, TDCP, formamide, BIT, CIT, phenol, formaldehyde and aniline, as well as the following new specifications:

• ≤ 0,062 mg/m3 formaldehyde emission in wood toy material

• ≤ 0.01 mg/L acrynonitrile migration (polymeric materials)

• ≤ 0.005 mg/L BPA migration

• ≤ 0.07 mg/L butadiene migration (polymeric materials)

• ≤ 0.77 mg/L styrene migration  (polymeric materials)

• ≤ 0.01 mg/L vinyl chloride migration (polymeric materials)

15. Update the requirements for Allergenic fragrances content limits (or limits to trigger labelling obligation): 10 mg/kg (reduced from the present 100 mg/kg) each. When the labelling obligation is triggered, the information of allergenic fragrances shall also be in the digital product passport (DPP).

16. Expands the permitted use of cobalt under the general prohibition.

URL：

https://eur-lex.europa.eu/eli/reg/2025/2509/oj

BACL Physical and Chemical Inspection and Certification Services：

BACL,with its headquarter in Silicon Valley, it is a global and comprehensive international third-party testing and certification body. Currently we have physical and chemical testing labs in the United States, Shenzhen, Dongguan, Xiamen and other places, and we have accredited the certifications by CNAS (Registration No.: L2408, L5662, L6290, L9963, L11432, IB0343), CPSC (Lab ID: 1112, 1415, 1647), CMA (No.: 2016192126Z, 2015192413Z) and other authorities. We offer a full range of testing services which cover footwear, toys, textile, clothing, leather, jewelry, groceries, food contact materials, cosmetics and electrical and electronic products, etc. We can help enterprises to complete the precise control of whole industry chain from raw materials to the finished products.