In February 2025, the European Union released Communication Paper C/2025/1032 on the draft Toy Safety Regulation (TSR), which aims to strengthen safety standards for the sale of toys in Europe and will replace the current Toy Safety Directive (Directive 2009/48/EC, TSD).
The TSR draft has made significant revisions to TSD, including (but not limited to) the following:
1. Clearly state that the following two types of products do not belong to toys:
Scooter for children weighing over 20 kilograms.
Books made entirely of paper or cardboard and without additional materials or components, intended for children over 36 months old.
2. Replacing the EU Declaration of Conformity (DoC) with a Digital Product Passport (DPP)
DPP is specific product data containing DoC and other information that can be accessed through electronic data carriers.
3. Psychological health and cognitive development
For toys that interact or connect with external devices (such as smart phones, tablets, the Internet or other smart devices) through digital technology, manufacturers need to consider the risks posed by products to children's mental health and cognitive development as part of the basic safety requirements.
4. Emphasize that online platform sales must comply with Article 22 of the General Product Safety Regulation (GPSR, (EU) 2023/988)
5. Improve the chemical safety assessment mechanism
Request to assess the risk of exposure to a single chemical substance and the combined exposure hazards of different chemicals in toys, while considering the obligations and requirements of the REACH regulation.
6. Expand the categories of carcinogenic, mutagenic, or reproductive toxic substances prohibited from use in toys:
Endocrine disruptors (ED) Class 1 or 2
Specific Target Organ Toxicity (STOT) Class 1
• Respiratory sensitization category 1
• Skin sensitization category 1
• Persistent, Bioaccumulation, Toxicity (PBT)
• High persistence, high bioaccumulation (vPvB)
• Persistent, high mobility (PMT)
• High persistence, high mobility (vPvM)
7. Add specific prohibited substances:
Prohibit the use of PFAS (perfluoroalkyl substances) and bisphenol substances in toys.
• It is prohibited to use essence in children's toys under 36 months old or other toys that can be imported.
8. Update migration requirements for specific elements
The migration of specific elements has been reduced from 19 to 15, separating chromium (VI), cadmium, mercury, and lead independently, with a total content not exceeding the detection limit.
9. Update the scope of restricted substances and requirements for some substances in Appendix C:
10. Requirements for updating sensitization essence:
• The limit of 58 restricted allergenic essence was reduced from 100 mg/kg to 10 mg/kg.
• 71 kinds of sensitized essence whose content exceeds a certain level and needs to be identified shall be updated from the previous content of more than 100 mg/kg to more than 10 mg/kg, and must also be listed in the digital product passport (DPP).
11. The word 'warning' can be replaced with the following icon:
Implementation schedule:
After the new toy regulation TSR comes into effect, there will be a 30 month transition period, but a few provisions will apply from the effective date. After the transition period ends, toys that have been released into the EU market and comply with the current Toy Directive TSD can continue to be sold on the market until inventory is sold out (up to 50 months).
