EdLaw
Toy Safety Regulation (Regulation (EU) 2025/2509)
The EU's new toy-safety law, published in the Official Journal on 12 December 2025 (OJ L, 2025/2509) and in force since 1 January 2026 — but applying only from 1 August 2030 (Art. 59; the notified-body and delegated-powers chapters apply from 1 January 2026). It repeals the Toy Safety Directive 2009/48/EC with effect from 1 August 2030 (Art. 56), and toys placed on the market in conformity with the Directive before that date stay marketable (Art. 57(1)).
Until 31 July 2030, Directive 2009/48/EC is the operative toy-safety law — for current certification work consult it on EUR-Lex (see Sources); this folder reproduces the successor Regulation because that is what new-product planning must design against, including its headline addition: the digital product passport replacing the paper EC declaration of conformity (Art. 19).
Applicability to EdTech
- The classification question comes first. The Regulation applies to "products that are designed or intended, whether or not exclusively, for use in play by children under 14 years of age (toys)", judged by whether "a parent or supervisor can reasonably assume, by virtue of the functions, dimensions and characteristics of that product, that it is intended for use in play by children of a relevant age group" (Art. 2(1)) — with an excluded-products list in Art. 2(2)–(3). Classroom VR hardware and teaching devices are not designed or intended for play, but "whether or not exclusively" makes marketing and presentation load-bearing: a product pitched for games or child-led entertainment invites toy classification, which brings the full regime (essential safety requirements, digital product passport, toy-specific warnings).
- RED interaction: for toys with radio functions, the RED cybersecurity delegated requirements and EN 18031-2 already name toys and childcare equipment — see the RED README.
- Digital product passport (Arts. 19–23): required per toy from application, accessible via a data carrier — a supply-chain system change, not paperwork.
- Safety assessment before placing on the market (Art. 25), conformity routes at Art. 26, CE marking at Arts. 17–18.
Contents
| Document | Covers |
|---|---|
| SCOPE-AND-DEFINITIONS.md | Arts. 1–3 — scope, exclusions, definitions |
| SAFETY-REQUIREMENTS.md | Arts. 5–6 — essential safety requirements, warnings |
| OPERATOR-OBLIGATIONS.md | Arts. 7, 9, 10 — manufacturer/importer/distributor obligations |
| CONFORMITY-CE-AND-DPP.md | Arts. 15, 17–19, 25, 26 — presumption, CE marking, digital product passport, safety assessment, conformity routes |
| APPLICATION.md | Arts. 55–57, 59 — penalties, repeal of 2009/48/EC, transition, application from 1 August 2030 |
Scope note: fulfilment service providers and online marketplaces (Arts. 11, 14), the DPP technical articles (Arts. 20–23), notified-body machinery (Arts. 28–44), market surveillance (Arts. 45–48), ECHA opinions (Arts. 51–52) and the annexes (incl. Annex II particular safety requirements and its chemical rules) can be added with the same tooling when needed.
Key obligations at a glance
- Toys must meet the essential safety requirements — the general requirement plus Annex II particular requirements — including foreseeable use "bearing in mind the behaviour of children" (Art. 5).
- Warnings per Art. 6 (general and toy-category-specific, user-visible at purchase including online).
- Manufacturers: safety assessment (Art. 25), conformity assessment (Art. 26), digital product passport (Art. 19), CE marking (Arts. 17–18), plus the Art. 7 duties.
- Until 1 August 2030: comply with Directive 2009/48/EC instead; pre-2030 Directive-conformant stock stays marketable (Art. 57(1)).
Enforcement
National market surveillance under Regulation (EU) 2019/1020 (Arts. 45–48, not extracted); national penalties, "effective, proportionate and dissuasive" (Art. 55).
Related
- Product-safety cluster index
- Radio Equipment Directive — toys with radio functions carry RED duties today, including the Art. 3(3)(e) privacy requirement
- GPSR — the safety net for child-appealing products that are not toys
Sources
- EUR-Lex — Regulation (EU) 2025/2509 (Toy Safety Regulation), OJ text
- EUR-Lex — Directive 2009/48/EC (Toy Safety Directive), consolidated text — the operative law until 31 July 2030
Meta
Article text in the content documents is reproduced verbatim from the EUR-Lex OJ text (CELEX 32025R2509) and built/re-verified mechanically by tools/eur-lex/build_eu_product_safety.py (verify mode; do not hand-edit). Anchors: official ELI ids plus derived paragraph/point anchors from printed labels. Directive 2009/48/EC is deliberately NOT extracted here — it dies in 2030; if Directive-era provisions are needed for certification work before then, extract them into a sibling folder rather than mixing regimes.