SG 119/26
Montenegro introduces EU-aligned toy safety requirements.
On August 12, 2026, Montenegro published new Toy Safety Regulations (Official Gazette of Montenegro (OGM) No. 120/2026, ‘the Regulation’), transposing Directive 2009/48/EC on toy safety (Toy Safety Directive, TSD, current consolidated version to December 2022 and SafeGuardS 14/26 for reference) into national legislation.
Key provisions of the Regulation include:
- Requiring that only toys complying with essential and general safety requirements may be placed on the market
- Mandating manufacturers to conduct pre-market safety assessments to identify and evaluate any risks that a toy may present, including chemical, physical, mechanical, electrical, flammability, hygiene and radioactivity hazards.
- Specifying obligations for economic operators (manufacturers, authorized representatives, importers and distributors), including circumstances in which manufacturer obligations also apply to importers and distributors.
- Obliging toys placed on the market to bear the CE conformity marking
- Applying conformity assessment procedures using Montenegrin standards that are equivalent to the corresponding harmonized standards cited in the OGM to demonstrate presumption of conformity with essential and general safety requirements, as well as specific requirements for properties relating to physical and mechanical, flammability, chemical properties, electrical, hygiene and radioactivity (Annex 2).
- Specifying a list of 19 products that are not considered as toys (Annex 1)
- Establishing requirements for a declaration of conformity (DoC) for compliant toys (Annex 3)
- Authorizing manufacturers to draw up the technical documentation containing the information in Annex 4
- Prescribing that warnings are displayed in a clear, legible, understandable and accurate manner on the toy, an affixed label, or its packaging. Warnings and instructions must be provided in Montenegrin. Small toys without packaging must bear attached warnings, while specified toy categories are subject to additional warning and precautionary requirements (Annex 5)
- Specifying requirements for toys subject to an EC-type examination (Annex 7 ‘Module B-Type examination and Annex 8 ‘Module C-Conformity to type based on internal production control’)
- Introducing transitional provisions that will take effect upon Montenegro’s accession to the EU, including CE marking requirements and the replacement of national conformity assessment terminology with corresponding EU terms (e.g. EU DoC, EU-Type examination and notified body)
Who is impacted?
The Regulation affects stakeholders across the toy supply chain, including manufacturers, importers, retailers and other intermediaries operating in Montenegro.
When does it apply?
OGM No. 120/2026 became effective on August 13, 2026, and repealed OGM Nos. 4/15 (Toy Safety Regulations) and 65/24 (Amendments to the Toy Safety Regulations)
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