SG 187/25
New EU Toy Safety Regulation 2025/2509 published on December 12, 2025, introducing new requirements such as the Digital Product Passport (DPP)
European Union (EU) has published new Toy Safety Regulation (2025/2509) on December 12, 2025, introducing the Digital Product Passport and new chemical requirements.
Scope
Although the scope has remained the same (products that are designed or intended, whether or not exclusively, for use in play by children under 14 years of age) there is a clear statement that “intended for use in play” should be interpreted as what parents or supervisors can reasonably assume.
In addition to the products currently exempted from the definition of toys, the following products have been newly exempted:
- Paintball equipment
- Reading and educational books intended for children over 36 months that do not have a play value.
Digital Product Passport (DPP)
The technical design and mode of operation still need to be developed. The content of the DPP is similar to the current Declaration of Conformity but requires additional information such as the CE-marking, the customs commodity code and how consumers can contact the manufacturer in case of a complaint.
Manufacturer should upload the information to the EU digital registry (to be developed).
The information should be publicly available through a data carrier (QR code or similar) and must be affixed to the toy or its label. Customs authorities may release a toy only after verifying that the data carrier and commodity code correspond to the data in the EU digital registry.
Chemical requirements
The chemical requirements for toys have been strengthened. Key changes include:
- Following substance are prohibited in addition to the current CMR requirements:
- Endocrine disruption for human health, category 1 or 2
- Specific target organ toxicants, category 1, in either single or repeated exposure
- Respiratory sensitizers, category 1
- Skin sensitizers, category 1A
- PFAS intentionally used in toys are prohibited. ‘PFAS’ means any substance that contains at least one fully fluorinated methyl (CF3-) or methylene (-CF2-) carbon atom (without any H/Cl/Br/I attached to it)
- Ten bisphenols listed below are prohibited:
| No | Substance name | CAS number | EC Number |
|---|---|---|---|
| 1 | 4,4’-(1-methylpropylidene)bisphenol; bisphenol B | 77-40-7 | 201-025-1 |
| 2 | 4,4’-isopropylidenedi-o-cresol | 79-97-0 | 201-240-0 |
| 3 | 6,6’-di-tert-butyl-4,4’-butylidenedi-m-cresol | 85-60-9 | 201-618-5 |
| 4 | 2,2’,6,6’-tetra-tert-butyl-4,4’-methylenediphenol; TBMD | 118-82-1 | 204-279-1 |
| 5 | 4,4’-isopropylidenebis[2-allylphenol] | 1745-89-7 | 217-121-1 |
| 6 | 4,4’-isopropylidenedi-2,6-xylol | 5613-46-7 | 227-033-5 |
| 7 | 2,2’-[(1-methylethylidene)bis(4,1-phenyleneoxy)]bisethyl diacetate | 19224-29-4 | 242-895-2 |
| 8 | (1-methylethylidene)bis(4,1-phenyleneoxy-3,1-propanediyl) bismethacrylate | 27689-12-9 | 248-607-1 |
| 9 | 4-(4-isopropoxyphenylsulfonyl)phenol | 95235-30-6 | 405-520-5 |
| 10 | 2,2’-diallyl-4,4’-sulfonyldiphenol; TG-SA | 41481-66-7 | 411-570-9 |
- The limits for heavy metals remain unchanged, except for aluminum:
| Element | mg/kg in dry, brittle, powder-like or pliable toy material | mg/kg in liquid or sticky toy material | mg/kg in scraped-off toy material |
|---|---|---|---|
| Aluminium | 2,250 | 560 | 28,130 |
- Restriction of N-nitrosamines and N-nitrosatable substances in five categories of toys:
| N-nitrosamines mg/kg | N-nitrosatable substances mg/kg | |
|---|---|---|
| (a) Toys intended for use by children under 36 months and intended or likely to be placed into the mouth | 0.01 | 0.1 |
| (b) Toys intended for use by children under 36 months not covered by (a) | 0.05 | 1 |
| (c) Toys intended for use by children of 36 months and over and intended to be placed into the mouth | 0.05 | 1 |
| (d) Balloons | 0.05 | 1 |
| (e) Finger paints, slimes and putties | 0.02 | 1 |
- The restrictions for specific substances which previously applied only to toys for children under three years, now apply to toys for all ages. These include TCEP, TCPP, TDCP, formamide, BIT, CIT, phenol, formaldehyde and aniline, as well as the following new specifications:
- ≤ 0.01 mg/L acrylonitrile 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)
- Toys should not be biocidal products
- Additional allergenic fragrances have been added to the list of prohibited substances. Their presence is only permitted if technically unavoidable under GMP and must not exceed 10 mg/kg (reduced from the present 100 mg/kg)
Transitional period
The current Directive 2009/48/EC shall be repealed on August 1, 2030. From that date, only Regulation 2025/2509 will apply. During the transitional period, both the Regulation and the Directive may be used to demonstrate compliance.
With a global network of toy laboratories and EU Notified Bodies in France and Germany, we help ensure full compliance with the EU Toy Safety Directive and future EU Toy Safety Regulation. Our internationally recognized laboratories are strategically located in key manufacturing zones and transit points worldwide. No matter where in Europe your toy will be sold, we help you meet sustainability goals and regulatory requirements.
Protect children and your brand – partner with us to navigate the complex EU Toy Safety Directive. Contact us to learn more, or visit our website. In the end, it’s only trusted because it’s tested.
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